PRIVACY POLICY & PERSONAL DATA PROTECTION NOTICE

Last Updated: 28 August 2026

ADA Shared Services Sdn Bhd. (200801004348 / 805632-X) (“ADA”, “ADA2U”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy and Personal Data Protection Notice (“Privacy Policy”) explains how we collect, use, disclose, store and protect your personal data when you:

• Visit our website at ada2u.com;
• Create an ADA2U account;
• Make an online booking or purchase;
• Subscribe to a co-working or office plan;
• Use our workspaces, facilities or services;
• Contact our customer service team;
• Participate in our promotions or events; or
• Otherwise interact with ADA2U.

This Privacy Policy should be read together with our Terms and Conditions and any other notices provided when we collect your personal data.

By providing your personal data to us or using our services, you acknowledge that you have read and understood this Privacy Policy.

1. ABOUT ADA2U

ADA2U is operated by:

ADA Shared Services Sdn Bhd.
Company Registration No.: 200801004348 / 805632-X

Website: ada2u.com
Email: wecare@ada2u.com
Telephone: +604 619 2500
Business Address: Penthouse 1-21-1, Suntech @ Penang Cybercity, Lintang Mayang Pasir 3, Bayan Baru, 11950 Penang, Malaysia

For the purposes of applicable Malaysian personal data protection laws, ADA Shared Services Sdn Bhd. acts as the data controller in respect of personal data that we collect and process in connection with our business activities.

2. PERSONAL DATA WE MAY COLLECT

Depending on how you interact with ADA2U, we may collect the following categories of personal data.

2.1 Personal Identification Information

This may include:

• Full name;
• Nationality;
• Date of birth;
• Gender, where relevant;
• NRIC or identification number, where required;
• Passport details, where required;
• Photograph or profile image; and
• Other identification information necessary to verify your identity.

We will only request identity documents where reasonably required for the relevant service, security requirement or legal obligation.

2.2 Contact Information

This may include:

• Email address;
• Telephone or mobile number;
• Residential or business address;
• Billing address; and
• Mailing address.

2.3 Company and Business Information

Where you register or purchase services on behalf of a business, we may collect:

• Company name;
• Company registration number;
• Business address;
• Nature of business;
• Job title;
• Employee or authorised representative details;
• Company email address;
• Company telephone number;
• SSM documents; and
• Other documents required for virtual office or business address services.

2.4 Booking and Membership Information

We may collect information relating to:

• Co-working space bookings;
• Hot desk bookings;
• Dedicated desk subscriptions;
• Private office bookings;
• Serviced office plans;
• Meeting room bookings;
• Event space bookings;
• Virtual office subscriptions;
• Business mailing address services;
• Check-in and check-out records;
• Membership history;
• Workspace preferences;
• Access cards or access credentials; and
• Other services purchased from ADA2U.

2.5 Payment and Transaction Information

When you purchase our services, we may collect:

• Billing information;
• Payment status;
• Transaction reference number;
• Invoice details;
• Purchase history;
• Refund information; and
• Payment method information.

Payments may be processed by third-party payment gateway providers.

Where payments are processed by a third-party provider, full debit card or credit card information may be collected and processed directly by that payment provider rather than stored by ADA2U.

2.6 Website and Technical Information

When you use our website, certain information may be collected automatically, including:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Pages visited;
• Date and time of access;
• Referring website;
• Website interactions;
• Cookie identifiers;
• Approximate location based on IP address; and
• Other technical and analytical information.

2.7 Communications

We may retain records of communications between you and ADA2U, including:

• Emails;
• Online contact forms;
• Customer support enquiries;
• Feedback;
• Complaints;
• WhatsApp or messaging communications, where applicable; and
• Other correspondence.

2.8 CCTV and Building Security Information

Where CCTV is installed at our premises, images and video recordings may be collected for security, safety, access control, incident investigation and property protection purposes.

CCTV is generally used in common and public areas and will not be used in areas where individuals would reasonably expect complete privacy.

2.9 Visitor Information

If you visit an ADA2U location, we may collect:

• Visitor name;
• Contact details;
• Company name;
• Person being visited;
• Visit date and time;
• Vehicle registration number, where applicable; and
• Security or visitor access records.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal data:

Directly from You

For example when you:

• Create an account;
• Complete an online form;
• Make a booking;
• Purchase a membership;
• Make a payment;
• Register as a visitor;
• Contact us;
• Subscribe to marketing communications;
• Participate in an event;
• Request a quotation; or
• Provide documents for a virtual office or business address service.

