Privacy Policy

This Privacy Policy explains how Global Success Partners Sdn Bhd ("we", "us", "our") collects, uses, discloses, and protects personal data when you use Salasilah (the "Service"), a genealogy platform for building and sharing family trees, available at salasilah.ilpam.my.

We handle personal data in accordance with the Malaysian Personal Data Protection Act 2010 (PDPA), as amended by the Personal Data Protection (Amendment) Act 2024. Please read this policy carefully. By creating an account and using the Service, you agree to the practices described here.

Your use of the Service is also governed by our Terms & Conditions. Where the two documents conflict on a matter of personal data, this Privacy Policy prevails.

1. Who we are and our role

Global Success Partners Sdn Bhd operates Salasilah. Our role under the PDPA depends on the data involved:

• Your account and the running of the platform — your sign-in details, security and activity logs, and aggregate analytics: here we are the data controller.
• The family-tree content you create — you decide which people to record, what to record about them, and whom to share it with. For that information you are the controller and we act as your data processor, handling it on your instructions. If you use Salasilah purely for your own personal, family or household genealogy, the PDPA's obligations may not apply to you at all (the "household" exemption); if you use it for an organisation, a business, or a public purpose, you take on the responsibilities of a data controller for that content (see section 4).

You can reach us — including our Data Protection Officer — on any privacy matter at assari@globalsuccesspartners.com.

2. The personal data we collect

a. Account information

When you sign in with Google (OAuth), we receive and store your email address, display name, and Google profile picture. We do not receive or store your Google password. We also record the date and time of each sign-in.

b. Family tree content you provide

The core purpose of the Service is to let you record genealogical information. This may include, for each person you add to a tree:

• Full name, gender, and family relationships (parents, spouses, children, adoption status);
• Birth and death dates and living/deceased status;
• A photograph, if you upload one;
• Optional descriptive details — a salutation or title, tags, a short note, and a longer free-text biography.

Some of these fields are private to you as the tree owner: a person's salutation, note, and biography are never included in any shared view or fork — they leave the Service only in a full data export that you choose to create. (Tags travel with the tree as ordinary content.) You may also import a tree from a Salasilah JSON backup or a standard GEDCOM (.ged) file; imported data is treated exactly like data you enter yourself.

This information may relate to you and to other individuals — both living and deceased — including family members who are not themselves users of the Service. See section 4 on your responsibilities when entering other people's data.

We do not collect national identification (NRIC) or passport numbers. The Service provides no field for them and does not store them — a deliberate data-minimisation choice, since they are not needed for genealogy and carry disproportionate risk.

c. Sensitive personal data

Some information you may enter can be treated as sensitive personal data under the PDPA — in particular information from which religious belief may be inferred (for example, use of the Islamic inheritance / faraid calculator). You provide such data voluntarily and at your own discretion, and by entering it you give your explicit consent to us processing it for the purposes in section 3.

The 2024 amendment adds biometric data to the categories of sensitive personal data. Salasilah does not collect or process biometric data. Any photograph you upload is stored as an ordinary image and is not used for facial recognition or any other biometric identification.

d. Usage and technical data

• Activity records: we log key actions (such as sign-ins, creating or editing people, opening a shared link, and exporting a tree) together with a timestamp. Where an IP address is involved, we store only a salted one-way hash of it — never the raw IP address — so that we can count distinct visitors without identifying them.
• Analytics: we use Umami, a privacy-focused, self-hosted, cookieless analytics tool, to understand aggregate usage. It does not use tracking cookies or share data with third-party advertising networks.
• Essential cookies: we use a single, essential session cookie to keep you signed in. It is HttpOnly and, in production, Secure. We do not use advertising or cross-site tracking cookies. A small browser localStorage value remembers your light/dark display preference.

3. How and why we use your data

We process personal data to:

• Provide the Service — create your account, store and display your family trees, and run features such as the faraid calculator;
• Enable sharing — generate the view-only or forkable share links that you choose to create, and apply the access controls (sign-in requirement, allowlist, passcode, expiry) you set;
• Maintain security and integrity — authenticate users, enforce access permissions, and detect or prevent abuse;
• Understand and improve the Service through aggregate, privacy-preserving analytics;
• Improve the Service — our authorised administrators may access your account and family-tree content where reasonably necessary to operate, support, secure, and improve the product;
• Communicate with you about your account or a request you make to us.

We do not sell your personal data, and we do not use it for third-party advertising or automated decision-making that produces legal effects.

