Alphagen Academy & Cortexa Learning System

Effective Date: 1st November 2025

1. Introduction

This Privacy Policy (“Policy”) is issued by Alphagen Academy Sdn Bhd, a company incorporated in Malaysia with its registered address at E-1-2, CBD3, Jalan Perdana, 63000 Cyberjaya, Selangor (“we,” “us,” or “our”). We are committed to protecting your personal data in accordance with the Personal Data Protection Act 2010 (“PDPA”) of Malaysia. This Policy explains how we collect, use, process, and protect your personal data, as well as the rights you have in relation to your personal data. By using our website and our learning system known as “Cortexa”, you agree to the terms of this Policy. If you do not agree, please do not use our website or services.

2. The Data We Collect

We may collect and process the following categories of personal data from you:

• Identity Data: Name, age, date of birth, identity card number or passport number.
• Contact Data: Residential address, email address, and phone number.
• Professional Data (For Learning Facilitators): If you register as an authorized Learning Facilitator, we may collect information regarding your teaching qualifications, professional affiliations, and class management logs.
• Usage Data: Information about how you use our website, including your IP address, browser type, and browsing activities.
• Sensitive Personal Data: In accordance with the PDPA, we may only collect sensitive personal data (such as health, political opinions, or religious beliefs) with your explicit consent.
• Personal Data from Minors: If you are a minor (under 18 years old), we may collect and process your personal data, but only with the consent or authorization of your parent or legal guardian.

3. The Purposes of Data Collection and Processing

We collect and process your personal data for the following purposes:

• To provide and operate our services: This includes the Cortexa learning system, educational games, content access, and user accounts.
• To Manage Educational Accounts: To verify Learning Facilitator credentials and enable class management features within the Cortexa system.
• To personalize your user experience: We use data to tailor the Cortexa learning environment and website to your needs.
• To communicate with you: Including responding to inquiries and providing customer support.
• To improve our products and services: Through research and analysis of usage trends.
• To Publish Testimonials: We may display personal testimonials of satisfied Students (Cadets) or parents on our website or marketing materials. We will obtain your consent prior to posting your name or image along with your testimonial.
• To manage your account: Processing registrations and payments, where applicable.
• To comply with legal obligations: Meeting our regulatory requirements under Malaysian law.
• To send promotional materials: We will only send marketing materials if you have given us your explicit consent. You have the right to opt-out at any time.

4. The Seven Personal Data Protection Principles

In line with the PDPA, we are committed to adhering to the following principles:

• General Principle: We will not process your personal data unless you have given your consent.
• Notice and Choice Principle: We will inform you of the purposes for which your data is collected and processed, and you have the choice to consent or not.
• Disclosure Principle: We will not disclose your personal data to a third party without your consent.
• Security Principle: We will take practical and reasonable steps to protect your personal data from loss, misuse, modification, unauthorized or accidental access, or disclosure.
• Retention Principle: We will only retain your personal data for as long as necessary to fulfill the purpose for which it was collected.
• Data Integrity Principle: We will take reasonable steps to ensure that your personal data is accurate, complete, and up-to-date.
• Access Principle: You have the right to access and correct your personal data.

5. Protection of Children’s Personal Data (under 18 years old)

We are committed to protecting the privacy of children who use our website and Cortexa system. As outlined in our Terms of Service, minors must use the Platform under parental or guardian supervision. If we intend to collect, use, or disclose the personal data of a minor (under 18 years old), we will:

• Obtain Verifiable Parental/Guardian Consent: We will make reasonable efforts to obtain the consent of a parent or legal guardian before collecting any personal data from a child.
• Explain Data Practices Clearly: We will provide clear information to parents and guardians about our data collection practices.
• Provide Parental Control: Parents and legal guardians have the right to review the data collected, request deletion, or refuse further collection of their child’s data.
• Limited Data Collection: We will not require a child to disclose more personal data than is reasonably necessary for their participation in an online activity.

6. Disclosure of Personal Data

We may disclose your personal data to the following third parties, provided you have given your consent and for the purposes stated in this Policy:

• Our service providers and business partners who assist us in providing our services (e.g., cloud hosting providers, payment processors).
• Governmental authorities, regulators, or law enforcement agencies, if required by law.
• Other entities in the event of a merger, acquisition, or sale of assets.

We will take reasonable steps to ensure that any third parties who process your data on our behalf comply with the PDPA.

7. Cross-Border Data Transfer

Your personal data may be transferred to and processed in countries outside of Malaysia. In such cases, We will ensure that the transfer is permitted under the PDPA and that the receiving country provides a level of protection for personal data that is comparable to or greater than that provided by the PDPA.

8. Your Rights as a Data Subject

You have the following rights under the PDPA:

• Right to Access: You may request access to your personal data held by us.
• Right to Correct: You may request to correct or update any of your personal data that is inaccurate, incomplete, or misleading.
• Right to Withdraw Consent: You may withdraw your consent to the processing of your personal data at any time.
• Right to Prevent Processing for Direct Marketing: You may object to the processing of your personal data for direct marketing purposes.

To exercise any of these rights, please contact our Data Protection Officer.

9. Cookies Policy

Our website and Cortexa system use cookies to enhance your experience. A cookie is a small text file placed on your device. We use cookies to remember your preferences, analyse traffic, and personalize content. You can manage your cookie preferences through your browser settings.

10. Changes to This Privacy Policy

We may update this Policy from time to time. We will post any changes on this page with a new effective date. We encourage you to review this Policy periodically to stay informed about how we are protecting your personal data.

11. Contact Us

If you have any questions about this Policy or our data protection practices, or if you wish to exercise your rights, please contact our Data Protection Officer at:

Name: Data Protection Officer (DPO) Chan Yi Siang

Address: Alphagen Academy Sdn Bhd, E-1-2, CBD3, Jalan Perdana, 63000 Cyberjaya, Selangor

Email: hello@alphagen-academy.my

Phone: 012-3063639