Privacy Policy
November 23, 2025 2025-11-24 16:17Privacy Policy
Last Updated: 17th November 2025
PORTDEMY (“we”, “our”, “us”) is committed to protecting the privacy and personal data of all learners, parents, educators, and users of our platform. This Privacy Policy explains how we collect, use, disclose, store, and safeguard personal information globally—across the European Union (EU), United Kingdom (UK), United States (US), Asia-Pacific countries, and the rest of the world.
By accessing or using PORTDEMY, you consent to the practices described in this Privacy Policy.
1. Data Controller
PORTDEMY
PORTMAN AI Sdn Bhd
E18, Mines 2 Retail Tower, PORTMAN College,
2nd Floor, Jalan Mines 2, Mines Wellness City,
43300 Seri Kembangan, Selangor
Email: data@portdemy.com
We act as the Data Controller for personal data processed through PORTDEMY.
2. Information We Collect
We collect necessary information to provide a personalized learning experience.
2.1 Personal Information
- Name
- Email address
- Phone number
- Student age/year level
- Parent/guardian information (for minors)
2.2 Learning Information
- Lessons viewed
- Quizzes attempted
- Learning progress
- AI Tutor interactions
- Activity time and completion logs
- Scores, badges, and learning patterns
2.3 Payment Information
- Credit/debit card details
- PayPal or digital payment details
- Billing address
Payment information is processed securely by PCI-compliant third-party providers (e.g., Stripe, PayPal, Senangpay). We do not store card details.
2.4 Technical Information
- Device type
- Browser
- IP address
- Cookies and usage analytics
- App or platform performance logs
2.5 Communication Data
- Support messages
- Chatbot or AI Tutor interactions
- Email or WhatsApp communications
- Feedback and surveys
3. Legal Basis for Processing (Global Compliance)
We process personal data on the following grounds:
GDPR (EU/UK) Legal Bases
- Consent
- Performance of a contract
- Legitimate interest
- Compliance with legal obligations
US Privacy Laws (CCPA/CPRA and others)
- Notice at collection
- No sale or sharing of personal information
- Consumer rights protections
Asia-Pacific (PDPA, DPA, PDP, DPDP Act)
- Explicit consent
- Purpose limitation
- Data minimisation
Lawful usage and retention
3. Legal Basis for Processing (Global Compliance)
We process personal data on the following grounds:
GDPR (EU/UK) Legal Bases
- Consent
- Performance of a contract
- Legitimate interest
- Compliance with legal obligations
US Privacy Laws (CCPA/CPRA and others)
- Notice at collection
- No sale or sharing of personal information
- Consumer rights protections
Asia-Pacific (PDPA, DPA, PDP, DPDP Act)
- Explicit consent
- Purpose limitation
- Data minimisation
Lawful usage and retention
4. How We Use Your Information
We use your data for:
- Providing access to PORTDEMY learning content
- Tracking student progress and generating reports
- Delivering personalised learning and AI Tutor feedback
- Improving course quality and user experience
- Processing payments and subscription management
- Communicating updates, support messages, and optional promotions
- Maintaining platform safety and preventing misuse
- Improving platform performance through analytics
We do not sell personal data.
5. Sharing of Information
We only share personal data when necessary:
5.1 Trusted Service Providers
- Payment processors (Stripe, PayPal, Senangpay etc.)
- Cloud hosting providers
- Learning analytics tools
- AI-powered educational tools
- Customer support systems
All vendors must meet global security and privacy standards.
5.2 Legal & Regulatory Requirements
We may disclose information if required by:
- Law
- Court order
- Government authority
6. International Data Transfers
PORTDEMY serves students globally. Your data may be processed in other countries.
For transfers outside your region, we ensure protection through:
- GDPR Standard Contractual Clauses (SCCs)
- Encryption and secure transfer protocols
- Compliance with PDPA/DPDP/PDP regulations
- Adequate data protection safeguards
7. Data Retention
We retain your personal information only as long as necessary:
- Active accounts: retained while membership is active
- Inactive or cancelled accounts: retained for up to 12–24 months
- Payment records: retained as required by financial regulations
- Anonymized learning data may be retained for research and improvement
Personal data that is no longer needed is securely deleted or anonymized.
8. Your Rights
8.1 GDPR (EU/UK) Rights
Users in the EU/UK have the right to:
- Access personal data
- Correct inaccurate data
- Delete personal data (“Right to be Forgotten”)
- Restrict processing
- Object to processing
- Data portability
- Withdraw consent
- Lodge a complaint with their Data Protection Authority
8.2 U.S. Privacy Rights (CCPA/CPRA & others)
Users in California and applicable states may:
- Request categories of data collected
- Request access to personal data
- Request deletion
- Request correction
- Opt out of sharing/selling of personal data
- Limit use of sensitive personal data
👉 PORTDEMY does not sell personal data.
8.3 Asian Region Rights (PDPA, DPA, PDP, DPDP Act)
Users in Asia may:
- Access their information
- Request correction
- Request deletion
- Withdraw consent
- Limit processing of personal data
To exercise any rights, contact our DPO at:
📧 data@portdemy.com
9. AI, Automation & Personalization
PORTDEMY uses AI technologies to provide:
- Personalised learning recommendations
- AI Tutor feedback and explanations
- Adaptive difficulty adjustments
- Intelligent quiz generation
- Behaviour-based learning insights
All AI-driven processes are supervised by human educators.
Users may request:
- Human review
- Disabling AI personalization (where feasible)
10. Children’s Privacy
PORTDEMY is designed for learners under parent or guardian supervision.
- Parents must create and manage student accounts
- We do not knowingly collect data from minors without parental consent
Parents may access, correct, or delete their child’s data at any time
11. Cookies & Tracking
We use cookies for:
- Keeping users logged in
- Personalising the learning experience
- Analytics and performance monitoring
- Optional marketing (consent-based in GDPR regions)
Users may disable cookies in their browser settings.
12. Data Security
We use strong security measures, including:
- SSL/TLS encryption
- Secure cloud hosting
- Role-based access control
- Encrypted backups
- Regular system monitoring
- Firewall & intrusion detection
- Child-safe data protection measures
13. Data Breach Notification
If a data breach occurs, we will:
- Notify affected users promptly
- Provide information on the nature of the breach
- Describe steps taken to mitigate risk
- Offer support for affected individuals
14. Third-Party Links
Our platform may contain links to external sites.
We are not responsible for their privacy practices.
We encourage you to review their privacy policies before sharing information.
15. Governing Law & Jurisdiction
This Privacy Policy is governed by the laws of Malaysia.
Any disputes will be handled by the appropriate courts in that jurisdiction.
16. Changes to This Policy
We may update this Privacy Policy from time to time.
Major updates will be announced, and the latest version will always be available on our website.
Continued use of PORTDEMY constitutes acceptance of updated policies.
17. Contact Us
If you have questions or requests regarding this Privacy Policy, please contact:
📧 Email: data@portdemy.com
🌐 Website: portdemy.com
