SOUL INSIGHT PRIVACY POLICY

Effective date: 1 August 2026

1. Introduction

Soul Insight Sdn. Bhd. respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how Soul Insight Sdn. Bhd. collects, records, holds, stores, uses, discloses, transfers, secures, retains and otherwise processes personal data when you:

• visit our websites or landing pages;

• create a Soul Insight account;

• use our Thinkific learning platform;

• purchase or access a course, webinar, event, membership, coaching programme or other service;

• participate in the Soul Insight community;

• communicate with us;

• complete a quiz, survey, assessment, assignment or feedback form;

• attend or participate in a live or recorded webinar;

• subscribe to communications;

• otherwise interact with Soul Insight.

This Privacy Policy applies to the Parenting ADHD programme and any other service, programme, product or initiative operated under the Soul Insight name, unless a separate privacy notice is provided.

By submitting your personal data to us, creating an account or using our services, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy should be read together with our Terms of Use and any additional notice provided when particular personal data is collected.

2. About Soul Insight

For the purposes of applicable Malaysian personal-data protection law, the organisation responsible for your personal data is:

Soul Insight Sdn. Bhd.
Registration No. 202501013852 (1615266-A)

Registered and correspondence address:

1-23-5 Menara Bangkok Bank
Berjaya Central Park
Jalan Ampang
50450 Kuala Lumpur
Malaysia

Email: [email protected]

References in this Privacy Policy to “Soul Insight”, “we”, “us” and “our” mean Soul Insight Sdn. Bhd.

3. Scope and eligibility

Our Services are presently intended for persons located in Malaysia.

Accounts and purchases are restricted to persons aged 18 years and above.

Our services are designed primarily for adults, including parents, legal guardians, caregivers, educators and other adult participants. Children must not independently create an account, purchase a product, join a membership or submit personal data to us.

Where an adult provides information relating to a child or another person, that adult is responsible for ensuring that:

• the information is provided lawfully;

• the information is relevant and reasonably necessary for the relevant program, support, community or educational purpose;

• unnecessary identifying information is not disclosed;

• the adult has the appropriate authority or lawful basis to provide the information;

• the disclosure does not breach another person’s privacy, confidence or rights.

4. Personal data we may collect

Depending on how you interact with us, we may collect the following categories of personal data.

4.1 Identity and account information

This may include:

• full name;

• username;

• email address;

• password or authentication information;

• account identifier;

• profile photograph, where voluntarily added;

• age confirmation;

• account preferences;

• records of account creation, acceptance of policies and account activity.

Passwords are generally handled through the relevant platform provider and should not be visible to Soul Insight in readable form.

4.2 Contact information

This may include:

• email address;

• telephone number;

• billing address;

• state;

• country;

• other contact information you voluntarily provide.

4.3 Transaction and billing information

This may include:

• products or services purchased;

• purchase date;

• amount paid;

• currency;

• invoice or receipt details;

• billing status;

• payment-plan status;

• subscription status;

• failed-payment information;

• refund, cancellation or chargeback records;

• promotional or coupon use;

• relevant transaction identifiers.

Payments are processed through external payment-service providers such as Stripe. Soul Insight does not ordinarily receive or store your complete payment-card number, card verification code or full payment credentials.

4.4 Course and learning information

This may include:

• programme enrolments;

• lesson access;

• course progress;

• completion information;

• quiz answers;

• assignment submissions;

• worksheet submissions;

• assessment results;

• certificates;

• downloads;

• attendance;

• participation;

• learner preferences;

• questions submitted;

• feedback and survey responses.

4.5 Webinar and event information

This may include:

• registration information;

• attendance and joining information;

• display name;

• webinar chat messages;

• poll responses;

• questions submitted before or during an event;

• audio, image or video where your microphone or camera is enabled;

• recordings of the webinar;

• technical participation records;

• event feedback.

You are responsible for choosing whether to enable your camera or microphone. You may use a first name or appropriate display name where platform settings permit.

4.6 Community and user-generated content

This may include:

• community profile information;

• posts;

• comments;

• questions;

• replies;

• uploaded images or documents;

• reactions;

• moderation records;

• reports or complaints;

• records of community-rule violations;

• communications with moderators.

Community content may be visible to other authorised members according to the relevant community settings.

