Dawnbreaker Digital privacy notice

Last updated: 3 November 2026

1. Who we are

DAWNBREAKER DIGITAL SDN. BHD. (Registration No. 202601036231 (1698326-A)) ("Dawnbreaker", "we", "us") is a Malaysian company. We build and run staff and payroll systems, business websites and custom business systems, for businesses in Malaysia. We are based in Malaysia, and we handle personal data under Malaysian law wherever you contact us from.

This notice explains how we collect and use personal data for our own business, as a data controller under the Personal Data Protection Act 2010 (PDPA).

2. Who this notice covers

This notice covers:

This notice does not cover employees' data inside a client's system. When a company uses our staff and payroll system, it controls its employees' data, and we process that data only on its instructions, as its data processor. If you work for one of our clients, your employer's personal data notice applies, and you should contact your employer. If you contact us instead, we will pass your request to your employer.

3. What personal data we collect

(a) Contact and identity details: your name, company, job title, phone or WhatsApp number, e-mail address and business address.

(b) Messages: the content of your WhatsApp messages and e-mails, and our notes of calls and meetings. This includes your WhatsApp profile name and photo, as WhatsApp shows them to us.

(c) Business information you share with us: for example, your number of staff, how you run payroll today, the tools you use and what you need.

(d) Referral information:

(e) Website data. Our website uses no analytics or advertising cookies. When you visit it:

(f) Contract and payment records: quotes, agreements, invoices and payments.

(g) Testimonials and case studies: your name, words, company name or logo, but only with your separate written consent.

4. Where we get it

We get personal data:

5. Why we use it

We use personal data to:

(a) reply to enquiries and give quotes;

(b) provide our systems, business websites and support;

(c) manage our agreements, invoices, payments and business records, including for tax and accounting;

(d) run our referral programme. This means tracking introductions, working out rewards and paying them to the introducing company, and telling each client introduced by a professional partner, in writing, that we pay that partner a fee;

(e) send you information about our services, where section 9 allows;

(f) keep our systems and records secure, prevent fraud and corruption, and meet our legal duties, such as tax reporting to the Inland Revenue Board (LHDN);

(g) handle complaints and legal claims; and

(h) publish a testimonial or case study, but only with your consent.

We also use it for any purpose directly related to these.

6. Do you have to give us your data?

No, it is voluntary. But without your contact details, we cannot reply to you. We also need certain details to enter into an agreement with you or to pay a referral reward.

7. Who we share it with

We share personal data with the following:

We do not sell personal data.

Our providers change from time to time. The version of this notice on our website is always the current list, and the date at the top shows when it last changed.

8. Transfers outside Malaysia

Some of the providers in section 7 process data outside Malaysia. The places are Singapore (our servers and our website) and the United States (our AI tools, our source-code hosting and our off-site encrypted backup copies). Our e-mail (Google) and our OneDrive storage (Microsoft) are held in those companies' data centres, which may be in the United States or in other countries. We transfer personal data outside Malaysia only as section 129 of the PDPA allows. For example:

Backup copies are encrypted before they leave our servers, and the storage providers cannot read them.

9. Marketing messages, and how to stop them

10. How long we keep it

Data Kept for
Enquiries that do not lead to business Up to 24 months after our last contact, then deleted
Agreements, invoices, and client and referral records For the relationship, and 7 years after it ends, to meet tax and accounting duties
Do-not-contact list For as long as we send marketing. We keep only what we need to honour your request
Testimonials and case studies Until you withdraw consent. Printed material already given out cannot be recalled
Copies of the above inside our encrypted backups Daily copies are deleted 61 days after they are made. Monthly copies are kept 13 months. Our off-site copies are locked for their first 30 days and cannot be deleted in that time, even by us

What that last row means for a deletion request. If you ask us to delete your personal data, we delete it from our live records straight away, and it then disappears from our backups as those backups expire on the cycle above. We cannot pull a single person's data out of an encrypted backup copy, and we cannot delete an off-site copy while it is locked. Those copies are encrypted, we do not read them, and we do not use them for anything except restoring a system after a failure.

11. How we protect it

We take practical steps to protect personal data from loss, misuse, and unauthorised access or disclosure. These steps include:

No system is perfectly secure. If a personal data breach affects data covered by this notice, we will notify the Personal Data Protection Commissioner, and you, where the PDPA requires. For data in a client's system, we tell the client, and the client decides.

12. Your rights

Under the PDPA, you may:

To make a request, contact us using the details in section 14. For data held in a client's system, we will pass your request to your employer.

13. Data protection contact

Questions about personal data at Dawnbreaker can be sent to our director, using the contact details in section 14.

14. Contact us

DAWNBREAKER DIGITAL SDN. BHD.
E-mail: dawnbreakerdigital@gmail.com

15. Children

Our services are for businesses. They are not aimed at anyone under 18.

16. Changes to this notice

We may update this notice. The date at the top shows the latest version. We will tell our clients about significant changes.

17. Language

This notice is published in Bahasa Malaysia and English. If the two versions differ, the English version prevails.