Effective Date: 18 November 2025

Governing Law: Personal Data Protection Act 2010 (PDPA), Malaysia

1. Introduction

CognitiveFlow Malaysia ("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.

2. Data Controller

CognitiveFlow Malaysia is the data controller responsible for your personal data. For any privacy-related inquiries, contact us at privacy@cognitiveflow.my.

3. Personal Data We Collect

We collect the following types of personal data:

• Identity Data: Full name, age, gender
• Contact Data: Email address, phone number, mailing address
• Technical Data: IP address, browser type, device information, cookies
• Usage Data: Information about how you use our website and services
• Assessment Data: Cognitive challenge descriptions, clarity level ratings, training progress
• Communication Data: Records of correspondence and support inquiries

4. How We Collect Your Data

We collect personal data through:

• Direct interactions when you complete forms, register for services, or contact us
• Automated technologies including cookies, server logs, and analytics tools
• Third-party sources such as payment processors and analytics providers

5. Purpose and Legal Basis for Processing

We process your personal data for the following purposes under PDPA:

• Service Delivery: To provide cognitive training services and support
• Communication: To respond to inquiries and send service-related notifications
• Marketing: To send promotional materials (with your consent)
• Analytics: To improve our website and services
• Legal Compliance: To comply with Malaysian legal obligations
• Security: To protect against fraud and unauthorized access

6. Data Disclosure and Sharing

We may share your personal data with:

• Service Providers: Third-party vendors who assist in operations (hosting, payment processing, analytics)
• Legal Authorities: When required by Malaysian law or to protect our rights
• Business Transfers: In the event of a merger, acquisition, or sale of assets

We do not sell your personal data to third parties.

7. International Data Transfers

Your data may be transferred to and stored in servers located outside Malaysia. We ensure appropriate safeguards are in place to protect your data in accordance with PDPA requirements.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and updates
• Staff training on data protection practices

9. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy or as required by Malaysian law. Typically:

• Account Data: Retained for the duration of your account plus 7 years
• Marketing Data: Retained until you withdraw consent
• Transaction Records: Retained for 7 years in accordance with Malaysian tax and accounting requirements

10. Your Rights Under PDPA

Under the Personal Data Protection Act 2010, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Correction: Request correction of inaccurate or incomplete data
• Right to Withdraw Consent: Withdraw consent for processing at any time
• Right to Limit Processing: Request limitation of data processing in certain circumstances
• Right to Data Portability: Request transfer of your data to another service provider

To exercise these rights, contact us at privacy@cognitiveflow.my.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance user experience. For detailed information, please refer to our Cookie Policy.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

13. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors without parental consent.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

15. Contact Information

For questions or concerns about this Privacy Policy or our data practices, contact us:

• Email: privacy@cognitiveflow.my
• General Inquiries: hello@cognitiveflow.my
• Address: Kuala Lumpur, Malaysia

16. Complaints

If you believe your personal data has been mishandled, you have the right to lodge a complaint with the Personal Data Protection Commissioner of Malaysia.

Effective Date: 18 November 2025

Jurisdiction: Malaysia

1. Agreement to Terms

By accessing or using the services provided by CognitiveFlow Malaysia ("we," "us," or "our"), you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, please discontinue use of our services immediately.

2. Services Description

CognitiveFlow Malaysia provides cognitive training programs, mental clarity workshops, and structured thinking resources designed to enhance cognitive performance. Our services include online training modules, assessments, and personalized support.

3. Eligibility

You must be at least 18 years of age to use our services. By using our services, you represent and warrant that you meet this age requirement and have the legal capacity to enter into these Terms.

4. Account Registration

To access certain features, you may be required to create an account. You agree to:

• Provide accurate, current, and complete information
• Maintain the security of your account credentials
• Notify us immediately of any unauthorized access
• Accept responsibility for all activities under your account

5. Acceptable Use Policy

You agree not to:

• Use our services for any unlawful purpose or in violation of Malaysian law
• Transmit harmful code, viruses, or malicious software
• Attempt to gain unauthorized access to our systems
• Interfere with or disrupt the integrity or performance of our services
• Collect or harvest personal data of other users without consent
• Reproduce, duplicate, or resell our proprietary materials without authorization
• Misrepresent your affiliation with any person or entity

6. Intellectual Property Rights

All content, materials, trademarks, and intellectual property on our platform are owned by or licensed to CognitiveFlow Malaysia. This includes but is not limited to:

• Training materials and course content
• Software and applications
• Graphics, logos, and design elements
• Text, images, and multimedia content

You are granted a limited, non-exclusive, non-transferable license to access and use our services for personal, non-commercial purposes only.

