PDPA Privacy Policy

1. Introduction

PresenceQuotient ("we", "us", or "our") is committed to protecting your personal data in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our platform.

2. Data Controller

PresenceQuotient operates as the data controller responsible for your personal data. By using our platform, you consent to the collection and processing of your personal data as described in this Policy.

3. Personal Data We Collect

We may collect the following categories of personal data:

• Identity Data: Full name, username, profile photo
• Contact Data: Email address, phone number
• Voice & Biometric Data: Voice samples you upload for AI persona training
• Content Data: Scripts, knowledge base entries, documents you submit
• Technical Data: IP address, browser type, device identifiers, usage logs
• Transaction Data: Access group codes, subscription and usage records

4. Purpose of Data Collection (Seven Principles)

Under PDPA, we collect your personal data only for lawful purposes, including:

• Providing and personalising the PresenceQuotient platform and services
• Training and operating your AI Persona on your behalf
• Managing your account, access codes, and group membership
• Communicating important service updates and notifications
• Complying with legal obligations under Malaysian law
• Improving platform security, performance, and user experience

5. Disclosure of Personal Data

We do not sell, rent, or trade your personal data. We may share your data only with:

• Service Providers: Third-party vendors who assist in delivering our platform (e.g., cloud hosting, AI APIs), bound by data processing agreements
• Legal Authorities: When required by Malaysian law, court order, or government regulation
• Business Transfers: In the event of a merger or acquisition, with appropriate data protection safeguards

6. Your Rights Under PDPA

As a data subject under the PDPA, you have the right to:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete personal data
• Withdraw Consent: Withdraw your consent to our processing of your data at any time (subject to legal or contractual restrictions)
• Limit Processing: Request that we limit processing of your data in certain circumstances

To exercise your rights, contact us at shiftbytic@image-creator.com. We will respond within 21 days as required under the PDPA.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by Malaysian law. Voice and biometric data will be deleted within 30 days of account closure upon request.

8. Data Security

We implement appropriate technical and organisational measures to safeguard your personal data against unauthorised access, loss, or disclosure, including encryption, access controls, and secure cloud infrastructure.

9. Overseas Transfer

Your data may be transferred to and processed in countries outside Malaysia. Where such transfers occur, we ensure equivalent levels of data protection are in place, consistent with PDPA requirements.

10. Cookies & Tracking

Our platform uses cookies and similar technologies to improve your experience. You may control cookie preferences through your browser settings. Disabling cookies may affect certain platform features.

11. Updates to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes via email or a prominent notice on the platform. Continued use of PresenceQuotient after changes constitutes acceptance of the updated Policy.

12. Contact Us

For any queries, concerns, or complaints regarding your personal data or this Policy, please contact our Data Protection Officer: