Privacy Policy

Issued by NEOONE EMPIRE SDN. BHD., trading as The One Percent Academy

NEOONE EMPIRE SDN. BHD., trading as The One Percent Academy ("Company," "we," "us," or "our"), respects your privacy and is committed to protecting the personal data of everyone who visits our website, subscribes to our masterclass or mailing list, or purchases or uses any of our Programs (together, the "Services"). This Privacy Policy explains what personal data we collect, why we collect it, how we use and share it, and the rights available to you.

This Policy is drafted primarily to comply with Malaysia's Personal Data Protection Act 2010, as amended by the Personal Data Protection (Amendment) Act 2024 (together, the "PDPA"), and, as a matter of good practice, also reflects the expectations of individuals in other jurisdictions we serve, including the EU/UK (under the GDPR and UK GDPR) and other applicable data protection laws. This Policy should be read together with our Terms of Service.

1. Who We Are

For the purposes of the PDPA and other applicable data protection laws, the data controller (data user) responsible for your personal data is NEOONE EMPIRE SDN. BHD., trading as The One Percent Academy. You can reach us regarding any privacy matter at info@neo-trading-consultants.com.

2. Scope of This Policy

This Policy applies to personal data we collect through our website, our checkout and community platforms, our email and messaging communications, our social media and advertising activity, and any other interaction you have with us in connection with the Services. It does not apply to the practices of third parties that we do not control, including Whop and Telegram, each of which maintains its own privacy policy governing its handling of your data. We encourage you to review those policies as well.

3. Personal Data We Collect

We collect the following categories of personal data:

• Identity and contact data — such as your name, email address, and phone number, collected when you sign up for our masterclass, complete an onboarding or intake form, or purchase a Program.
• Transaction data — such as which Program you purchased, the amount paid, and payment status, as provided to us by Whop. We do not collect or store your full payment card number, CVV, or bank account details; those are collected and processed directly by Whop and its payment partners.
• Onboarding and intake data — information you provide through our student intake process, such as your trading background, goals, and challenges, used to personalize your onboarding and, where offered, mentorship.
• Community and communications data — your Telegram username and activity within our community channels, and any correspondence between you and us, including support requests and, where applicable, notes or recordings from scheduled calls, which we will inform you of and, where required by law, obtain your consent to before recording.
• Marketing and engagement data — your email engagement history (such as opens and clicks) with our email communications, and your interactions with our social media accounts and direct-message automations.
• Technical and usage data — your IP address, browser and device type, pages visited, and similar data collected automatically through cookies and analytics tools when you visit our website, as described in Section 6.

We do not intentionally collect any sensitive personal data (such as data about health, religion, or race) and ask that you do not share such information with us unless it is strictly necessary and you have given us your explicit consent to do so.

4. How We Collect Personal Data

We collect personal data: (a) directly from you, when you sign up for the masterclass, complete an intake form, purchase a Program, message us, or otherwise interact with us; (b) automatically, through cookies and similar technologies when you use our website; and (c) from third parties, such as Whop (transaction confirmation) and social media and advertising platforms (such as Meta and Google), which may share limited data with us about how you interacted with our advertisements before reaching our website.

5. How and Why We Use Personal Data

We use personal data for the following purposes:

• To provide, operate, and deliver the Programs you purchase, including granting and managing your access to our learning materials and community channels.
• To process payments and manage billing, including installment/payment plans, through Whop.
• To communicate with you, including sending onboarding information, support responses, and Program-related updates.
• To send you marketing communications about our Programs and content, where you have opted in or where otherwise permitted by law, and always with the ability to opt out at any time.
• To personalize and improve our onboarding, mentorship, and content based on aggregated or individual feedback.
• To measure and improve the performance of our website and advertising, using analytics and advertising tools.
• To detect, investigate, and prevent fraud, abuse, or violations of our Terms of Service.
• To comply with our legal obligations, including tax, accounting, and regulatory recordkeeping requirements.

Under the PDPA, we process your personal data on the basis of your consent (for example, when you opt in to our masterclass or mailing list) and, where relevant, because processing is necessary to perform our contract with you (for example, to deliver a Program you purchased) or to comply with a legal obligation. For individuals in the EU/UK, we additionally rely, as applicable, on the legal bases of contractual necessity, legitimate interests (such as securing our Services and improving our offering), consent, and legal obligation.