7. Payment Terms

Certain services may require payment. You agree to:

• Provide valid payment information
• Pay all applicable fees as described at the time of purchase
• Accept responsibility for all charges incurred under your account
• Acknowledge that all fees are in Malaysian Ringgit (MYR) unless otherwise stated

Prices are subject to change with reasonable notice. Subscription fees are billed in advance on a recurring basis.

8. Refund Policy

Our refund policy is detailed in our separate Refund Policy. Generally, we offer a 14-day money-back guarantee for eligible services in accordance with Malaysian consumer protection law.

9. User Content

You retain ownership of any content you submit through our services. By submitting content, you grant us a non-exclusive, worldwide, royalty-free license to use, reproduce, and display your content solely for the purpose of providing and improving our services.

10. Disclaimers and Limitation of Liability

Our services are provided "as is" without warranties of any kind. To the maximum extent permitted by Malaysian law:

• We do not guarantee specific cognitive improvements or results
• We are not liable for any indirect, incidental, or consequential damages
• Our total liability shall not exceed the amount you paid for services in the past 12 months
• We do not provide medical or psychological advice; our services are educational in nature

11. Indemnification

You agree to indemnify and hold harmless CognitiveFlow Malaysia, its officers, directors, employees, and agents from any claims, damages, losses, or expenses arising from your use of our services or violation of these Terms.

12. Service Modifications and Termination

We reserve the right to:

• Modify, suspend, or discontinue any aspect of our services at any time
• Terminate or suspend your account for violation of these Terms
• Refuse service to anyone for any reason at our sole discretion

Upon termination, your right to use our services ceases immediately.

13. Governing Law and Dispute Resolution

These Terms are governed by the laws of Malaysia. Any disputes shall be resolved through:

• Good faith negotiations between parties
• Mediation if negotiations fail
• Jurisdiction of Malaysian courts if mediation is unsuccessful

The venue for any legal proceedings shall be Kuala Lumpur, Malaysia.

14. Privacy and Data Protection

Your use of our services is also governed by our Privacy Policy, which complies with the Personal Data Protection Act 2010 (PDPA) of Malaysia.

15. Severability

If any provision of these Terms is found to be unenforceable or invalid under Malaysian law, that provision shall be limited or eliminated to the minimum extent necessary, and the remaining provisions shall remain in full force and effect.

16. Entire Agreement

These Terms, together with our Privacy Policy and Refund Policy, constitute the entire agreement between you and CognitiveFlow Malaysia regarding the use of our services.

17. Changes to Terms

We reserve the right to update these Terms at any time. Changes will be effective immediately upon posting. Your continued use of our services after changes constitutes acceptance of the modified Terms.

18. Contact Information

For questions about these Terms, contact us:

• Email: legal@cognitiveflow.my
• General Inquiries: hello@cognitiveflow.my
• Address: Kuala Lumpur, Malaysia

Effective Date: 18 November 2025

Governing Law: Consumer Protection Act 1999, Malaysia

1. Overview

CognitiveFlow Malaysia is committed to customer satisfaction. This Refund Policy outlines the conditions under which refunds are available, in accordance with Malaysian consumer protection law.

2. 14-Day Money-Back Guarantee

We offer a 14-day money-back guarantee on eligible services. If you are not satisfied with your purchase, you may request a full refund within 14 days of the initial purchase date.

