GDPR Notice

This notice is provided under Articles 13 and 14 of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the UK GDPR. It applies if you are located in the European Union, the European Economic Area or the United Kingdom, and it supplements the general Privacy Policy.

1. Data controller

The controller of your personal data is Steven Nagendran, an independent IT Architect and Instructor based in Kuala Lumpur, Malaysia. Contact: [email protected], +60126049973. I have not appointed a Data Protection Officer, as this is not required for processing of this scale.

2. Personal data I process

• Contact data you provide: name, email address, phone number and organisation
• Enquiry data: enquiry type and the content of your message
• Engagement data: proposals, correspondence and billing references, if we work together
• Technical data: IP address, browser type and request logs recorded by the hosting provider for security

3. Purposes and legal bases

• Responding to your enquiry: steps taken at your request before entering into a contract (Article 6(1)(b)), or my legitimate interest in answering professional enquiries (Article 6(1)(f)).
• Delivering an agreed engagement: performance of a contract (Article 6(1)(b)).
• Keeping the website secure: legitimate interest in protecting the site from abuse (Article 6(1)(f)).
• Business and tax records: compliance with a legal obligation (Article 6(1)(c)).
• Anything else: only with your consent (Article 6(1)(a)), which you can withdraw at any time.

4. Recipients of your personal data

Your personal data may be shared with:

• Processors acting on my behalf: website hosting, contact form delivery and email providers
• Google Fonts, which receives your IP address when your browser loads the website's fonts
• Training centres or partners involved in an engagement you requested, with your agreement
• Professional advisers and public authorities, where required by law

I do not sell your personal data.

5. International transfers

I am based in Malaysia, which does not have an EU or UK adequacy decision. When you contact me, your personal data is transferred to Malaysia because this is necessary to respond to your request (Article 49(1)(b)). Where service providers process personal data outside the EEA or UK, I rely on the safeguards they offer, such as Standard Contractual Clauses.

6. Retention

Enquiries that do not lead to an engagement are kept for no longer than 2 years. Engagement records are kept for up to 7 years to meet tax and accounting requirements. Personal data is then deleted or anonymised.

7. Your rights

Under the GDPR you have the right to:

• Access your personal data and receive a copy (Article 15)
• Have inaccurate data rectified (Article 16)
• Have your data erased (Article 17)
• Restrict processing (Article 18)
• Receive your data in a portable format (Article 20)
• Object to processing based on legitimate interests (Article 21)
• Withdraw consent at any time, without affecting earlier processing (Article 7(3))

To exercise any of these rights, email [email protected]. I will respond within one month, which may be extended by two further months for complex requests. I may need to verify your identity first.

8. Automated decision-making

I do not make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects for you.

9. Is providing your data required?

There is no legal or contractual requirement to provide personal data. However, without at least your name and email address I cannot respond to your enquiry.

10. Complaints

If you believe your personal data is being processed unlawfully, you have the right to lodge a complaint with the data protection supervisory authority in the EU or EEA country where you live or work, or with the Information Commissioner's Office (ICO) in the UK. I would appreciate the chance to address your concern first.

11. Changes to this notice

I may update this notice from time to time. The "Last updated" date at the top of this page shows when it was last revised.

12. Contact

For any question about this notice or your personal data, email [email protected] or use the contact page.