Launch Numel
Launch Numel

Privacy Policy

Last Updated: 27/02/2026
Effective Date: 27/02/2026

1. Introduction

Welcome to Numel, a web-based AI decision platform operated by The Morning Owl SDN. BHD. (“TMO,” “we,” “us,” or “our”), a company registered under the laws of Malaysia.

This Privacy Policy explains how we collect, use, process, store, and protect information when you access or use Numel (the “Platform”) and related services (the “Services”).

Numel enables users to upload datasets, apply machine learning models through a guided interface, and generate structured insights for business decision-making.

We are committed to protecting your data in accordance with:

  • Personal Data Protection Act 2010 (PDPA Malaysia)

  • EU General Data Protection Regulation (GDPR), where applicable

  • California Consumer Privacy Act (CCPA), where applicable

By accessing or using Numel, you agree to the collection and use of information as described in this Privacy Policy.

2. Who We Are

Numel is owned and operated by:

The Morning Owl SDN. BHD.
Registered Company No.: 202501015530 (1616945K)
Email: info@themorningowl.co
Website: https://www.themorningowl.co

For Numel:

  • TMO acts as the Data Controller for account and platform data.

  • TMO acts as a Data Processor for datasets uploaded by business users, where the user determines the purpose and nature of the data processed.

3. Definitions

For clarity:

  • “Personal Data” means information that identifies or can identify an individual.

  • “User Data” refers to datasets uploaded into Numel by users.

  • “Processing” means collection, storage, analysis, deletion, or any other handling of data.

  • “Data Controller” determines the purposes and means of processing.

  • “Data Processor” processes data on behalf of the controller.

  • “User” refers to any individual or organization using Numel.

4. Information We Collect

a. Information You Provide Directly

  • Account details: Name, email address, company name, password

  • Billing information (where applicable)

  • Support communications and feedback

  • Uploaded datasets (which may contain business or personal data depending on user input)

b. Information Collected Automatically

  • IP address

  • Device type and operating system

  • Browser type

  • Platform interaction logs

  • Session duration and feature usage

  • Cookies and analytics data

c. Uploaded Data Responsibility

Numel processes datasets uploaded by users strictly according to user instructions.Users are responsible for ensuring that:

  • They have lawful rights to upload and process the data

  • Any personal data within datasets complies with applicable data protection laws

Numel does not independently determine the purpose of uploaded dataset processing.

5. Purpose of Processing

We process information to:

  • Create and manage user accounts

  • Provide AI modeling and analysis services

  • Generate model outputs and structured insights

  • Improve system performance and usability

  • Maintain platform security and prevent misuse

  • Provide customer support

  • Comply with legal and regulatory requirements

We do not use uploaded datasets to train external AI systems unless explicitly stated and agreed in writing.

6. Lawful Basis for Processing (GDPR Reference)

Where applicable, processing is based on:

  • Contractual Necessity: To deliver the Numel platform services

  • Consent: For marketing communications or optional integrations

  • Legitimate Interest: For analytics, system improvement, and fraud prevention

  • Legal Obligation: To comply with applicable laws

7. Data Retention Policy

Account Data:

Retained while your account remains active and up to 24 months after account closure for compliance and administrative purposes.

Uploaded Datasets:

  • Stored temporarily during active sessions

  • Retained according to your subscription plan and system configuration

  • Automatically deleted upon account termination unless otherwise required by law

Users may request manual deletion at any time.

Model Outputs:

May be retained within your workspace until deleted by you.

8. Data Sharing and Disclosure

We do not sell personal data. We may share information only in the following circumstances:

a. Service Providers

Hosting, cloud infrastructure, analytics, payment processors, and security vendors under strict confidentiality agreements.

b. Legal Compliance

If required by law, regulation, court order, or government authority.

c. Business Transfers

In the event of merger, acquisition, or restructuring, data may be transferred under confidentiality safeguards.

We do not share uploaded datasets with third parties for marketing purposes.

9. International Data Transfers

If data is transferred outside Malaysia:

  • We implement contractual safeguards

  • We use reputable cloud providers with appropriate security certifications

  • We ensure equivalent data protection standards

10. User Rights

Under applicable laws, you may have the right to:

  • Access your personal data

  • Request correction of inaccurate data

  • Request deletion

  • Withdraw consent

  • Restrict or object to processing

  • Request data portability (where technically feasible)

  • Lodge a complaint with the relevant data protection authority

Requests may be submitted to info@themorningowl.co. We aim to respond within 21 business days.

11. Security Measures

Numel implements layered security controls, including:

  • SSL/TLS encryption

  • Encrypted data storage

  • Role-based access controls

  • Secure cloud infrastructure

  • Regular system monitoring and vulnerability assessments

While we apply industry-standard safeguards, no digital system can guarantee absolute security.

12. Cookies and Tracking Technologies

Numel uses cookies for:

  • Authentication and session management

  • Platform performance analytics

  • Usage optimization

You may manage cookie preferences via your browser settings. Detailed categories are outlined in our Cookie Policy.

13. Data Breach Procedure

If a data breach occurs:

  • We assess impact within 72 hours

  • Notify affected users and authorities where legally required

  • Implement remedial measures

  • Maintain breach documentation for compliance

14. Third-Party Integrations

Numel may integrate with third-party services such as:

  • Cloud storage providers

  • Analytics tools

  • Payment gateways

We are not responsible for third-party privacy practices. Users should review third-party policies independently.

15. Marketing Communications

If you opt in, we may send:

  • Product updates

  • Feature releases

  • Educational content

  • Service announcements

You may unsubscribe at any time via email preferences.

16. Updates to This Policy

We may revise this Privacy Policy to reflect changes in operations, technology, or legal requirements.

The “Last Updated” date will be revised accordingly. Significant changes may be communicated via email or platform notification.

17. Contact Us

For privacy-related inquiries:

Data Protection Officer
The Morning Owl SDN. BHD.
Email: info@themorningowl.co

18. Governing Law

This Privacy Policy is governed by the laws of Malaysia.
Any disputes shall be subject to the jurisdiction of Malaysian courts.


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The Morning Owl SDN. BHD. (202501015530 / 1616945-K)

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