3. Eligibility for Refund

Refunds are available under the following conditions:

• Request is made within 14 days of purchase
• You have not completed more than 25% of the training program
• You have not downloaded or accessed exclusive materials marked as non-refundable
• Service was purchased directly from CognitiveFlow Malaysia (not through third-party platforms)
• Your account is in good standing with no violations of our Terms of Service

4. Non-Refundable Items and Services

The following are not eligible for refund:

• One-on-one coaching sessions already conducted
• Customized assessment reports already delivered
• Downloaded digital materials and resources
• Services purchased more than 14 days ago
• Promotional or discounted services marked as final sale
• Gift certificates and vouchers
• Third-party services or products accessed through our platform

5. Refund Request Process

To request a refund, follow these steps:

• Step 1: Email refunds@cognitiveflow.my with your request
• Step 2: Include your full name, email address, order number, and reason for refund
• Step 3: Our team will review your request within 3 business days
• Step 4: You will receive a confirmation email with the decision
• Step 5: If approved, the refund will be processed within 7-10 business days

6. Refund Processing Time

Once approved, refunds are processed as follows:

• Credit/Debit Card: 7-10 business days for funds to appear in your account
• Online Banking: 5-7 business days
• E-Wallets: 3-5 business days

Processing times may vary depending on your financial institution.

7. Refund Method

Refunds will be issued to the original payment method used for the purchase. We do not offer cash refunds or transfers to different payment methods.

8. Partial Refunds

In certain circumstances, partial refunds may be granted:

• If you have accessed or completed a portion of the training program
• If some services have already been delivered
• In cases of technical issues affecting service delivery

The amount of the partial refund will be determined on a case-by-case basis and communicated to you before processing.

9. Subscription Cancellations

For subscription-based services:

• You may cancel your subscription at any time
• Cancellation takes effect at the end of the current billing cycle
• No refunds are provided for the current billing period unless within the 14-day guarantee window
• You will retain access to services until the end of the paid period

10. Technical Issues and Service Disruptions

If you experience technical difficulties preventing access to our services:

• Contact our support team at hello@cognitiveflow.my immediately
• We will work to resolve the issue within 48 hours
• If the issue cannot be resolved, you may be eligible for a pro-rated refund
• Extended service access may be provided as compensation in lieu of refund

11. Change of Mind

Under the Consumer Protection Act 1999 of Malaysia, you have the right to a refund within 14 days if you change your mind about a purchase, subject to the eligibility conditions outlined in Section 3.

12. Fraudulent or Abusive Refund Requests

We reserve the right to deny refund requests that we determine to be fraudulent or abusive. This includes but is not limited to:

• Multiple refund requests from the same customer
• Refund requests after significant service consumption
• Suspicious patterns of behavior suggesting abuse of the refund policy

Accounts found to be abusing the refund policy may be terminated.

13. Force Majeure

In the event of circumstances beyond our control (natural disasters, government actions, technical failures), we will make reasonable efforts to provide services or offer alternative compensation. Refunds in such cases will be assessed on an individual basis.

14. Currency and Exchange Rates

All transactions are in Malaysian Ringgit (MYR). If your bank or payment provider applies currency conversion, exchange rate differences are your responsibility and are not subject to refund.

15. Changes to Refund Policy

We reserve the right to modify this Refund Policy at any time. Changes will be effective immediately upon posting on our website. Your continued use of our services after changes constitutes acceptance of the modified policy.

16. Dispute Resolution

If you are not satisfied with our refund decision, you may:

• Request a review by our management team
• Seek assistance from the Tribunal for Consumer Claims Malaysia
• Pursue other remedies available under Malaysian consumer protection law

17. Contact Information

For refund-related inquiries, contact us:

• Refund Requests: refunds@cognitiveflow.my
• General Support: hello@cognitiveflow.my
• Address: Kuala Lumpur, Malaysia

Effective Date: 18 November 2025

Compliance: Personal Data Protection Act 2010 (PDPA), Malaysia

1. Introduction

This Cookie Policy explains how CognitiveFlow Malaysia ("we," "us," or "our") uses cookies and similar tracking technologies on our website. By using our website, you consent to the use of cookies as described in this policy.

2. What Are Cookies

Cookies are small text files stored on your device (computer, smartphone, tablet) when you visit a website. They help websites recognize your device and remember information about your visit, such as preferences and actions taken.

3. Types of Cookies We Use

Essential Cookies

These cookies are necessary for the website to function properly. They enable basic features such as page navigation, secure access, and form submissions. The website cannot function properly without these cookies.

• Session Cookies: Temporary cookies that expire when you close your browser
• Security Cookies: Used to authenticate users and prevent fraudulent activity
• Load Balancing Cookies: Help distribute traffic across servers

Performance and Analytics Cookies

These cookies collect information about how visitors use our website, such as which pages are visited most often and if error messages are received. This helps us improve website performance.