Automatically

Certain technical information may be collected automatically when you visit our website through cookies and similar technologies.

From Third Parties

We may receive personal data from:

• Your employer or company;
• An authorised representative;
• Payment gateway providers;
• Building management;
• Business partners;
• Referral partners;
• Event organisers;
• Publicly available sources; or
• Government or regulatory authorities where permitted by law.

Where you provide personal data relating to another person, you confirm that you are authorised to provide such information to us and, where required, have informed that person about this Privacy Policy.

4. PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA

We may collect and process your personal data for the following purposes.

Providing Our Services

To:

• Create and manage your ADA2U account;
• Process workspace reservations;
• Process meeting room bookings;
• Manage memberships;
• Provide private office or serviced office services;
• Provide virtual office services;
• Provide business mailing address services;
• Manage visitor access;
• Provide internet and workspace facilities;
• Manage access cards and building access; and
• Deliver other services requested by you.

Payments and Billing

To:

• Process payments;
• Confirm transactions;
• Issue invoices and receipts;
• Manage deposits;
• Process refunds;
• Collect outstanding amounts; and
• Maintain financial records.

Customer Support

To:

• Respond to enquiries;
• Provide customer service;
• Handle complaints;
• Resolve booking issues;
• Manage service requests; and
• Communicate important information about your account or bookings.

Business Administration

To:

• Maintain customer records;
• Administer our business;
• Manage contracts and memberships;
• Conduct accounting and auditing;
• Generate internal reports;
• Improve operational efficiency; and
• Maintain records required by law.

Security and Fraud Prevention

To:

• Protect our premises;
• Verify identity;
• Manage building access;
• Prevent unauthorised access;
• Detect fraud;
• Investigate suspicious activities;
• Protect customers, staff and visitors; and
• Protect ADA2U’s property and systems.

Website Improvement and Analytics

To:

• Understand how our website is used;
• Improve website functionality;
• Analyse visitor behaviour;
• Troubleshoot technical issues;
• Monitor website performance; and
• Develop new products or services.

Marketing and Promotions

Where permitted by law, we may use your contact information to:

• Inform you of ADA2U promotions;
• Introduce new workspace plans;
• Send newsletters;
• Send special offers;
• Promote events;
• Provide membership updates; and
• Share information about services that may be relevant to you.

You may opt out of direct marketing communications at any time.

Legal and Regulatory Compliance

To:

• Comply with applicable laws;
• Respond to lawful requests from authorities;
• Maintain regulatory records;
• Establish, exercise or defend legal claims;
• Conduct fraud investigations; and
• Fulfil other legal or regulatory requirements.

5. IS PROVIDING PERSONAL DATA MANDATORY?

Some personal data is required for us to provide our services.

Where information is marked as mandatory, failure to provide such information may mean that we are unable to:

• Create your account;
• Process your booking;
• Confirm your identity;
• Process payment;
• Provide a virtual office service;
• Provide building access;
• Enter into a service agreement with you; or
• Provide other requested services.

Information that is not required will generally be identified as optional where appropriate.

6. CONSENT

Where consent is required by applicable law, we will obtain your consent before collecting, using or disclosing your personal data for the relevant purpose.

You may withdraw your consent, where applicable, by contacting us.

Withdrawal of consent will not affect processing carried out before the withdrawal became effective.

Please note that withdrawing consent may affect our ability to continue providing certain services where the relevant personal data is necessary to provide those services or to comply with legal obligations.

7. MARKETING COMMUNICATIONS

With your consent or where otherwise permitted by applicable law, we may send promotional information through:

• Email;
• SMS;
• WhatsApp;
• Telephone;
• Social media; or
• Other digital communication channels.

You may unsubscribe from marketing communications at any time by:

• Using the unsubscribe option included in the communication;
• Following the opt-out instructions provided; or
• Contacting us at wecare@ada2u.com.

Service-related communications such as booking confirmations, payment notices, account notifications or important operational updates are not considered promotional communications and may still be sent where necessary to provide the service.

8. DISCLOSURE OF PERSONAL DATA

We do not sell your personal data.

We may disclose or provide access to your personal data where reasonably necessary to the following categories of recipients.

Service Providers

Including providers of:

• Website hosting;
• Cloud storage;
• IT services;
• Customer relationship management systems;
• Email services;
• Booking systems;
• Accounting systems;
• Data analytics;
• Cybersecurity; and
• Other technology services.