6. Cookies and Similar Tracking Technologies

Our website uses cookies and similar technologies, including Google Analytics (GA4), Meta Pixel and Conversions API, and Microsoft Clarity, to understand how visitors use our website, to measure the performance of our marketing campaigns, and, in the case of Microsoft Clarity, to generate anonymized session recordings and heatmaps that help us improve the website experience. These tools may collect data such as your IP address, device and browser information, and pages visited, and may set cookies or similar identifiers on your device. You can control or disable cookies through your browser settings; please note that doing so may affect the functionality of our website. Where required by applicable law, we will request your consent before deploying non-essential cookies.

7. Third-Party Service Providers We Use

We share personal data with the following categories of third-party service providers, each of which processes personal data on our behalf, or as a separate controller under its own terms, solely to help us operate the Services:

• Whop — checkout, payment processing, and community/course access management.
• Telegram — community messaging and group access.
• Notion — internal onboarding, intake, and resource management.
• Brevo — email marketing and newsletter delivery.
• Resend — transactional email delivery (such as receipts and account notifications).
• Google Analytics (GA4) and Microsoft Clarity — website analytics.
• Meta (Facebook/Instagram) — advertising, Pixel/Conversions API tracking, and direct-message automation in response to your interactions with our content.
• Our video hosting provider — secure delivery of course video content.
• Cloudflare — website security services.

We require our service providers to protect your personal data and to use it only for the purposes for which we share it with them. We do not sell your personal data to any third party for their own independent marketing purposes.

8. International Data Transfers

Because we use service providers located outside Malaysia (including in the United States, the European Union, and Singapore, among others, depending on the provider's own infrastructure), your personal data may be transferred to, stored, and processed in countries other than your country of residence, which may have different data protection laws. Where we transfer personal data outside Malaysia, we take reasonable steps to ensure that the recipient provides a standard of protection comparable to the PDPA, including by relying on service providers who maintain their own recognized data protection safeguards (such as standard contractual clauses, where applicable, for transfers from the EU/UK).

9. Data Retention

We retain personal data for as long as necessary to provide the Services to you, to comply with our legal, tax, and accounting obligations (generally at least seven (7) years for financial records under Malaysian law), to resolve disputes, and to enforce our agreements. Where personal data is no longer needed for these purposes, we will securely delete or anonymize it.

10. Data Security

We implement reasonable technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, and destruction, consistent with the Security Principle under the PDPA. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Under the PDPA, you have the right to: (a) access the personal data we hold about you; (b) request correction of inaccurate or incomplete personal data; (c) withdraw your consent to our processing of your personal data (for example, by unsubscribing from marketing emails), noting that this may limit our ability to provide certain parts of the Services; (d) request that we limit the processing of your personal data in certain circumstances; and, following the 2024 PDPA amendments, (e) request data portability, where technically feasible.

If you are located in the EU/UK or another jurisdiction with equivalent data protection laws, you may also have the right to request erasure of your personal data and to object to certain processing, which we will honor to the extent required by the law applicable to you. To exercise any of these rights, contact us at info@neo-trading-consultants.com. We will respond within the timeframe required by applicable law.

12. Marketing Communications and Opt-Out

You may opt out of receiving marketing emails at any time by using the unsubscribe link included in each email, and you may opt out of automated direct-message follow-ups on social media by replying to stop such messages or contacting us directly. Opting out of marketing communications does not affect transactional or Program-related communications necessary to deliver a Program you have purchased.

13. Children's Privacy

The Services are not directed at, and are not intended for use by, anyone under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we have inadvertently collected personal data from someone under 18, we will take reasonable steps to delete it.

14. Data Breach Notification

In the event of a data breach involving your personal data that is likely to result in significant harm, we will notify the Personal Data Protection Commissioner of Malaysia and affected individuals in accordance with the notification requirements under the PDPA, and will take reasonable steps to investigate and remediate the breach.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our Services, or applicable law. We will post the updated Policy on our website and, where the changes are material, provide additional notice, such as by email. We recommend reviewing this Policy periodically to stay informed of how we handle your personal data.

16. How to Contact Us / Lodge a Complaint

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact us at:

NEOONE EMPIRE SDN. BHD.
trading as The One Percent Academy
Email: info@neo-trading-consultants.com

If you are not satisfied with our response, you may also lodge a complaint with the Department of Personal Data Protection Malaysia (www.pdp.gov.my), or, if you reside outside Malaysia, with your local data protection authority.