PRIVACY POLICY

Last Updated: 1st January 2026
Data Controller: Sublime Telecom Sdn Bhd (Company No. 1056012-A | Company Reg (SSM): 201301026182 | D-U-N-S Number: 66-0137-024)
Appointed Data Protection Officer (DPO) Contact: shops@sublimetele.com

Sublime Telecom Sdn Bhd ("Sublime Telecom", "Company", "we", "us", or "our") operates as a premier telecommunications hardware, enterprise networking, and technical services provider in Malaysia. We value your digital trust and are fully committed to protecting your personal data.

This Privacy Policy ("Policy") informs you of our practices regarding the collection, processing, use, storage, disclosure, and transfer of your personal data when you interact with our official website, technical support systems, professional training portals, and our official brand storefronts across integrated third-party ecommerce marketplaces (including but not limited to Shopee and Lazada).

This Policy is formulated in strict alignment with the Malaysia Personal Data Protection Act 2010 (PDPA), including all subsequent amendments and guidelines issued by the Department of Personal Data Protection (JPDP).

1. Personal Data We Collect
We collect information necessary to deliver enterprise-grade hardware, precise technical assistance, and specialized educational programs. The types of personal data we process include:

• Identity & Corporate Information: Full name, corporate title, company name, business registration numbers (SSM/MyCoID), national identity card number (NRIC), or passport number.
• Contact Credentials: Corporate or personal billing address, shipping address, telephone number, and email address.
• Transactional & Financial Data: Bank account numbers, payment receipts, purchase history, corporate credit terms, and credit assessment records.
• Technical Support Logs: Network topology layout maps, hardware configurations, system logs, remote access authorizations, and records of communication with our support helpdesk.
• Educational & Professional Data: Training attendee names, professional certifications sought, previous networking qualifications, and performance assessments.
• Digital Identity Markers: IP address, device telemetry, browser metadata, operating system data, and behavioral tracking data captured via tracking cookies.

2. Source of Personal Data
We gather your information through various direct and indirect operational touchpoints:

A. Direct Interactions

• When you set up a corporate account on our procurement portal.
• When you submit a technical support ticket or initiate a live chat session.
• When you register employee cohorts into our certified training courses.
• When you fill out hardware product warranty registration forms.

B. Third-Party Marketplace Integrations

• When you place hardware orders through our official stores on third-party platforms (e.g., Shopee and Lazada). The marketplace securely transmits your name, contact phone number, shipping address, and item specifics to our unified Enterprise Resource Planning (ERP) logistics system to complete fulfillment.

C. Automated Technologies

• Tracking tools such as the Meta Pixel, Google Analytics 4, and marketplace collaborative advertising trackers that log your navigation choices when you consent to our Cookie Policy.

3. Purposes of Processing Personal Data
Sublime Telecom processes your personal data strictly for specified, lawful commercial functions:

4. Disclosure and Third-Party Transfers
To maintain operational continuity, Sublime Telecom may selectively share your data under rigorous confidentiality frameworks with the following categories of third parties:

1. Logistics & Delivery Partners: Trusted local courier networks (e.g., PosLaju, GDEX, DHL) to successfully drop-ship enterprise hardware to your location.
2. Financial Ecosystems: Secure, accredited local e-payment gateways, FPX processors, and banking institutions to clear financial transactions safely.
3. Upstream Equipment Manufacturers (OEMS): Global telecommunications equipment manufacturers to register corporate software licensing, enterprise warranties, or process specialized RMA hardware exchanges.
4. Regulatory Bodies & Corporate Auditing: Statutory bodies, including the Inland Revenue Board (LHDN), HRD Corp (for training tracking), or law enforcement entities when required by binding legal process.
5. Marketing Platform Providers: Ad networks and social media platforms (e.g., Meta, Google) where hashed, pseudonymous identifiers are securely matched to build highly relevant advertising audiences.

5. Security & International Data Transfers

5.1 Technical and Organizational Security: In compliance with the Security Principle of the PDPA, Sublime Telecom implements robust safeguards. These include end-to-end transport layer security (SSL/TLS encryption), automated vulnerability assessments, perimeter firewalls, and restricted operational access policies for personnel handling technical client logs.

5.2 Cross-Border Transfers: Because our upstream manufacturing partners and localized cloud database infrastructure may operate outside Malaysia, your personal data may occasionally be transferred across international borders. Sublime Telecom ensures that all recipient entities provide a level of data protection equivalent to or exceeding the mandates of the Malaysia PDPA.

6. Retention Period
We retain your personal data only for as long as necessary to fulfill the operational purposes detailed in Section 3 of this document, or to comply with overarching statutory, accounting, and consumer defense laws in Malaysia (such as the 7-year records retention standard mandated under the Income Tax Act 1967). When personal data is no longer required, it is securely destroyed or permanently anonymized.

7. Your Statutory Rights Under the PDPA
As a data subject in Malaysia, you hold full legal rights over your personal footprint. You can exercise these rights at any point by reaching out to our Data Protection Officer:

• Right of Access: Request a complete structural copy of the personal data we hold about you.
• Right of Correction: Request immediate rectifications to outdated, incomplete, or inaccurate records.
• Right to Withdraw Consent: Terminate your voluntary consent for specific processing modules, such as digital advertising pixels or marketing newsletters.
• Right to Restrict Processing: Request a temporary halt on data processing if you contest its accuracy or legal basis.

Sublime Telecom will endeavor to acknowledge and fulfill verified access and correction requests within twenty-one (21) days of receipt, in accordance with standard PDPA operational guidelines.
Please note that choosing to withdraw your consent for primary data streams (such as billing data or support access logs) may prevent us from completing future hardware sales or providing technical troubleshooting assistance.

8. Amendments to This Policy
Sublime Telecom reserves the right to modify or refresh this Privacy Policy periodically to reflect shifts in our business methods, marketplace APIs, or updates to Malaysian digital regulatory laws. Notice of material changes will be broadcast prominently across our primary e-commerce portals.

9. Language Prevailing Clause
In accordance with Section 7(3) of the PDPA, this Privacy Policy is issued in both English and Bahasa Malaysia. In the event of a structural conflict, ambiguity, or operational dispute between the two language frameworks, the English version shall take precedence.

10. Changes to This Policy
We reserve the right to update this Privacy Policy from time to time. The latest version will always be published on this page together with its effective date.

11. Contact Us
If you have questions regarding this Privacy Policy or your personal information, please contact:
Sublime Telecom Sdn Bhd
Address: 22nd Floor, Strata Office, SO-22-3A, 3, Jalan Bangsar, KL Eco City, 59200 Kuala Lumpur, Wilayah Persekutuan Kuala Lumpur
Email: shops@sublimetele.com
Telephone: 03-2303 0246
Business Hours: Monday - Friday: 9:30am - 5:30pm | Saturday: 10am - 2pm