4.7 Communications and customer-support information

This may include:

• emails;

• one-to-one WhatsApp communications;

• support requests;

• complaint information;

• access or billing issues;

• feedback;

• records of our response;

• notes reasonably required to manage the issue.

4.8 Technical, device and usage information

This may include:

• internet protocol address;

• device type;

• browser type;

• operating system;

• language;

• login time;

• pages accessed;

• referral source;

• session and cookie identifiers;

• platform activity;

• approximate location derived from technical information;

• security and fraud-prevention data;

• diagnostic and error information.

4.9 Marketing and analytics information

This may include:

• marketing consent and withdrawal records;

• email open and click activity;

• campaign interactions;

• event-registration sources;

• advertisement interactions;

• audience or campaign attribution;

• website and platform analytics;

• communication preferences.

We may use tools such as Meta Pixel, Google Analytics and Google Tag Manager. Where required, applicable cookies or tracking technologies will be addressed through an appropriate cookie notice or consent mechanism.

4.10 Testimonials, research and programme-improvement information

This may include:

• testimonials;

• reviews;

• interview responses;

• survey responses;

• research responses;

• programme-evaluation feedback;

• photographs, audio or video submitted with separate consent.

Public testimonials will ordinarily be anonymous or de-identified unless you separately and expressly consent to another form of identification.

5. Sensitive personal data and information about children

Soul Insight does not require users to disclose a child’s diagnosis, school, medical records, full name, address, identity number or other identifying information merely to create a standard account.

Users should avoid providing unnecessary sensitive personal data or information that may identify a child or another individual unless specifically requested by Soul Insight for a particular Service.

• .

Where a future service requires health, diagnostic, coaching or other sensitive information, Soul Insight will provide an additional notice and obtain appropriate consent before collecting or using that information.

Soul Insight may remove or redact information that creates privacy, safeguarding, legal or professional concerns.

6. Information we do not ordinarily collect 

During the present service phase, Soul Insight does not intend to provide individual diagnosis, psychological assessment, therapy, prescription, medical treatment or other individual professional healthcare services through the standard platform.

We therefore do not ordinarily seek to collect detailed medical histories or clinical records through standard account registration.

Users must not use general course, community or webinar facilities as a substitute for a secure clinical intake or medical-record system.

7. Sources of personal data

We may collect personal data:

• directly from you;

• when you create or update an account;

• when you make a purchase;

• when you participate in a programme, event or community;

• when you communicate with us;

• automatically through our websites, platforms and analytics tools;

• from service providers acting on our behalf;

• from a spouse or caregiver purchasing an authorised couple product;

• from a partner organisation where you have lawfully registered through that organisation;

• from publicly available information where permitted by law;

• from consented referral, survey, testimonial or research processes.

For a couple plan, the primary purchaser may provide limited information required to create the second authorised account. The second participant may be asked to verify or complete their own account details.

8. Purposes for which we process personal data

We may process personal data for the following purposes.

8.1 Account and service administration

To:

• create, authenticate and manage accounts;

• enrol users;

• provide access to purchased or authorised content;

• administer individual and couple accounts;

• maintain course progress;

• issue certificates;

• administer webinars, replays and communities;

• provide membership benefits;

• manage access periods and expiries.

8.2 Transactions and billing

To:

• process payments;

• issue invoices and receipts;

• administer subscriptions and payment plans;

• manage failed payments;

• prevent fraud;

• address chargebacks;

• manage refunds where applicable;

• maintain accounting and tax records.

8.3 Service delivery

To:

• provide courses, resources, webinars, events, communities and programmes;

• administer quizzes, assignments and learning activities;

• provide downloadable materials;

• manage customer support;

• deliver operational and transactional communications.

8.4 Communications

To:

• send account notifications;

• send receipts;

• send access instructions;

• provide password-reset communications;

• send webinar reminders;

• notify users of rescheduling or service changes;

• respond to enquiries;

• manage complaints;

• notify users of material policy or security changes.

Transactional and service-related communications may be sent even where the user has not consented to marketing.

8.5 Marketing

Where appropriate consent has been obtained, to:

• send educational updates;

• send newsletters;

• promote Soul Insight products, events and programmes;

• provide relevant offers;

• invite users to participate in surveys, reviews or testimonials;

• measure campaign effectiveness.

Marketing consent is separate from acceptance of the Privacy Policy and Terms of Use. You may unsubscribe from marketing emails using the unsubscribe facility provided or by contacting us.

