Privacy Policy

1. Introduction

Gradient Owl ("we", "us", "our") is an online school for AI development operated as a registered business in Malaysia, with a principal place of business at 12A Jalan SS 15/4B, Subang Jaya, 47500 Selangor. We take the protection of personal data seriously and handle all information we collect in line with the Malaysian Personal Data Protection Act 2010 (PDPA) and applicable regulations.

This policy explains what personal data we collect when you use our website, how we use it, who we share it with, how we protect it, and what rights you have. If you have questions after reading this policy, write to us at [email protected].

This policy applies to data collected through the Gradient Owl website at gradientq.cyou and through our course enrolment and communication processes. It does not apply to any third-party websites we may link to.

2. Personal Data We Collect

We collect personal data in the following ways:

Information you provide directly:

• Full name and email address submitted through our enquiry form
• Phone number, if provided voluntarily in the form
• Message content you include when submitting an enquiry
• Enrolment details including course selection and payment information collected during the enrolment process

Information collected automatically:

• Basic browser and device information (browser type, operating system, screen resolution)
• IP address and general geographic location derived from it
• Pages visited on our website, time on page, and referral source
• Cookie-related preferences you have set (see Section 5)

Legal basis for processing: We process your personal data on the basis of your consent (when you submit our enquiry form), for the performance of a contract (when processing your enrolment), and for our legitimate interests in operating and improving our educational services. You may withdraw consent at any time by contacting us.

Data retention: Enquiry data is retained for 12 months. Enrolment and course records are retained for 7 years to meet our business record-keeping obligations. You may request earlier deletion where we are not under a legal obligation to retain the data.

3. How We Use Your Data

We use the personal data we collect for the following purposes:

• Responding to your enquiries about our courses and availability
• Processing course enrolments and managing your access to course materials
• Sending course-related communications including session schedules, exercise feedback, and cohort updates
• Issuing written records of course completion at the end of each track
• Improving our website and course content based on usage patterns
• Meeting legal obligations and maintaining business records

We do not use your personal data to send unsolicited marketing communications. If you are an enrolled learner, we may send you information about upcoming intakes relevant to your completed track — you may opt out of these messages at any time by writing to us.

Third-party sharing: We do not sell, rent, or trade your personal data to third parties. We may share data with service providers who assist us in operating the website and delivering course infrastructure (such as cloud hosting and communication tools), under written agreements that require them to protect your data. We will disclose personal data to authorities if required to do so by law.

4. Data Protection Measures

We implement the following measures to protect personal data:

• HTTPS encryption for all data transmitted between your browser and our website
• Access to personal data restricted to staff members who need it to perform their role
• Course and enrolment records stored on servers located in Malaysia or Singapore
• Regular review of access permissions and data handling practices
• Staff awareness of data handling obligations under the PDPA

In the event of a personal data breach that is likely to cause harm, we will notify affected individuals and, where required, the relevant authorities, within a reasonable timeframe.

5. Cookies

Our website uses cookies to manage essential site functionality and, where you have consented, to support analytics. The following categories of cookies may be present:

• Essential cookies: Required for the site to function. These are set automatically and cannot be disabled.
• Analytics cookies: Used to understand how visitors use the site. Set only with your consent.
• Preference cookies: Remember choices you have made, such as your cookie consent decision. Set with your consent.

You can manage your cookie preferences at any time on our Cookie Policy page.

6. Your Rights Under the PDPA

Under the Malaysian Personal Data Protection Act 2010, you have the following rights regarding your personal data that we hold:

• Right of access: Request a copy of the personal data we hold about you.
• Right of correction: Request correction of inaccurate or incomplete personal data.
• Right to withdraw consent: Withdraw consent to processing at any time, where processing is based on consent.
• Right to limit processing: Request that we limit how we use your data in certain circumstances.
• Right to prevent processing for marketing: Request that we stop using your data for direct marketing purposes.

To exercise any of these rights, write to us at [email protected] with your name and a description of your request. We will respond within 21 days. If you are not satisfied with our response, you may raise the matter with the Department of Personal Data Protection Malaysia (PDPD).

7. Third-Party Links

Our website may contain links to external websites — for example, to documentation, tools, or resources referenced in our course content. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policy of any external site before submitting personal data there.

8. Age Restrictions

Our courses are intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have collected data from a minor, we will delete it without undue delay. If you believe a minor has submitted data to us, please contact us at [email protected].

9. Changes to This Policy

We may update this policy from time to time to reflect changes in our practices or in applicable law. When we make material changes, we will update the "Last Updated" date at the top of this page. Continued use of our website after a change is posted constitutes acceptance of the updated policy. We encourage you to review this page periodically.

10. Contact Us About Data Matters

For any questions about this policy or about how we handle your personal data, please contact us:

• Email: [email protected]
• Address: Gradient Owl, 12A Jalan SS 15/4B, Subang Jaya, 47500 Selangor, Malaysia
• Phone: +60 3-7614 2098 (office hours: Mon–Fri 6–10 pm, Sat 9 am–1 pm)