Privacy Policy
Last Updated: 20 January 2026 · lumarila · 89 Jalan Merdeka, 88000 Kota Kinabalu, Sabah, Malaysia
1. Introduction
lumarila ("we", "us", "our") is committed to handling your personal data with care and transparency. This Privacy Policy explains what information we collect, how we use it, and the rights you have in relation to it. Our operations are based in Kota Kinabalu, Sabah, Malaysia, and we comply with the Personal Data Protection Act 2010 (PDPA) of Malaysia.
If you have questions about this policy or how we handle your information, please contact us at [email protected].
2. Data We Collect
When you interact with lumarila — through our website, contact form, or directly with our advisors — we may collect the following personal information:
- Full name
- Email address
- Phone number (where provided)
- Details about your property requirements and housing circumstances
- Nationality or country of origin (where relevant to service delivery)
- Technical data including IP address, browser type, and website usage information (via cookies)
We collect data directly from you when you submit an enquiry, speak with one of our advisors, or use our website. We do not purchase data from third parties.
3. How We Use Your Data
Your personal data is used for the following purposes:
- To understand your property requirements and provide advisory services
- To communicate with you regarding your enquiry or active search
- To coordinate property viewings, tenancy documentation, and related arrangements
- To send service updates or follow-up communications where you have agreed to this
- To improve our website and understand how visitors use it (analytics)
- To comply with applicable legal obligations
We do not use your personal data for automated decision-making or profiling.
4. Legal Basis for Processing
We process your personal data on the following bases under the PDPA:
- Consent: Where you have submitted a contact form or agreed to receive communications.
- Contract: Where processing is necessary to fulfil the advisory services you have engaged us for.
- Legitimate interests: For internal business operations and service improvement, where these do not override your rights.
5. Data Retention
We retain personal data only for as long as is necessary for the purposes described in this policy. Specifically:
- Enquiry data from prospective clients: up to 12 months from last contact, unless an engagement is entered into
- Active client data: for the duration of the engagement and up to 3 years thereafter for legitimate business purposes
- Website analytics data: up to 26 months in aggregate form
6. Sharing Your Data
We do not sell, rent, or trade your personal information. We share data only in the following circumstances:
- With landlords or property managers, but only once you have given explicit consent to proceed with a specific property
- With trusted service providers who assist in operating our business (e.g., IT infrastructure), who are bound by confidentiality obligations
- Where required by law or a legitimate authority
7. Cookies
Our website uses cookies to improve your experience and analyse usage. Essential cookies are necessary for the website to function. Optional cookies for analytics and preferences can be managed through our cookie settings. Please refer to our Cookie Policy for full details.
8. Data Security
We take reasonable technical and organisational measures to protect your personal data from unauthorised access, disclosure, or loss. These include secure server hosting, access controls, and staff confidentiality obligations. In the event of a data breach that poses significant risk, we will notify affected individuals and relevant authorities as required by law.
9. Your Rights
Under Malaysian PDPA, you have the right to:
- Request access to the personal data we hold about you
- Request correction of inaccurate or incomplete data
- Withdraw consent for processing where consent was the basis for collection
- Request the cessation of processing that is causing or is likely to cause damage or distress
- Be informed of how your data is used
To exercise any of these rights, please contact us at [email protected]. We will respond within 21 days.
10. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and recommend reviewing their policies independently.
11. Children's Privacy
Our services are intended for individuals aged 18 and above. We do not knowingly collect personal data from minors. If we become aware that data has been submitted by a person under 18, it will be deleted promptly.
12. Changes to This Policy
We may update this Privacy Policy periodically. Significant changes will be communicated via our website. Continued use of our services after any update constitutes acceptance of the revised policy.
13. Contact
For any privacy-related enquiries, please contact us:
- Email: [email protected]
- Address: 89 Jalan Merdeka, 88000 Kota Kinabalu, Sabah, Malaysia