8.6 Analytics and programme improvement

To:

• understand how users access and use our services;

• analyse enrolment, completion and participation;

• improve content and user experience;

• plan new programmes;

• identify technical issues;

• evaluate commercial and educational performance;

• prepare aggregated or anonymised reports;

• conduct internal quality assurance.

8.7 Safety, moderation and legal compliance

To:

• enforce our Terms of Use and community rules;

• investigate misuse;

• protect users and children;

• detect security threats;

• investigate fraud;

• maintain evidence of consent and transactions;

• comply with law;

• respond to lawful requests;

• establish, exercise or defend legal rights.

8.8 Research and publication

Where appropriate consent and safeguards exist, we may use information for surveys, programme evaluation or research.

Formal research involving identifiable or sensitive participant information will be subject to a separate process, including additional consent and any ethics or governance review considered necessary.

We may publish aggregated or properly anonymised findings that do not reasonably identify an individual.

9. Basis for processing

Depending on the circumstances, we process personal data because:

• it is necessary to create or perform a contract with you;

• it is necessary to provide a requested service;

• you have consented;

• it is necessary to comply with a legal obligation;

• it is necessary for legitimate operational, security, analytical or business purposes;

• it is necessary to establish, exercise or defend legal rights;

• other basis available under applicable law.

Where consent is relied upon, you may withdraw consent subject to legal and contractual limitations. Withdrawal does not invalidate processing carried out before the withdrawal.

Where particular information is required to create an account, process a payment or provide a service, issue a certificate, or respond effectively to request, failure to provide it may prevent us from providing the relevant service.

10. Marketing communications

Soul Insight will not treat acceptance of this Privacy Policy or our Terms of Use as automatic consent to receive promotional emails.

Where marketing consent is requested, it will be obtained separately.

You may withdraw from marketing emails at any time by:

• using the unsubscribe link;

• adjusting available account preferences; or

• emailing [email protected].

Withdrawal from marketing does not prevent necessary transactional, account, security, billing or service communications.

We do not sell personal data to advertisers.

We do not provide personal data to unrelated third parties for their own independent marketing without appropriate consent.

11. Cookies, analytics and similar technologies

Our websites and service platforms may use cookies, tags, pixels, software development kits and similar technologies.

These technologies may be used to:

• keep users signed in;

• remember settings;

• support security;

• enable platform functions;

• understand website usage;

• measure campaign performance;

• identify referral sources;

• improve user experience;

• support advertising and retargeting where permitted.

Some technologies are provided by external providers, including Thinkific, Google and Meta.

Where applicable, you may manage cookies through:

• a cookie banner or settings tool;

• your browser;

• relevant provider settings;

• device privacy settings.

Blocking certain essential technologies may affect site or platform functionality.

12. Disclosure of personal data

We may disclose personal data to the following categories of recipient, where reasonably necessary.

12.1 Platform and technology providers

Including but not limited to providers supporting:

• course hosting;

• account management;

• video conferencing;

• cloud storage;

• email;

• analytics;

• website operation;

• security;

• technical support.

Current or anticipated providers may include Thinkific, Zoom, Google and related service providers.

12.2 Payment and finance providers

Including:

• Stripe;

• banks;

• payment gateways;

• accounting and finance providers;

• SQL accounting systems;

• fraud-prevention providers;

• professional financial advisers.

12.3 Soul Insight personnel and authorised service providers

Including authorised:

• directors;

• employees;

• administrators;

• clinical experts;

• moderators;

• facilitators;

• contractors;

• consultants;

• technology providers;

• legal and professional advisers.

Access should be limited according to role and reasonable operational need.

12.4 Business and organisational partners

Where a programme is lawfully delivered with a school, employer, association, sponsor or other organisation, limited information may be shared as necessary to administer the programme.

We will not disclose private learning information to such an organisation for unrelated purposes without an appropriate basis.

12.5 Government, regulatory and legal recipients

We may disclose information where:

• required by law;

• required by a court or competent authority;

• necessary to investigate suspected unlawful conduct;

• necessary to protect a person’s safety;

• necessary to establish, exercise or defend legal rights.

12.6 Corporate transactions

If Soul Insight undergoes a restructuring, merger, investment, acquisition, transfer or sale of relevant business assets, personal data may be disclosed under appropriate confidentiality and legal safeguards.

