Last Updated: June 17, 2026

ApX Machine Learning, a service provided by APX MACHINE LEARNING TECHNOLOGIES (Registration No: 202603008008 (003810963-D)), a company incorporated in Malaysia ("we", "our", "us"), is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services ("the Site").

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site. By using the Site, you consent to the data practices described in this policy.

1. Information We Collect

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Information:

• Name, email address, and password when you create an account
• Profile information you choose to provide
• Communication preferences and marketing opt-ins

Payment Information:

• Billing address and payment method details (processed securely through third-party payment processors)
• Transaction history and purchase records
• We do not store full credit card numbers on our servers

Course and Learning Data:

• Course enrollment and progress information
• Quiz and assessment results
• Certificate completion records
• Time spent on courses and learning activity
• User-generated content (comments, reviews)

Technical Data:

• IP address, browser type and version, device information
• Time zone settings, operating system
• Access times, pages visited, and referring URLs
• Cookies and similar tracking technologies

AI Chatbot Data:

• Conversation messages and queries you submit to the AI assistant
• Chat session context retained during your active session

2. Children's Privacy

Our services are intended for users aged 13 and older. We do not knowingly collect personal information from children under 13 years of age. If you are under 13, please do not use the Site or provide any personal information.

If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information as soon as possible. If you believe we have collected information from a child under 13, please contact us immediately.

Users between 13 and 18 should use the Site with the permission and supervision of a parent or legal guardian.

3. Legal Basis for Processing

We process your personal data only where we have a lawful basis to do so. The basis we rely on for each type of processing is as follows:

• Account creation & service delivery: Performance of a contract (necessary to provide the services you have requested)
• Payment processing & transaction records: Performance of a contract and Legal obligation (required for financial compliance)
• Marketing communications: Consent (we will only send marketing emails where you have opted in)
• Analytics & service improvement: Legitimate interests (we have a legitimate interest in understanding how our services are used to improve them, balanced against your privacy rights)
• Fraud prevention & security: Legitimate interests and Legal obligation (we have a legitimate interest in protecting our platform and users)
• Compliance with legal obligations: Legal obligation (required by applicable laws including Malaysia PDPA 2010, GDPR, and other applicable regulations)
• AI chatbot interactions: Legitimate interests (processing is necessary to deliver the AI assistant feature you actively use)

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights. You may object to processing based on legitimate interests at any time by contacting us.

4. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to facilitate website functionality, analyze site traffic, and deliver personalized content. Cookies are small data files stored on your device.

Types of Cookies We Use:

• Essential Cookies: Required for the Site to function (authentication, security)
• Analytics Cookies: Help us understand how users interact with the Site
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Track your activity to deliver relevant advertisements

You will be asked for consent before we place non-essential cookies. You can manage your cookie preferences through our banner or your browser settings. Blocking cookies may affect your experience on the Site.

Do Not Track: We currently do not respond to "Do Not Track" signals from browsers.

Google Analytics and Google Signals

We use Google Analytics to analyze website traffic and user behavior. We have activated Google Signals, which allows Google Analytics to collect visitation information from our Site and associate it with Google information from accounts of signed-in users who have consented to this association for the purpose of ads personalization. This Google information may include end-user location, search history, YouTube history, and data from sites that partner with Google. This data is used to provide aggregated and anonymized insights into our users' cross-device behaviors.

You can access and delete this data at any time via Google's My Activity page. You can opt out of Google Analytics Advertising Features through Google Ads Settings, mobile ad settings, or by using the Google Analytics Opt-out Browser Add-on. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as Google advertising cookies) together to optimize and serve ads based on past visits to our Site.

5. Use of Your Information

We use the information collected to:

• Provide, operate, and maintain the Site and our courses
• Process your transactions and manage your orders
• Create and manage your account
• Track your course progress and issue certificates
• Send you transactional emails (order confirmations, password resets, account updates)
• Send marketing communications where you have opted in
• Respond to your comments, questions, and customer service requests
• Analyze usage patterns to improve our services and develop new features
• Detect, prevent, and address technical issues or fraud
• Comply with legal obligations and enforce our Terms and Conditions
• Personalize content delivery and user interface configuration based on user activity

6. Disclosure of Your Information

We may share your information with:

Service Providers: We work with third-party companies to provide services on our behalf:

• Hosting Providers: Cloud infrastructure and server hosting services
• Analytics Services: Tools to analyze website usage and user behavior
• Email Service Providers: Platforms for sending transactional and marketing emails
• Payment Processors: Secure payment processing services (they handle your payment data directly and securely)
• Customer Support Tools: Platforms to manage support tickets and customer communications
• AI/LLM API Providers: Chat messages you send to the AI assistant are transmitted to third-party large language model (LLM) API providers to generate responses. These providers may vary over time and are bound by data processing agreements. Messages are used solely to generate a response and are not used to train models beyond the provider's standard practices.

These service providers are contractually bound to protect your data and use it only for the purposes we specify.