4. Data about other people (your responsibility)

A family tree, by its nature, contains information about people other than yourself. As explained in section 1, you are the controller of the content you add (unless your use is purely personal, family or household). When you add another individual's personal data to a tree, you confirm that you are entitled to do so and that you will handle their information responsibly. In particular:

• Only add information you have obtained lawfully and are permitted to record;
• Where required, obtain the consent of living individuals before adding their data — especially sensitive data such as identification numbers or photographs;
• Use the Service's sharing controls thoughtfully, since sharing a tree may disclose others' data to the people you share it with.

If a person whose data appears in a tree contacts us and asks for it to be corrected or removed, we may contact the relevant tree owner and, where appropriate, take steps to address the request.

PDPA rights apply to living individuals. The 2024 amendment confirms that a deceased person is not a "data subject" under the Act. Even so, when a tree is shared, Salasilah minimises the details shown for everyone — living and deceased — as a privacy courtesy (see section 5).

5. Disclosure and sharing

We disclose personal data only:

• At your direction — to people you deliberately share a tree or link with. You control the scope, gating, and expiry of every share you create, and you can revoke a share at any time. Every share link requires the recipient to sign in with Google and enter a passcode — there are no open, anonymous links.
• To service providers (our data processors) that help us operate the Service, under confidentiality and security obligations — currently our cloud/server hosting provider, Google (sign-in), Dropbox (encrypted off-site backups), and our self-hosted Umami analytics. Under the 2024 amendment these processors are themselves directly responsible for protecting the data. Some may process or store data outside Malaysia (for example, backup storage); where they do, we take reasonable steps to ensure a comparable level of protection.
• Where required by law — to comply with a valid legal obligation, court order, or lawful request from an authority.

Privacy-protective sharing. To limit exposure when you share, shared views automatically reduce every person's name to a single given name — for the living and the deceased alike — and show only the birth year (not the full date) for living individuals, while you keep the full detail in your own private view. Your private salutation, notes, and biography are never included in a shared view or fork.

6. Data retention

We keep your account and tree data for as long as your account is active or as needed to provide the Service. You can delete individual people, photos, or entire trees at any time, and you can ask us to delete your account. Share links you create can be set to expire automatically and can be revoked by you at any time. When you delete content it is removed from the live Service; residual copies may persist in our encrypted backups for a limited period (typically up to a few months) before those backups rotate out. We retain minimal, privacy-preserving activity records for security and analytics.

7. How we protect your data

• All traffic is encrypted in transit using HTTPS/TLS;
• Access to a tree is restricted to its owner and to the people the owner explicitly shares it with; every share is protected by a passcode, Google sign-in, or both (the owner's choice), so there are no open, anonymous links;
• Share passcodes are stored as salted hashes and additionally encrypted at rest, so a database leak alone does not expose them;
• Sign-in and passcode entry are rate-limited to resist brute-force attempts and abuse;
• Tree exports can optionally be locked with a password of your choosing;
• Uploaded images are validated to reduce the risk of malicious files;
• Where we log IP addresses we keep only a salted one-way hash, never the raw address;
• Backups are encrypted and stored off-site.

No system can be guaranteed perfectly secure, but we take reasonable technical and organisational measures appropriate to the sensitivity of the data.

8. Data breach notification

In line with the 2024 amendment to the PDPA, if a personal data breach occurs that affects your personal data, we will notify the Personal Data Protection Commissioner as soon as practicable. Where a breach is likely to cause you significant harm, we will also notify you without unnecessary delay and explain what happened and the steps you can take.

9. Your rights under the PDPA

Subject to the PDPA, and as a living individual, you have the right to:

• Access the personal data we hold about you;
• Correct data that is inaccurate, incomplete, or out of date;
• Data portability — introduced by the 2024 amendment — to receive certain data in a portable form, or have it transmitted to another provider where technically feasible. Salasilah supports this with a tree export in structured JSON (with an optional encrypted format) and a standard GEDCOM (.ged) export readable by other genealogy software;
• Withdraw consent to our processing (this may mean we can no longer provide parts of the Service);
• Limit the processing of your data in certain circumstances;
• Delete your data, subject to any legal retention obligations.

To exercise any of these rights, contact us at assari@globalsuccesspartners.com. You also have the right to lodge a complaint with the Personal Data Protection Commissioner, Malaysia if you believe your data has been mishandled.

10. Children's data

The Service is intended for adults. A tree may legitimately include information about children as family members, but the account holder is responsible for ensuring they have the right to record such information. We do not knowingly allow children to create their own accounts.

11. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes we will update the "Last updated" date above and, where appropriate, notify you. Continued use of the Service after a change means you accept the updated policy.

12. Contact us

For any questions about this policy or your personal data, contact Global Success Partners Sdn Bhd at assari@globalsuccesspartners.com.