13. Service providers and data processors

Certain service providers process personal data on Soul Insight’s behalf.

Soul Insight engages service providers that provide appropriate contractual, privacy and security commitments. However, each provider operates its own infrastructure and may also process information in accordance with its own applicable terms and privacy notices.

Thinkific uses subprocessors to support its services. The list and location of those subprocessors may change over time.

Users should also review the privacy information made available by relevant service providers, particularly where they interact directly with the provider’s platform.

14. Cross-border transfers

Some technology, cloud, payment, analytics, email and platform providers may store or process personal data outside Malaysia.

This may include processing in countries where:

• the relevant platform operates;

• its affiliates are located;

• its cloud or subprocessor infrastructure is located;

• technical support is provided.

Where personal data is transferred outside Malaysia, Soul Insight will take reasonable steps to ensure that the transfer is carried out in accordance with applicable Malaysian law and that appropriate safeguards, contractual protections, risk assessments or other lawful transfer mechanisms are used where required.

By using international technology platforms, your information may be processed in another jurisdiction subject to the safeguards described above.

15. Webinar recordings

Webinar recordings may capture a participant's voluntary participation, including the participant's display name, voice, image, chat messages, poll responses and questions. Participants who do not wish to be identifiable should disable their camera and microphone, use an appropriate display name and avoid sharing identifying information

16. Community privacy

Soul Insight membership communities are shared spaces.

Although access may be restricted to authorised members:

• other members may see posts and profile information;

• other members may remember, copy or improperly disclose information;

• absolute confidentiality cannot be guaranteed;

• community participation does not create a doctor-patient, therapist-client, lawyer-client or other confidential professional relationship.

Users must not:

• disclose unnecessary identifying information about a child;

• publish another person’s confidential information;

• copy or share another member’s posts outside the community;

• record community sessions without permission;

• assume that a community post is private medical communication.

Soul Insight may moderate, remove, preserve or disclose community content where reasonably necessary for safety, enforcement, evidence or legal compliance.

17. Artificial intelligence and automated tools

Soul Insight may use carefully controlled digital tools to assist with administrative, analytical, drafting, organisational or operational tasks.

Soul Insight’s operating rule is that identifiable or sensitive customer information should not be entered into general-purpose artificial-intelligence tools unless:

• the use has been authorised;

• the information is necessary;

• the information is appropriately minimised, de-identified or protected;

• suitable contractual and security controls are in place;

• the use is consistent with this Privacy Policy and applicable law.

Soul Insight does not presently intend to use automated systems to make decisions that produce significant legal or similarly serious effects on users without appropriate human involvement.

18. Data security

Soul Insight will take reasonable and appropriate administrative, organisational, contractual and technical measures to protect personal data against:

• loss;

• misuse;

• unauthorised access;

• unauthorised disclosure;

• alteration;

• destruction;

• accidental exposure.

Measures may include:

• role-based access;

• access restrictions;

• password controls;

• multi-factor authentication where available;

• platform security settings;

• secure cloud services;

• personnel confidentiality obligations;

• backups;

• security monitoring;

• vendor review;

• incident-response procedures;

• data minimisation;

• staff guidance.

No online system is completely secure. Soul Insight cannot guarantee that a security incident will never occur.

Users are responsible for protecting their login credentials and must notify us promptly if they suspect unauthorised account access.

19. Data breaches

Soul Insight maintains or will maintain an incident-response process.

Where a personal-data breach occurs, Soul Insight will:

• assess the nature and likely impact of the incident;

• take reasonable containment and remediation steps;

• preserve appropriate records;

• notify relevant service providers;

• notify the Malaysian Personal Data Protection Commissioner where required;

• notify affected individuals where required;

• cooperate with lawful investigations.

20. Data retention

Soul Insight retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including contractual, operational, accounting, tax, security, dispute and legal purposes.

Our anticipated retention approach is:

20.1 Account and service records

Retained while the account or service remains active and for a reasonable period afterwards to manage records, disputes, renewals and legal obligations.

20.2 Transaction, invoice, accounting and tax records

Retained for at least seven years, or for another period required by applicable law.

20.3 Contract and consent records

Retained for the duration of the relationship and afterwards for the period reasonably necessary to establish acceptance, manage disputes and defend legal rights.

20.4 Course progress and certificate records

Retained for the course-access period and afterwards for a reasonable period to verify completion, provide support and administer certificate records.