Legal Requirements: We may disclose your information if required by law, court order, or government request, or to:

• Comply with legal obligations
• Protect and defend our rights or property
• Prevent fraud or illegal activity
• Protect the safety of users or the public

Business Transfers: If we are involved in a merger, acquisition, or sale of assets, your information may be transferred. You will be notified of any such change.

With Your Consent: We may share your information for any other purpose with your explicit consent.

7. Your Rights Under GDPR (European Users)

If you are located in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
• Right to Restriction: Request that we limit how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to our processing of your data, particularly for marketing
• Right to Withdraw Consent: Withdraw consent at any time where we rely on consent
• Right to Lodge a Complaint: File a complaint with your local data protection authority

To exercise any of these rights, please contact us. We will respond to your request within 30 days.

8. Your Rights Under CCPA/CPRA (California Users)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request information about the personal data we collect, use, and disclose
• Right to Delete: Request deletion of your personal data
• Right to Opt-Out: Opt-out of the sale of your personal data (we do not sell personal data)
• Right to Non-Discrimination: Exercise your privacy rights without discriminatory treatment
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit: Limit the use and disclosure of sensitive personal information

To exercise your rights, contact us. We will verify your identity before processing your request.

9. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using SSL/TLS
• Encryption of sensitive data at rest
• Regular security assessments and updates
• Access controls and authentication requirements
• Secure payment processing through PCI-DSS compliant providers
• Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

10. Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authorities within 72 hours of becoming aware of the breach, as required by law.

The notification will include the nature of the breach, the categories of data affected, the likely consequences, and the measures we have taken or propose to take to address the breach and mitigate its effects.

11. Retention of Your Information

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention Periods:

• Account Data: Retained while your account is active and for 30 days after account deletion
• Course Progress: Retained while your account is active or as long as you have access to courses
• Transaction Records: Retained for 7 years to comply with tax and accounting regulations
• Marketing Data: Retained until you withdraw consent or 2 years of inactivity
• Technical Logs: Retained for 90 days for security and troubleshooting purposes

After the retention period expires, we will securely delete or anonymize your data. You can request earlier deletion by contacting us, subject to legal obligations.

12. Account Deletion

You may request deletion of your account at any time by contacting us. Upon receiving your request, we will:

• Deactivate your account within 48 hours
• Delete your personal data within 30 days
• Retain transaction records for legal compliance (anonymized where possible)
• Remove your access to purchased courses

Please note that account deletion is permanent and cannot be undone. You will lose access to all purchased courses and certificates.

13. International Data Transfers

Your personal data may be transferred to and processed in countries outside of your country of residence, including countries that may not have the same level of data protection laws.

When we transfer data from the EEA to countries without adequate protection, we implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Ensuring our service providers are certified under recognized frameworks
• Obtaining your explicit consent where required

By using our Site, you acknowledge and consent to the transfer of your data as described in this policy.

14. Third-Party Links and Services

The Site may contain links to third-party websites or services that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

We strongly advise you to review the privacy policy of every site you visit. This Privacy Policy applies only to information collected through our Site.

15. Automated Decision-Making

We may use automated systems to analyze your learning patterns and recommend relevant courses or content. These automated decisions do not have legal or significant effects on you. You have the right to request human review of any automated decision that affects you.

16. Marketing Communications

Subject to your consent, we may transmit marketing communications regarding new courses, platform features, promotional offers, and related updates.

You can unsubscribe from marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Updating your preferences in your account settings
• Contacting us directly

Please note that you will continue to receive transactional emails (order confirmations, password resets, etc.) even if you opt out of marketing communications.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the new Privacy Policy on this page with an updated "Last Updated" date
• Sending you an email notification if the changes are significant
• Displaying a prominent notice on the Site

We encourage you to review this Privacy Policy periodically. Your continued use of the Site after any changes indicates your acceptance of the updated policy.

18. Contact Us and Data Protection

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: Through our contact form
• Data Protection Inquiries: For GDPR or data protection requests, please clearly mark your communication as "Privacy Request"

We will respond to your inquiry within 30 days. For data subject requests under GDPR or CCPA, we will verify your identity before processing your request.

19. Malaysia Personal Data Protection Act (PDPA)

APX Machine Learning Technologies is incorporated in Malaysia and processes personal data in accordance with the Personal Data Protection Act 2010 (PDPA). We comply with the seven data protection principles established under the PDPA: the General Principle, Notice and Choice Principle, Disclosure Principle, Security Principle, Retention Principle, Data Integrity Principle, and Access Principle.

If you are a data subject whose personal data we process, you have the following rights under the PDPA:

• Right of Access: Request access to your personal data held by us
• Right to Correction: Request correction of inaccurate, incomplete, misleading, or outdated personal data
• Right to Withdraw Consent: Withdraw your consent to the processing of your personal data at any time, subject to legal and contractual restrictions
• Right to Limit Processing: Request that we limit the processing of your personal data to storage only

To exercise any of these rights, please contact us through our contact form.