Privacy Policy.

1. Who we are

This Privacy Policy is issued by Paragon Holdings Sdn. Bhd. ("Paragon Holdings", "the Group", "we", "us", "our"), a private limited company incorporated in Malaysia with its registered office in Kuala Lumpur. Paragon Holdings is the data controller in respect of personal data collected through this website (paragonhcm.com).

This policy applies only to paragonhcm.com. Each portfolio company within the Group operates independently and maintains its own privacy practices on its own website.

2. Personal data we collect

We collect personal data only when you choose to provide it, or when it is automatically generated by your interaction with the website.

Information you provide

• Contact form submissions: name, company or organisation, email address, phone number (optional), division of interest, and the contents of your message or enquiry.
• Direct correspondence: any information you send us by email at info@paragonhcm.com.

Information collected automatically

• Technical data: IP address, device type, browser type and version, operating system, referring URL, and pages visited. This is logged by our hosting provider for security and service-quality purposes.
• Third-party fonts: Pages on this website use Google Fonts, which is served by Google and may log basic technical request data. We do not pass personal data to Google through this service.

3. Purposes for which we use personal data

We use personal data for the following purposes:

• To respond to investment, partnership, and media enquiries you send us.
• To direct operational enquiries to the appropriate Paragon Holdings portfolio company.
• To maintain records of correspondence in line with our internal record-keeping practices.
• To protect the security and integrity of our website and detect or prevent misuse.
• To comply with applicable legal, regulatory, and tax obligations in Malaysia and other jurisdictions in which we operate.

4. Legal basis for processing

Where the Personal Data Protection Act 2010 (Malaysia) applies, our legal basis for processing your personal data is your consent (provided when you submit a form or send us correspondence) and our legitimate interests in operating the Group, responding to enquiries, and protecting our website.

5. Disclosure of personal data

We do not sell or rent personal data. We may disclose personal data only in the following limited circumstances:

• Within the Group: if your enquiry concerns a specific portfolio company (Paragon Shipping & Logistics, Redlogik, Ayurtherm, IdeaBrew), we may forward your details to the relevant company so they can respond directly.
• Service providers: hosting, email, and IT service providers acting on our instructions and bound by confidentiality obligations.
• Legal and regulatory: where disclosure is required by Malaysian law, by court order, or by a competent regulator, or to protect our rights, property, and safety or those of others.
• Corporate transactions: in connection with a merger, acquisition, restructuring, or sale of assets, in which case the recipient will be bound by equivalent privacy obligations.

6. International transfers

The Group operates across Malaysia, Qatar, and the United Arab Emirates. Personal data you submit may therefore be accessed by Paragon Holdings personnel or service providers in any of these jurisdictions. Where such transfers occur, we take reasonable steps to ensure that the recipient applies a level of protection consistent with this policy and the requirements of the Malaysian Personal Data Protection Act 2010.

7. Data retention

We retain personal data only for as long as is necessary to fulfil the purposes set out in this policy, to comply with our legal and regulatory obligations, and to resolve disputes or enforce agreements. Enquiry records are typically retained for the duration of the business relationship and for a reasonable period thereafter, unless a longer retention period is required by law.

8. Your rights

Subject to applicable law, you have the right to:

• Request access to the personal data we hold about you.
• Request correction of inaccurate or incomplete personal data.
• Request that we limit our processing of your personal data, or withdraw your consent at any time (without affecting prior lawful processing).
• Object to direct marketing (although we do not currently send unsolicited marketing communications).
• Lodge a complaint with the Personal Data Protection Department of Malaysia (Jabatan Perlindungan Data Peribadi).

To exercise any of these rights, please contact us using the details below. We may need to verify your identity before responding.

9. Security

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. The website is served over HTTPS. However, no method of transmission over the Internet is fully secure, and we cannot guarantee absolute security.

10. Cookies and tracking

This website does not currently set tracking, advertising, or analytics cookies. Limited technical cookies may be set by third-party services (such as Google Fonts) that the website depends on. If we introduce analytics or marketing cookies in the future, we will update this policy and provide an appropriate consent mechanism.

11. Children

This website is not directed at children, and we do not knowingly collect personal data from individuals under the age of 18. If you believe a child has provided us with personal data, please contact us so we can delete it.

12. Third-party websites

This website links to portfolio company websites and other third-party websites. We are not responsible for the privacy practices or the content of those websites. Please review their privacy policies before submitting personal data.

13. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our portfolio, or applicable law. The "Last updated" date at the top of this page indicates when the policy was most recently revised. Where the changes are material, we will provide a more prominent notice.

14. How to contact us

For questions about this Privacy Policy or to exercise your rights, please contact:

Paragon Holdings Sdn. Bhd.
Kuala Lumpur, Malaysia
Email: info@paragonhcm.com