Legal
Privacy Policy
This Privacy Policy explains how Keith Wong — trading as Keith Wong and operating the Kira-Kira tools — collects, uses, discloses and protects personal data submitted through keithwong.my and its related pages (together, "the Site"). It applies whether you're using the insurance and financial planning content, the Kira-Kira loan and financing calculators, or contacting us via WhatsApp.
1. Who this covers
The Site has two related parts, and this policy covers both:
- Keith Wong's advisory practice (homepage and topic pages) — operating as a Financial Adviser's Representative and Islamic Financial Adviser's Representative licensed under Bank Negara Malaysia, and a Licensed Financial Planner under the Securities Commission Malaysia.
- Kira-Kira (loan, refinancing, SME and LPPSA calculators) — an independent information and referral tool. Kira-Kira is not a licensed moneylender or bank, and does not itself extend credit.
Data collected through the advisory side may be subject to additional conduct requirements under BNM and SC guidelines beyond general PDPA obligations; data collected through Kira-Kira is handled under PDPA alone, as a general commercial referral service.
2. What personal data we collect
- Contact details — name, phone number (via WhatsApp), and any details you volunteer in conversation.
- Financial information you enter into a calculator — income, existing debts, property value, business revenue, age, and similar figures used to generate your estimate. This is processed in your browser to produce the result shown to you; it is only transmitted to us if you click through to WhatsApp with the pre-filled summary, or otherwise choose to share it.
- Usage and analytics data — pages visited, approximate location (country/region level), device and browser type, collected via Google Analytics (GA4). See Section 6.
- Information you provide directly — if you proceed to an actual advisory or financing conversation, further personal and financial information may be collected as needed for that specific engagement (e.g. NRIC, income documents, existing policy details), always with your knowledge at the point of collection.
3. Why we collect it, and our legal basis
| Purpose | Basis |
|---|---|
| Generating your calculator estimate | Necessary to provide the tool you're using |
| Following up after you click "Continue on WhatsApp" | Your explicit consent, given via the consent checkbox before the button activates |
| Providing actual financial or insurance advice | Necessary to perform that engagement, and your consent |
| Site analytics and improvement | Legitimate interest, subject to your cookie choices where required |
| Complying with BNM/SC regulatory record-keeping | Legal obligation, where applicable to the advisory practice |
4. Who we share your data with
We do not sell personal data. We share it only in these circumstances:
- With the specific licensed bank, insurer, or institution you're referred to, and only after you've indicated you want to proceed — never speculatively.
- With service providers who help us operate the Site (e.g. hosting, analytics), under confidentiality obligations.
- Where required by law, regulation, or a valid request from Bank Negara Malaysia, the Securities Commission, or another authority with jurisdiction.
5. How long we keep it
Calculator inputs that never leave your browser are not retained by us at all. Data shared via WhatsApp or collected during an actual engagement is retained for as long as needed to provide the service, and thereafter as required by applicable BNM/SC record-keeping rules or general limitation periods under Malaysian law, typically 7 years, after which it is securely deleted.
6. Cookies and analytics
The Site uses Google Analytics (GA4) to understand how it's used — pages visited, and which tools and buttons are engaged with. This involves cookies and similar technologies. You can control or block these through your browser settings. Analytics data is used in aggregate and is not used to identify you personally.
7. Your rights
Under the PDPA, as strengthened by the 2024 amendments, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Withdraw consent for further processing
- Request data portability — transfer of your data to another provider, where technically feasible
- Lodge a complaint with the Personal Data Protection Commissioner if you believe we've mishandled your data
To exercise any of these rights, contact us at wkuankit@gmail.com.
8. Data Protection Officer
Under the 2024 PDPA amendments, data controllers meeting certain processing thresholds must appoint a Data Protection Officer. Currently, our processing activities do not meet the statutory thresholds for the mandatory appointment of a Data Protection Officer. However, we are committed to protecting your data.Data Protection Contact: wkuankit@gmail.com.
9. Data breach notification
In the event of a personal data breach likely to cause significant harm, we will notify the Personal Data Protection Commissioner and affected individuals in accordance with the timelines set under the PDPA (currently within 72 hours of becoming aware of the breach, for notification to the Commissioner).
10. Security
We take reasonable technical and organisational measures to protect personal data against loss, misuse, and unauthorised access. No online system is completely secure, and we cannot guarantee absolute security of data transmitted to us.
11. Children
This Site is not directed at, and is not intended for use by, anyone under 18. We do not knowingly collect personal data from minors.
12. Changes to this policy
We may update this policy from time to time. Material changes will be reflected by an updated date at the top of this page.
13. Contact
Questions about this policy, or requests relating to your personal data, can be sent to wkuankit@gmail.com or via WhatsApp.