PRIVACY POLICY

Last Updated: 20 May 2026

This Privacy Policy describes how TrainLeo (“TrainLeo”, “we”, “our”, or “us”), operated by SNA SMART ENTERPRISE, collects, uses, stores, and protects information when you use our platform and services.

By accessing or using TrainLeo, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

TrainLeo may collect and process the following categories of information:

Account Information

• Name
• Email address
• Organization name
• User role and permissions

Operational & Training Records

• Staff information
• Attendance records
• Training history
• Competency and quiz results
• Compliance records
• Uploaded documents and evidence photos
• Digital signatures

Technical Information

• Device information
• Browser type
• IP address
• Access timestamps
• Session activity logs

Billing Information

Payment transactions may be processed through third-party payment providers such as SenangPay.

TrainLeo does not store full payment card information on its servers.

2. How We Use Information

We use collected information to:

• Provide and operate the TrainLeo platform
• Manage subscriptions and billing
• Generate reports and compliance records
• Facilitate training and competency workflows
• Improve platform functionality and performance
• Provide customer support
• Send operational notifications and reminders
• Maintain platform security and prevent abuse

We may also use aggregated or anonymized usage information for analytics, operational improvement, or service monitoring purposes.

3. Employee & Personal Data Responsibility

Organizations using TrainLeo are responsible for ensuring they have the legal right, authority, and consent to upload and process employee or personal information within the platform.

Organizations are solely responsible for compliance with applicable:

• Employment laws
• Privacy laws
• Data protection regulations
• Internal company policies

including Malaysia’s Personal Data Protection Act 2010 (PDPA), where applicable.

4. Data Storage & Retention

Information may be stored on cloud infrastructure and third-party service providers used by TrainLeo.

TrainLeo may retain operational records, logs, reports, and uploaded files for as long as reasonably necessary to:

• Provide services
• Maintain operational integrity
• Support audits and reporting
• Comply with legal obligations
• Enforce platform policies

Upon subscription expiry, suspension, or termination, data may be deleted in accordance with our Terms & Conditions and internal retention policies.

Deleted data may not be recoverable.

Organizations are encouraged to regularly export and maintain backup copies of important operational records.

5. Data Sharing & Disclosure

TrainLeo does not sell customer personal information.

We may disclose information:

• To service providers necessary for platform operations
• To payment processors and infrastructure providers
• To comply with legal obligations or regulatory requests
• To protect the rights, safety, security, or integrity of TrainLeo, customers, or the public
• In connection with a merger, acquisition, restructuring, or sale of business assets

Third-party providers may include:

• Cloud hosting providers
• Authentication providers
• Email delivery providers
• Payment gateways
• File storage providers

6. Security Measures

TrainLeo takes reasonable technical and organizational measures to protect stored information against:

• Unauthorized access
• Loss
• Misuse
• Disclosure
• Alteration
• Destruction

However, no internet-based system or electronic storage method can be guaranteed to be completely secure.

Users are responsible for:

• Maintaining credential confidentiality
• Securing their devices
• Restricting unauthorized access to their accounts

7. Cookies & Analytics

TrainLeo may use cookies, session tokens, and similar technologies to:

• Maintain user sessions
• Improve platform functionality
• Analyze platform usage
• Enhance user experience

Users may adjust browser settings to disable cookies, although some platform features may not function properly as a result.

8. Third-Party Services & Links

TrainLeo may contain links or integrations with third-party services or websites.

We are not responsible for the privacy practices, content, or security of third-party platforms or providers.

Users are encouraged to review the privacy policies of any third-party services they access.

9. International Data Processing

Depending on infrastructure providers used by TrainLeo, information may be processed or stored outside Malaysia.

By using the platform, users acknowledge and consent to such processing where necessary for platform operations.

10. Limitation of Responsibility

While TrainLeo takes reasonable measures to safeguard information, we do not guarantee:

• uninterrupted availability,
• absolute security,
• prevention of all unauthorized access,
• or permanent preservation of all stored records.

TrainLeo shall not be liable for losses resulting from:

• third-party infrastructure failures,
• cyberattacks,
• internet disruptions,
• unauthorized access caused by user negligence,
• or circumstances beyond reasonable control.

11. Changes to this Privacy Policy

TrainLeo reserves the right to update or modify this Privacy Policy at any time.

Updated versions will be published on the platform. Continued use of the platform after updates constitutes acceptance of the revised Privacy Policy.

12. Contact Information

SNA SMART ENTERPRISE

Email: [email protected]

For questions, requests, or concerns regarding this Privacy Policy or personal data handling, please contact us through the email above.