20.5 Webinar and attendance records

Retained for a reasonable administrative and reporting period. Webinar recordings may be retained for the duration required to provide replay access and afterwards for archival, legal, production or Soul Insight approved educational use.

20.6 Support and complaint records

Retained for a reasonable period based on the nature and sensitivity of the matter, including for complaint management and legal protection.

20.7 Community content

Retained while relevant to the community. Removed content may be preserved where necessary for enforcement, safeguarding, evidence or legal compliance.

20.8 Marketing records

Retained while consent or a lawful marketing relationship continues and afterwards as necessary to maintain suppression or unsubscribe records.

20.9 Sensitive information

Sensitive or child-related information that is no longer required should be deleted, anonymised or restricted earlier where reasonably practicable.

Specific retention periods may be influenced by Thinkific, Stripe, Zoom, Google or other service-provider settings. Soul Insight will not retain information indefinitely merely because a platform permits it.

21. Anonymisation and aggregation

Soul Insight may anonymise or aggregate information so that it no longer reasonably identifies an individual.

Anonymised or aggregated information may be used for:

• reporting;

• research;

• programme development;

• commercial planning;

• educational analysis;

• publications;

• service improvement.

Once information has been properly anonymised, it may no longer constitute personal data.

22. Your rights and choices

Subject to applicable law, you may request to:

• access personal data held about you;

• correct inaccurate, incomplete or outdated information;

• withdraw consent where processing is based on consent;

• stop receiving marketing;

• ask questions about processing;

• request deletion where appropriate;

• request restriction or other available action;

• make a complaint.

Certain requests may be limited where:

• information must be retained by law;

• information is required to perform or enforce a contract;

• retention is necessary for accounting, fraud-prevention, safeguarding or legal claims;

• deletion would affect another person’s rights;

• the request is otherwise subject to a lawful exception.

Soul Insight may need to verify your identity before processing a request.

To exercise a privacy right, email:

[email protected]

Soul Insight will respond within the period required by applicable law or, where no fixed period applies, within a reasonable period.

23. Account deletion

You may request account deletion by contacting us.

Deleting an account may result in loss of access to:

• courses;

• progress;

• assignments;

• certificates;

• community posts;

• memberships;

• webinar replays;

• other account-linked services.

Account deletion does not necessarily require Soul Insight to delete:

• transaction records;

• tax or accounting records;

• records of consent;

• fraud or chargeback records;

• complaint records;

• information required for legal claims;

• information necessary to protect another person;

• information that has been properly anonymised.

24. Data Subjects Obligation and Accuracy of information

It is necessary for Soul Insight to collect and retain clients’ personal data. Therefore it is obligatory for clients to provide accurate and current information. Where personal data required to provide the Services is not provided, Soul Insight may be unable to create an account, process a transaction or provide the relevant Services .

You should update your information through available account settings or by contacting us.

Soul Insight may request verification where information affects:

• account ownership;

• billing;

• couple enrolment;

• certificate issuance;

• privacy requests;

• fraud prevention.

25. Third-party links and services

Our services may contain links to third-party websites, videos, applications or services.

Soul Insight is not responsible for a third party’s independent privacy practices. You should review the relevant third party’s privacy information before submitting personal data.

26. Changes to this Privacy Policy

Soul Insight reserves the right to amend this Privacy Policy from time to time by publishing the updated Privacy Policy on our website to reflect including but not limited to:

• legal changes;

• regulatory guidance;

• service changes;

• new products;

• technology changes;

• security practices;

• business operations.

We advise that you check our website for this Privacy Policy on a regular basis. Kindly view our privacy policy on the website www.soulinsight.my. 

27. Data-protection governance

Soul Insight has not presently designated a formal Data Protection Officer.

Data Privacy matters are currently administered by authorised Soul Insight representatives, under Soul Insight’s management authority.

Soul Insight will assess whether formal appointment or registration requirements apply as the business, volume and nature of processing develop.

28. Inquiries and Complaints

Should you require further information about the personal data we hold or the way in which your information is being collected or used which are not answered by this Privacy Policy please contact or write to us at: 

Email: [email protected]

Address:

Soul Insight Sdn. Bhd.
1-23-5 Menara Bangkok Bank
Berjaya Central Park
Jalan Ampang
50450 Kuala Lumpur
Malaysia