TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T)) of [Registered Address], Malaysia (“Trainers Hub”, “Platform”, “we”, “us”, “our”), operating WisdomHub and Programme Builder (together, the “Trainers Hub products”).

Effective Date: [Date]
Last Updated: 16 September 2026 (renamed; Programme Builder bridge, records, release, definitions added)

Merchant Disclosure (Consumer Protection (Electronic Trade Transaction) Regulations 2024)

In compliance with the Consumer Protection (Electronic Trade Transaction) Regulations 2024 (P.U. (A) 449/2024), Regulation 3 and the Schedule:

• Business name: TRAINERS HUB SDN. BHD.
• Business registration number: 202601033142 (1695237-T)
• Website address: wisdomhub.com.my
• Email address: hello@wisdomhub.com.my
• Telephone: [+60 X XXXX XXXX]
• Physical office address: [Full address], Malaysia
• Description of services: Online marketplace facilitating discovery and booking of corporate training services between Trainers / Training Providers and Malaysian corporate Clients (WisdomHub), and a programme-outline drafting tool (Programme Builder).
• Full price: Subscription and credit-pack prices are published at [/pricing] and are shown at checkout inclusive of Service Tax where it applies; no delivery or other cost is added. The price of a training engagement is set by the Trainer or Training Provider and shown on the brief or booking before you confirm.
• Method of payment: FPX online banking through our payment gateway; card only where Clause 6.3 provides for it.
• Terms and conditions of sale: This Agreement, together with the applicable role agreement (Clause 1.3).
• Estimated time of supply: Subscriptions and credits are activated on successful payment. Training is delivered on the dates agreed between the Client and the Trainer or Training Provider.
• Refund and complaints policy: See Clause 6 (refunds) and Clause 15 (dispute resolution) below; complaints to hello@wisdomhub.com.my.
• Language: Regulation 4 requires this disclosure in Bahasa Malaysia; other languages may be used in addition. [Bahasa Malaysia version pending.]

1. About These Terms

In short. One agreement covers every Trainers Hub product you use, so you accept it once and know which document governs what.

1.1 This Trainers Hub User Agreement (the “Agreement” or the “Terms”) governs your access to and use of the Trainers Hub products: any website, mobile application, dashboard, API, or other service we make available under the WisdomHub brand, and Programme Builder (collectively, the “Services”). A reference in any other Trainers Hub document to the “Platform Terms of Service” or the “Terms of Service” is a reference to this Agreement.

1.2 The Platform is an online marketplace that connects:
(a) individual freelance corporate trainers (“Trainers”);
(b) training providers incorporated as Sdn Bhd or registered as a Perkongsian Liabiliti Terhad / PLT (“Training Providers” or “TPs”); and
(c) Malaysian companies seeking corporate training services (“Clients”, shown as “company” on the Platform); and
(d) anyone holding an account to use another Trainers Hub product, whether or not they use the marketplace,
(together, “Users”).

1.3 By creating an account or using the Services, you agree to these Terms, our Privacy Policy, the Data Processing Addendum (where applicable), and (as applicable) the Trainer and Training Provider Agreement or Client Terms of Use. If you do not agree, you must not use the Services.

1.4 These Terms form an electronic contract under the Electronic Commerce Act 2006 and are legally binding once accepted by clicking “I agree” or by using the Services. Your acceptance is logged with timestamp, IP address, and device identifier, and constitutes admissible evidence under sections 90A–90C of the Evidence Act 1950.

2. Platform Role and Disclaimer of Engagement

In short. You contract with the other party, not with us. We run the marketplace and the tools; we do not deliver, vet, or guarantee training, and we never hold your HRD Corp money.

2.1 The Platform is an intermediary technology service. We facilitate discovery, listing, booking, and administrative coordination between Trainers/TPs and Clients.

2.2 We are not a party to any training engagement, contract for services, or commercial arrangement between a Trainer/TP and a Client. We do not employ Trainers, do not deliver training, and do not certify the quality, accuracy, or compliance of any course content.

2.3 We do not collect, hold, or disburse HRD Corp levy funds. All HRD Corp grant claims, levy utilisation, and disbursements are processed directly between the Client, the accredited Training Provider, and Pembangunan Sumber Manusia Berhad (“HRD Corp”) via the eTRiS portal.

2.4 Where the Platform displays “HRDF claimable”, “HRD Corp claimable”, or similar designations on a listing, that designation reflects the Trainer/TP’s self-declared and (where verifiable) Platform-checked accreditation status only. It is not a guarantee that HRD Corp will approve any claim, grant, or reimbursement.

2.5 Payments architecture. Payments processed through the Platform are executed by our nominated payment gateway (at launch, Billplz Sdn. Bhd., which processes the FPX payment and executes the split; we do not ourselves accept, hold, or settle User funds) using split payment at the time of transaction: the Platform’s Administrative Fee is deducted at source and the balance is settled directly to the receiving User’s bank account. The Platform does not hold, pool, or defer User funds in its own accounts, and does not operate an escrow, wallet, or stored-value facility.

