Privacy Policy

We collect personal data only when you provide it to us or when it is generated through your use of our website. The categories of data we may collect include:

• Contact information: full name, email address, phone number
• Enquiry content: the message or situation description you submit through our contact form
• Technical data: IP address, browser type, pages visited, and session duration (collected automatically through analytics tools, if enabled)
• Cookie consent preferences stored in your browser's local storage

We do not collect payment card details through this website. Invoicing and payment are handled separately through secure channels.

Legal basis: Data submitted through our contact form is processed on the basis of your consent (via form submission) and for the purpose of fulfilling a potential contractual relationship. Technical analytics data is collected on the basis of our legitimate interest in understanding how our website is used.

Retention: Enquiry data is retained for up to 24 months from the date of last contact, or for the duration of an active advisory engagement. Technical analytics data is retained for up to 12 months. You may request deletion at any time (see Section 6).

Personal data collected through this website is used for the following purposes:

• Responding to your enquiry and providing advisory services
• Communicating about engagement scope, scheduling, and deliverables
• Sending administrative communications related to your engagement
• Improving the content and usability of our website (analytics data only)
• Complying with applicable legal obligations

We do not use your personal data for unsolicited marketing communications. If you wish to receive updates from Lumen Array, we will seek your explicit consent separately.

Third-party services: We may use third-party analytics tools (such as Google Analytics) to understand website usage. These tools may set cookies and process technical data about your visit. See Section 5 for cookie details.

We do not sell, rent, or trade personal data with third parties. We may share data in the following limited circumstances:

• With service providers who assist us in operating our website or delivering services (e.g. email platforms, document storage), subject to data processing agreements
• Where required by applicable law, regulation, or court order
• In the context of a business transfer, merger, or acquisition, provided the receiving party agrees to honour this policy

Architecture details, workload data, and strategic information shared during advisory engagements are treated as strictly confidential and are not used for any purpose beyond delivering the engagement.

We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include:

• HTTPS encryption for all data transmitted through this website
• Access controls limiting who within Lumen Array can access personal data
• Use of reputable third-party service providers with adequate security certifications
• Regular review of data handling practices

In the event of a data breach that affects your personal data, we will notify you within a reasonable timeframe in accordance with applicable law.

This website uses cookies and similar technologies. Essential cookies are required for the website to function. Optional cookies (analytics, marketing, preferences) are only placed with your consent, which you provide or withdraw through the cookie banner or through our Cookie Policy page.

For full details of the cookies we use and how to manage them, see our Cookie Policy.

Under Malaysia's Personal Data Protection Act 2010, you have the following rights with respect to your personal data:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to correction: You may request that inaccurate or incomplete data be corrected.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
• Right to limit processing: You may request that we stop using your data for certain purposes.
• Right to lodge a complaint: You may raise concerns with the Personal Data Protection Commissioner of Malaysia (pdp.gov.my).

To exercise any of these rights, contact us at [email protected]. We will respond within 21 days.

Data Controller: Lumen Array Sdn. Bhd.

Address: Level 7, Menara UOA Bangsar, 5 Jalan Bangsar Utama 1, 59000 Kuala Lumpur, Malaysia

Email: [email protected]

Phone: +60 3-2287 6041

For data protection enquiries, use the email address above. We aim to respond to all privacy-related requests within 21 calendar days.