Payment Providers

Including:

• Banks;
• Payment gateway providers;
• Financial institutions; and
• Payment processing companies.

Building and Workspace Service Providers

Including:

• Building management;
• Property management;
• Security providers;
• Access control providers;
• Cleaning companies;
• Maintenance contractors; and
• Facility management providers.

Mail and Courier Providers

Where you use virtual office, mail handling or forwarding services, we may share relevant information with:

• Courier companies;
• Postal service providers; and
• Mail handling partners.

Professional Advisers

Including:

• Lawyers;
• Accountants;
• Auditors;
• Insurance providers;
• Tax advisers; and
• Other professional consultants.

Government and Regulatory Authorities

We may disclose information where required or permitted by applicable law, regulation, court order or lawful request from a competent authority.

Corporate Transactions

If ADA2U undergoes a merger, acquisition, restructuring, financing, sale of assets or similar corporate transaction, relevant personal data may be disclosed to advisers, potential purchasers or other parties involved in the transaction, subject to appropriate confidentiality and legal requirements.

9. THIRD-PARTY PAYMENT PROCESSING

Online payments may be processed through third-party payment gateway providers.

When you make a payment, the payment provider may independently collect information such as your:

• Cardholder name;
• Card number;
• Expiry date;
• Security code;
• Bank account information; or
• Other payment credentials.

ADA2U does not necessarily receive or store your complete payment card information.

Your payment information will also be subject to the payment provider’s privacy policy and terms.

We recommend reviewing the relevant payment provider’s privacy policy before completing a transaction.

10. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies.

Cookies are small files placed on your device that help us recognise your browser, remember your preferences and understand how our website is used.

We may use cookies for purposes such as:

Essential Cookies

Required for important website functions such as:

• Account login;
• Shopping cart functionality;
• Checkout;
• Security; and
• Booking functions.

Functional Cookies

Used to remember preferences and improve your website experience.

Analytics Cookies

Used to help us understand:

• Website traffic;
• Popular pages;
• Visitor behaviour;
• Website performance; and
• How users interact with our website.

Advertising and Marketing Cookies

Where applicable, these may be used to:

• Measure advertising performance;
• Display more relevant advertisements; and
• Understand the effectiveness of marketing campaigns.

You may manage or disable cookies through your browser settings or, where available, through our cookie preference tools.

Disabling certain cookies may affect the functionality of our website.

11. ANALYTICS AND THIRD-PARTY TECHNOLOGIES

We may use third-party analytics, advertising or website tools such as Google services, social media platforms or other technology providers.

These providers may process information about your interaction with our website in accordance with their respective privacy policies.

Where required by law, non-essential analytics or advertising technologies will be used subject to applicable consent requirements.

12. SOCIAL MEDIA

ADA2U may operate pages or accounts on third-party social media platforms.

When you interact with us through a social media platform, your information may also be collected and processed by the operator of that platform.

The platform’s own privacy policy will apply to its processing of your information.

13. VIRTUAL OFFICE AND BUSINESS ADDRESS SERVICES

If you purchase a virtual office, registered business address or mail handling service, we may require additional personal or business information to:

• Verify your identity;
• Verify your business;
• Comply with applicable regulations;
• Manage incoming mail;
• Forward mail;
• Maintain records;
• Prevent fraudulent use of our address; and
• Respond to lawful enquiries from authorities.

This may include company registration documents, identification documents and details of directors or authorised representatives where reasonably required.

14. CCTV AND PREMISES SECURITY

Where CCTV is used at ADA2U premises, recordings may be processed for:

• Security;
• Crime prevention;
• Incident investigation;
• Access control;
• Protection of property;
• Safety of customers and staff; and
• Resolution of disputes.

CCTV recordings will only be accessed by authorised persons or disclosed where reasonably necessary or required by law.

15. DATA SECURITY

We take reasonable and appropriate technical, organisational and physical measures to protect personal data against:

• Loss;
• Misuse;
• Unauthorised access;
• Unauthorised disclosure;
• Alteration;
• Destruction; and
• Other unlawful processing.

Measures may include:

• Access controls;
• Password protection;
• Secure systems;
• Security monitoring;
• Staff access restrictions;
• Physical security;
• Data backup;
• Cybersecurity measures; and
• Appropriate requirements for service providers.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

You are responsible for maintaining the confidentiality of your ADA2U account credentials and should notify us promptly if you believe your account has been compromised.

