Privacy Policy

PULMUR® Coffee respects your privacy and is committed to handling personal data responsibly.

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you visit our website, contact us, request samples, submit a business enquiry, request a quotation, place an order or otherwise interact with us.

PULMUR® Coffee is a brand operated by:

Ephesus Global Trading Sdn. Bhd.
Company Registration No. 201901013163 (1322491-X)

For the purposes of applicable Malaysian personal data protection law, Ephesus Global Trading Sdn. Bhd. is responsible for the personal data described in this Privacy Policy.

1. Personal Data We May Collect

Depending on how you interact with us, we may collect the following information.

Contact and identity information

This may include:

• Your name
• Job title
• Email address
• Telephone or WhatsApp number
• Other contact details

Business information

This may include:

• Company or trading name
• Business address
• Company registration information
• Business type
• Outlet or location information
• Purchasing requirements
• Information about your coffee programme or operations

Enquiry and order information

This may include:

• Products you are interested in
• Sample requests
• Quotations
• Order history
• Delivery information
• Preferred coffee profiles
• Grind or brewing requirements
• Custom blend requirements
• Communications with our team
• Customer service records

Payment and transaction information

This may include:

• Payment status
• Invoice information
• Transaction records
• Billing details
• Information necessary to process or reconcile payments

Where payments are processed by a third-party payment provider, we may not directly receive or store your complete payment card information.

Website and technical information

When you use our website, we may automatically receive certain technical information, such as:

• IP address
• Browser type
• Device information
• Pages visited
• Referring website
• Approximate location derived from technical information
• Date and time of visits
• Website interaction information

Marketing information

Where applicable, we may keep information about:

• Your communication preferences
• Whether you have subscribed to marketing communications
• Your engagement with emails or other communications
• Your business interests and product preferences

2. How We Collect Personal Data

We may collect personal data:

• Directly from you
• When you submit a website form
• When you contact us by email, telephone, WhatsApp or social media
• When you request samples or a quotation
• When you place or discuss an order
• Through our ongoing business relationship with you
• From your employer or another representative of your organisation
• From service providers involved in a transaction
• Through cookies and similar website technologies, where used
• From publicly available business sources where reasonably necessary for legitimate business purposes

3. Why We Use Personal Data

Responding to enquiries

We may use personal data to:

• Respond to questions
• Discuss your coffee requirements
• Recommend suitable products
• Arrange samples
• Prepare quotations
• Communicate with you about potential business opportunities

Processing and fulfilling orders

We may use personal data to:

• Confirm and manage orders
• Process payments
• Prepare products
• Arrange delivery
• Issue invoices
• Maintain transaction records
• Provide customer support

Managing business relationships

We may use personal data to:

• Maintain customer and supplier records
• Manage standing orders
• Provide account support
• Understand purchasing requirements
• Communicate operational information
• Manage our commercial relationship with your business

Custom products and services

We may use personal data to:

• Develop custom blends
• Manage private label projects
• Process artwork or packaging requirements
• Coordinate testing and approvals
• Deliver agreed custom services

Improving our products and services

We may use personal data to:

• Understand how customers use our services
• Improve our website
• Improve product and service quality
• Analyse business performance
• Develop new products or services

Marketing and business communications

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

• PULMUR® products
• New coffee releases
• Supply services
• Business offers
• Events
• Other relevant updates

You may ask us to stop sending direct marketing communications at any time.

Legal and operational purposes

We may process information where reasonably necessary to:

• Maintain business and accounting records
• Comply with legal or regulatory requirements
• Prevent fraud or misuse
• Protect our legal rights
• Resolve disputes
• Enforce agreements
• Respond to lawful requests from authorities

4. Providing Personal Data

Some information is necessary for us to:

• Respond to an enquiry
• Prepare a quotation
• Process an order
• Arrange delivery
• Provide requested services
• Comply with legal obligations

Where required information is not provided, we may be unable to provide the requested product or service.

Other information may be optional.

5. Sharing Personal Data

We may disclose personal data where reasonably necessary to the following categories of recipients.

Service providers

These may include providers that support:

• Website hosting
• Cloud storage
• Email and communications
• Customer relationship management
• Accounting
• Payment processing
• Analytics
• Information technology
• Fulfilment
• Courier and logistics services
• Other business operations

These service providers may only receive information reasonably necessary for the services they provide.

Professional advisers

We may disclose information to professional advisers such as:

• Accountants
• Auditors
• Lawyers
• Insurers
• Other professional consultants

Government and regulatory authorities

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

Business transactions

If our business or relevant assets are reorganised, sold, transferred, merged or acquired, personal data may be disclosed as part of that process, subject to appropriate confidentiality and legal requirements.

We do not sell personal data to third parties for their own independent marketing purposes.

6. International Transfers

Some of our technology or service providers may process or store information outside Malaysia.

Where personal data is transferred outside Malaysia, we will take reasonable steps to ensure that the transfer is handled in accordance with applicable Malaysian personal data protection requirements.

Depending on the circumstances, this may include assessing the destination, recipient and safeguards used to protect the information.

7. Cookies and Similar Technologies

Our website may use cookies and similar technologies to:

• Operate essential website functions
• Remember preferences
• Understand website usage
• Measure performance
• Improve the website and our communications

Some cookies may be placed by third-party technology or analytics providers.

You can manage or disable cookies through your browser settings. Disabling certain cookies may affect how some website features work.

Where applicable, additional information about specific cookies or consent choices may be provided through a cookie notice or consent tool.

8. Data Security

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

• Loss
• Misuse
• Unauthorised access
• Unauthorised disclosure
• Alteration
• Destruction

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

You should also take appropriate steps to protect information and account credentials under your control.

9. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for any additional period required or permitted by law.

Retention periods may depend on:

• The nature of our relationship with you
• Contractual requirements
• Accounting and tax obligations
• Legal requirements
• Dispute or claims periods
• Operational requirements

When personal data is no longer reasonably required, we may securely delete, destroy or anonymise it.

10. Your Rights

Subject to applicable Malaysian law and any legal limitations or exceptions, you may have the right to:

• Request access to personal data we hold about you
• Request correction of inaccurate or incomplete personal data
• Withdraw consent where processing is based on consent
• Ask us to stop or limit certain direct marketing communications
• Make a data portability request where the applicable legal requirements are met and the transfer is technically feasible
• Raise a concern about how your personal data is handled

A request may be subject to identity verification and any procedures or limitations permitted by law.

Withdrawing consent does not affect processing that was lawfully carried out before the withdrawal and may affect our ability to provide certain services.

11. Direct Marketing

You may opt out of marketing communications at any time by:

• Using the unsubscribe option provided in a marketing communication, where available
• Contacting us using the details below

We may still send non-marketing communications that are necessary for an existing enquiry, order, account or business relationship.

12. Personal Data Breaches

Where we become aware of a personal data breach, we will assess the circumstances and take appropriate action in accordance with applicable law.

Where legally required, this may include notifying the relevant authority and affected individuals.

13. Third-Party Websites

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

We are not responsible for the privacy practices of third-party websites that we do not control.

We encourage you to review the privacy information provided by those third parties.

14. Children's Personal Data

Our products and B2B services are not directed at children.

We do not knowingly seek to collect personal data from children through our business enquiry services.

15. Changes to This Privacy Policy

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

• Changes in our services
• Changes in how we process personal data
• Changes in technology
• Changes in applicable law

The latest version will be published on our website together with the date of the most recent update.

16. Contact Us

For questions, requests or concerns relating to personal data, please contact:

You may also contact the relevant Malaysian personal data protection authority where you believe your personal data has been handled in breach of applicable law.