Legal
Privacy Policy
Last Updated: 6 July 2025 | Effective Date: 6 July 2025
Vellum Row ("we", "us", "our") takes the handling of personal data seriously. This policy explains what information we collect from people who use our website or engage our estate records services, how we use it, and how we protect it. It applies to services delivered from our office at Level 3, Wisma Bukit Mata, Jalan Tunku Abdul Rahman, 93100 Kuching, Sarawak, Malaysia.
Our services operate under Malaysian law, including the Personal Data Protection Act 2010 (PDPA). Questions about this policy may be sent to [email protected].
1. Data We Collect
We collect personal data only where it is needed to respond to an enquiry, deliver a service, or keep this website functioning. The categories below cover what we typically hold:
- Contact information — name, email address, and telephone number, where provided through the enquiry form or by email.
- Engagement information — descriptions of items or documents in scope, collection and delivery addresses, and communication exchanged during an active engagement.
- Website interaction data — approximate location, browser type, pages visited, and duration of visit, collected through analytics cookies where consent has been given.
- Cookie preference data — your choices regarding optional cookies, stored locally in your browser.
We do not ask for identity documents, financial account numbers, or other sensitive categories of personal data through our website or enquiry process.
2. How We Use Personal Data
- Responding to enquiries — legal basis: legitimate interest in responding to communications directed to us.
- Delivering contracted services — legal basis: performance of a contract, where an engagement agreement is in place.
- Website analytics — legal basis: consent, given via the cookie modal. You may withdraw consent at any time through our Cookie Policy page.
- Legal and regulatory obligations — legal basis: compliance with applicable law, including record-keeping requirements under Malaysian law.
We do not use personal data for advertising profiling, and we do not sell personal data to any third party.
3. Data Sharing
We share personal data only in the following circumstances:
- Service providers — hosting and email infrastructure operated by third-party providers under data processing agreements. These providers do not use client data for their own purposes.
- Analytics services — where analytics cookies have been accepted, anonymised usage data may be processed by analytics providers.
- Legal requirement — where disclosure is required by law, court order, or a competent Malaysian authority.
Documents and records belonging to clients are not shared with any third party without explicit written instruction from the client, regardless of other provisions in this section.
4. Data Retention
We retain personal data for the following periods:
- Enquiry records (no engagement entered) — 12 months from the date of last contact, then deleted.
- Engagement records (active and completed) — 7 years from engagement close, in line with standard Malaysian record-keeping practice for commercial engagements.
- Website analytics data — aggregated and anonymised within 26 months of collection; raw session data deleted within 14 months.
5. Data Protection Measures
- This website uses HTTPS throughout. Data submitted via our enquiry form is transmitted over an encrypted connection.
- Email correspondence is stored on servers operated by our hosting provider within secure data centres.
- Physical documents handled during engagements are kept in our locked Kuching office during the engagement period and returned at handover.
- Access to client records within our office is limited to team members directly involved in the relevant engagement.
- In the event of a data breach that is likely to result in a risk to the rights or freedoms of individuals, we will notify affected persons and, where required, the relevant authority within a reasonable period of becoming aware of the breach.
6. Cookies
We use essential cookies to keep the site working and optional analytics cookies where consent has been given. Full details, including how to adjust your preferences, are in our Cookie Policy.
7. Your Rights
Under Malaysia's Personal Data Protection Act 2010, and where applicable under other data protection legislation, you have the following rights:
- Right of access — to request a copy of the personal data we hold about you.
- Right to correction — to request that inaccurate data be corrected.
- Right to withdraw consent — to withdraw consent to processing based on consent (including analytics cookies) at any time, without affecting processing carried out before withdrawal.
- Right to object — to object to processing carried out on the basis of legitimate interest, where you have grounds relating to your particular situation.
- Right of erasure — to request deletion of personal data where no legal basis for retention applies.
To exercise any of these rights, contact [email protected]. We will respond within 21 working days. Where a request is declined, we will explain the reason.
If you consider our handling of your personal data to be in breach of applicable law, you may lodge a complaint with the Personal Data Protection Commissioner of Malaysia.
8. Third-Party Links
Our website may contain links to external sites, including mapping services and reference pages. We are not responsible for the privacy practices of any third-party site. We encourage you to review the privacy policy of any external site before submitting personal data.
9. Children's Privacy
Our services are directed at adults. We do not knowingly collect personal data from persons under the age of 18. If we become aware that personal data from a minor has been submitted to us, we will delete it promptly and notify the submitting party.
10. Changes to This Policy
We may update this policy from time to time. Material changes will be indicated by a revised "Last Updated" date at the top of this page. Continued use of our website or services after an update constitutes acceptance of the revised policy. We encourage you to review this page periodically.
Contact for Data-Related Enquiries
Data Controller
Vellum Row
Level 3, Wisma Bukit Mata
Jalan Tunku Abdul Rahman
93100 Kuching, Sarawak, Malaysia
Privacy Contact
Please mark the subject line "Privacy Enquiry" for a faster response. We aim to respond within 21 working days.