• Google Analytics
• Website performance monitoring tools
• User behavior tracking for optimization

Functional Cookies

These cookies allow the website to remember choices you make and provide enhanced, personalized features.

• Language preferences
• Display settings (font size, layout)
• Previously entered form information

Marketing and Targeting Cookies

These cookies track your browsing habits and are used to deliver advertisements more relevant to you and your interests. They may be set by us or third-party advertising networks.

• Social media integration cookies
• Retargeting and remarketing cookies
• Conversion tracking cookies

4. Third-Party Cookies

We use services from third-party providers who may set their own cookies. These include:

• Google Analytics: For website traffic analysis
• Social Media Platforms: Facebook, LinkedIn, Instagram integration
• Payment Processors: For secure transaction processing
• Advertising Networks: For targeted advertising campaigns

We do not control these third-party cookies. Please review the privacy policies of these services for more information.

5. Purpose of Using Cookies

We use cookies for the following purposes:

• Authentication: To verify your identity and maintain secure sessions
• Preferences: To remember your settings and choices
• Analytics: To understand how our website is used and identify improvements
• Marketing: To deliver relevant advertisements and measure campaign effectiveness
• Security: To detect and prevent fraudulent activity
• Performance: To optimize website loading speed and functionality

6. Cookie Duration

Cookies may be stored for different periods:

• Session Cookies: Deleted when you close your browser
• Persistent Cookies: Remain on your device for a set period (typically 30 days to 2 years) or until manually deleted

7. Your Consent

When you first visit our website, you will see a cookie consent banner. You can choose to:

• Accept All Cookies: Consent to all cookies including marketing cookies
• Decline: Reject non-essential cookies (essential cookies will still be used)

Your consent preferences are stored using a cookie that expires after 365 days.

8. Managing Cookies

You can manage or delete cookies through your browser settings. Here's how:

Google Chrome:

• Settings → Privacy and security → Cookies and other site data
• Choose to block third-party cookies or all cookies

Mozilla Firefox:

• Settings → Privacy & Security → Cookies and Site Data
• Manage permissions and clear data

Safari:

• Preferences → Privacy → Manage Website Data
• Remove or block cookies as desired

Microsoft Edge:

• Settings → Cookies and site permissions
• Manage and delete cookies

Note: Disabling cookies may affect website functionality and user experience.

9. Do Not Track Signals

Some browsers allow you to send "Do Not Track" signals. Our website does not currently respond to these signals, but we respect your right to control tracking through browser settings and our consent banner.

10. Mobile Device Tracking

If you access our website through a mobile device, you can manage tracking through your device settings:

• iOS: Settings → Privacy → Tracking
• Android: Settings → Google → Ads → Opt out of Ads Personalization

11. Impact of Disabling Cookies

If you disable or refuse cookies, please note that:

• Some features of the website may not function properly
• You may need to manually adjust preferences each visit
• Login and authentication features may not work
• We may not be able to provide personalized content

12. Children's Privacy

Our website is not intended for children under 18. We do not knowingly collect data from minors through cookies. If you believe a child has provided information, contact us immediately at privacy@cognitiveflow.my.

13. Data Protection and PDPA Compliance

We process cookie data in accordance with the Personal Data Protection Act 2010 (PDPA) of Malaysia. This includes:

• Obtaining explicit consent before using non-essential cookies
• Providing clear information about cookie usage
• Allowing users to withdraw consent at any time
• Implementing security measures to protect cookie data
• Limiting data retention to necessary periods

14. Changes to Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in technology, legislation, or our practices. The updated policy will be posted on this page with a revised effective date.

15. Contact Information

If you have questions about our use of cookies, contact us:

• Cookie Inquiries: cookies@cognitiveflow.my
• Privacy Concerns: privacy@cognitiveflow.my
• General Inquiries: hello@cognitiveflow.my
• Address: Kuala Lumpur, Malaysia

16. Additional Resources

For more information about cookies and online privacy:

• Personal Data Protection Department Malaysia: www.pdp.gov.my
• All About Cookies: www.allaboutcookies.org
• Your Online Choices: www.youronlinechoices.com