16. PERSONAL DATA BREACHES

If we become aware of a personal data breach, we will assess the incident and take appropriate steps to contain, investigate and address the breach.

Where required under applicable Malaysian personal data protection laws, we will notify the relevant regulatory authority and affected individuals within the applicable requirements.

17. DATA RETENTION

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected or to satisfy legal, regulatory, accounting, contractual or operational requirements.

The applicable retention period may vary depending on:

• The type of information;
• The services provided;
• Contractual requirements;
• Accounting requirements;
• Tax requirements;
• Legal limitation periods;
• Security requirements; and
• Regulatory obligations.

When personal data is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it.

18. CROSS-BORDER TRANSFER OF PERSONAL DATA

Certain service providers used by ADA2U may operate servers or facilities outside Malaysia.

As a result, personal data may in certain circumstances be transferred to or processed in another country.

Where personal data is transferred outside Malaysia, ADA2U will take reasonable steps to ensure that such transfers are carried out in accordance with applicable Malaysian personal data protection laws and that appropriate safeguards are implemented where required.

19. YOUR PERSONAL DATA RIGHTS

Subject to applicable Malaysian personal data protection laws and any applicable exceptions, you may have rights relating to your personal data.

These may include the right to:

Request Access

Request information about personal data held by us and obtain access to such data, subject to applicable legal requirements.

Request Correction

Request correction of personal data that is inaccurate, incomplete, misleading or not up to date.

Withdraw Consent

Withdraw consent previously provided where our processing relies upon your consent, subject to applicable law and contractual requirements.

Limit Direct Marketing

Request that we stop or not begin using your personal data for direct marketing purposes.

Request Data Portability

Where applicable under Malaysian law and subject to technical feasibility, compatibility and applicable requirements, request the transmission of eligible personal data to another data controller.

Make a Complaint

Contact us regarding any concern about how your personal data is being processed.

You may also have the right to lodge a complaint with the Personal Data Protection Commissioner Malaysia in accordance with applicable law.

To exercise your rights, please contact:

Email: wecare@ada2u.com

We may request information necessary to verify your identity before processing a personal data request.

20. ACCURACY OF PERSONAL DATA

We take reasonable steps to ensure that personal data held by us is accurate and up to date.

You are encouraged to inform us promptly if your personal data changes.

You may update certain information through your online account, where this functionality is available, or contact us at:

wecare@ada2u.com

21. CHILDREN’S PERSONAL DATA

Our services are generally intended for individuals aged 18 years and above.

We do not knowingly collect personal data from children for the purpose of entering into workspace memberships or commercial service agreements unless such collection is appropriate and permitted by law.

Where information relating to a minor is required, we may request consent or authorisation from a parent, legal guardian or other authorised person where applicable.

22. THIRD-PARTY LINKS

Our website may contain links to websites operated by third parties.

These websites operate independently from ADA2U and may have their own privacy policies.

We are not responsible for the privacy practices, security or content of third-party websites.

We recommend reviewing the privacy policy of any external website before providing personal information.

23. BUSINESS TRANSFERS

If our business or part of our business is sold, reorganised, merged or transferred, personal data relevant to the affected business may form part of the transferred assets.

Any such transfer will be conducted subject to applicable personal data protection requirements.

24. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect:

• Changes to our services;
• Changes to our website;
• Changes in technology;
• Changes in our business operations; or
• Changes to applicable laws and regulations.

The latest version will be published on ada2u.com with the updated revision date.

Where changes materially affect how we process your personal data, we may provide additional notice where appropriate or required by law.

We encourage you to review this Privacy Policy periodically.

25. LANGUAGE

This Privacy Policy may be made available in English.

In the event of any inconsistency between language versions, the applicable version will be interpreted subject to Malaysian law and the requirements of the Personal Data Protection Act 2010.

26. CONTACT US

If you have questions about this Privacy Policy, wish to exercise your personal data rights, withdraw your marketing consent, correct your personal information or make a privacy-related complaint, please contact:

ADA Shared Services Sdn Bhd.
Company Registration No.: 200801004348 / 805632-X

Email: wecare@ada2u.com
Telephone: +604 619 2500
Website: ada2u.com
Business Address: Penthouse 1-21-1, Suntech @ Penang Cybercity,
Lintang Mayang Pasir 3, Bayan Baru,
11950 Penang, Malaysia

 

We will endeavour to respond to privacy-related enquiries in accordance with applicable Malaysian personal data protection requirements.