PRIVACY POLICY

Circle Advisory Mobile Application
Effective Date: February 2026

Owned and operated by:
Mohd Abdullah (trading as Circle Advisory)
Sole Proprietorship registered in Malaysia
Kuala Lumpur, Malaysia

1. Introduction

This Privacy Policy explains how Circle Advisory (“we”, “us”, “our”) collects, uses, processes, stores and protects your personal data in accordance with the Personal Data Protection Act 2010 (Malaysia) (“PDPA”).

By using our mobile application (“App”), you consent to the collection and processing of your personal data as described in this Policy.

This Privacy Policy should be read together with our Terms of Use.

2. Role of Platform Provider

The App is powered by FitBudd Inc. (“Platform Provider”), which provides the technical infrastructure.

• Circle Advisory acts as the data user under PDPA.
• FitBudd acts as a data processor providing hosting and technical support services.

We require the Platform Provider to maintain reasonable security safeguards over your personal data.

3. Personal Data We Collect

We may collect the following categories of personal data:

3.1 Identification Information

• Full name
• NRIC/passport (if voluntarily provided)
• Age
• Gender
• Email address
• Phone number

3.2 Health & Fitness Information

• Height, weight, body measurements
• Medical conditions (if voluntarily disclosed)
• Fitness goals
• Progress photos
• Workout performance data
• Nutrition logs

3.3 Account Information

• Username
• Password (encrypted)
• Communication history

3.4 Payment Information

Payments are processed through third-party payment gateways.

We do not store:

• Full credit card numbers
• CVV numbers

Payment processors may collect financial data directly in accordance with their own privacy policies.

3.5 Technical Information

• IP address
• Device type
• Browser type
• Usage analytics
• Cookies or similar technologies

4. Purpose of Collecting Personal Data

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

• To create and manage your account
• To provide coaching and fitness services
• To track progress and personalise programs
• To process payments
• To communicate service updates
• To improve user experience
• To comply with legal obligations
• To resolve disputes or enforce agreements

We will not process your personal data for unrelated purposes without your consent.

5. Health Information

Certain data you provide (e.g., medical conditions, injuries, photos) may constitute sensitive personal data under PDPA.

By voluntarily providing such information, you:

• Explicitly consent to its processing for coaching purposes
• Confirm the information is accurate to the best of your knowledge

We will use such data strictly for fitness and coaching purposes.

6. Disclosure of Personal Data

We may disclose your personal data to:

• Platform providers (FitBudd)
• Payment processors
• Professional advisers (accountants, legal advisers)
• Government authorities when required by law

We do not sell or rent your personal data to third parties.

7. Data Security

We implement reasonable administrative, technical and physical safeguards to protect personal data, including:

• Secure server hosting
• Encrypted data transmission (SSL)
• Access control restrictions

However, no internet transmission is completely secure. While we strive to protect your data, we cannot guarantee absolute security.

8. Data Retention

We retain personal data only for as long as necessary to:

• Provide services
• Fulfil contractual obligations
• Comply with legal requirements
• Resolve disputes

Upon account termination, personal data may be deleted unless retention is required by law.

9. Data Access and Correction (Your Rights Under PDPA)

Under the PDPA, you have the right to:

• Request access to your personal data
• Request correction of inaccurate data
• Withdraw consent (subject to contractual and legal limitations)

Requests may be made to:
📧 admin@circleadvisory.my

We may charge a reasonable administrative fee for data access requests as permitted under PDPA.

10. Data Deletion Requests

You may request deletion of your account and associated personal data via:

• The in-app deletion function, or
• Email to admin@circleadvisory.my

We will process deletion requests within a reasonable time, except where:

• Retention is required by law
• Data is necessary for resolving disputes
• Data is required to enforce agreements

Anonymised data may be retained for analytics.

11. Cross-Border Data Transfer

Your data may be stored on servers located outside Malaysia due to cloud hosting services.

Where personal data is transferred outside Malaysia, we take reasonable steps to ensure adequate protection consistent with PDPA requirements.

12. Marketing Communications

We may send you service-related communications.

Marketing emails will only be sent if:

• You have consented, or
• It relates to similar services you have purchased

You may opt out at any time using the unsubscribe link or by contacting us.

13. Cookies and Tracking Technologies

The App may use cookies or similar technologies to:

• Improve functionality
• Analyse usage patterns
• Enhance user experience

You may adjust device settings to limit tracking, though some features may be affected.

14. Third-Party Links

The App may contain links to third-party websites.

We are not responsible for the privacy practices of third-party sites.

15. Children's Privacy

The App is not intended for individuals under 18 without parental consent.

We do not knowingly collect personal data from minors without guardian consent.

16. Limitation of Liability

While we take reasonable steps to protect personal data, we shall not be liable for:

• Unauthorised access beyond our reasonable control
• Data breaches caused by third-party platform providers
• User negligence in safeguarding login credentials

Nothing in this clause excludes liability that cannot be excluded under Malaysian law.

17. Updates to This Policy

We may update this Privacy Policy from time to time.

Material changes will be notified via:

• App notification
• Email (where available)

Continued use of the App constitutes acceptance of updates.

18. Contact Information

For privacy-related enquiries:

Circle Advisory
Attn: Mohd Abdullah
Email: admin@circleadvisory.my
Kuala Lumpur, Malaysia