2.6 Sole exception — non-HRD Corp direct engagements. Where a Client engages a Trainer for a programme that is not claimed through HRD Corp and elects the Platform operator’s reseller arrangement, the Platform operator contracts as principal: the Client pays the Platform operator’s own account and the Platform operator separately engages and pays the Trainer as its vendor. Funds received on this path are the Platform operator’s own receivables and payables, not third-party money held on trust or in escrow.

2.7 No vetting of Users. We are an intermediary. Any person or entity meeting the eligibility requirements in Clause 3 may register. We do not:
(a) conduct criminal record, bankruptcy, litigation, or credit checks on any User;
(b) take up references, contact past clients or employers, or assess character, integrity, or reliability;
(c) enquire into whether a User is employed elsewhere, or whether their use of the Platform breaches any obligation they owe to an employer, principal, professional body, or other third party;
(d) assess, test, observe, or accredit teaching ability, subject-matter competence, or the quality of any programme or course material;
(e) inspect training venues or supervise training delivery; or
(f) verify a User’s financial standing or ability to pay.

2.8 What we do instead is limited to the document checks and screening set out in Clause 3.2 and in our KYC procedure — confirming that a document was produced and, where a register is available to us, that it matches. That is a document check, not an endorsement. Verification of an accreditation certificate does not mean we have assessed the person. We do not collect references, and a User must not represent that we have checked any.

2.9 We make no representation and give no warranty as to the identity, character, employment status, honesty, solvency, competence, or suitability of any User. Each User is responsible for satisfying itself as to any counterparty before contracting with them, and for conducting whatever additional checks its own policies or its own regulator require. Clause 9 (Disclaimers) and Clause 10 (Limitation of Liability) apply.

2.10 Programme Builder. Programme Builder (https://programmebuilder.netlify.app) is a separate Trainers Hub product, sold under its own terms published on its site, and is not part of the Platform marketplace. Three things carry across:
(a) an outline, description, or other material you import from Programme Builder into the Platform is your content: Clause 8 applies to it, and Clauses 4 (listing accuracy) and 13 (intellectual property) of the Trainer and Training Provider Agreement apply to it as if you had typed it into the Platform yourself;
(b) your Platform account is your identity across every Trainers Hub product, and the credit wallet on that account is the only wallet for every Trainers Hub product (Clause 6.5B); and
(c) an answer given by a support chatbot in any Trainers Hub product is information to help you use the product. It is not advice, not a representation, and not a term of this Agreement or of any contract between Users.

3. Eligibility and Account Creation

In short. You keep your account safe by giving us accurate details, holding the documents we ask for, and guarding your sign-in.

3.1 To create an account you must:
(a) be at least 18 years of age and have legal capacity to contract under the Contracts Act 1950;
(b) if registering on behalf of a company, be duly authorised to bind that company;
(c) provide accurate, current, and complete information; and
(d) maintain the confidentiality of your login credentials.

3.2 We may require verification documents and may apply our Know-Your-Customer (“KYC”) procedure (as published from time to time), which may include:
(a) for individual Trainers, the HRD Corp accreditation certificate and the TTT or TTT exemption certificate, which carry the NRIC or passport number we rely on for identity (see Privacy Policy Clause 3.2);
(b) SSM registration documents (Section 14/17 Superform, Form 9, Form 24/49, or current equivalents);
(c) HRD Corp Train-the-Trainer (“TTT”) certificate and/or TP accreditation status;
(d) tax registration documents (including SST registration if applicable);
(e) authorisation letter signed by a director or partner where the registrant is not a director or partner;
(f) sanctions and politically-exposed-person (“PEP”) screening for higher-value Clients.

3.3 You are responsible for all activity that occurs under your account. Notify us immediately at hello@wisdomhub.com.my of any unauthorised access.

4. Acceptable Use

In short. The Platform stays useful for you when everyone deals honestly, keeps engagements on the Platform, and uploads only what they have the right to.

4.1 You agree not to:
(a) submit false, misleading, or fraudulent information;
(b) impersonate any person or misrepresent your accreditation status;
(c) circumvent the Platform to take bookings off-platform with the intent to avoid the Administrative Fee (see Clause 7);
(d) upload content that infringes intellectual property rights, is defamatory, obscene, or unlawful under Malaysian law (including the Communications and Multimedia Act 1998, Sedition Act 1948, and Penal Code);
(e) use the Platform to send unsolicited commercial communications in breach of the PDPA 2010 or the Communications and Multimedia (Technical Standards) Regulations;
(f) introduce malware or attempt unauthorised access to our systems;
(g) scrape, data-mine, or use automated tools to extract content;
(h) reverse-engineer, decompile, or copy the Services; or
(i) use the Platform in connection with any activity prohibited by Malaysian law, including the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (“AMLATFPUAA”).

4.2 Where training is delivered on a Client’s premises in Sabah or Sarawak, the Trainer/TP must comply with the Sabah Labour Ordinance (Cap. 67) or Sarawak Labour Ordinance (Cap. 76) as applicable, in addition to the Occupational Safety and Health Act 1994.

4.3 We may investigate suspected breaches and take action under Clauses 5 and 13.

5. Account Suspension and Termination

In short. You can close your account at any time. We can suspend or close it for breach, non-payment, lapsed accreditation, or risk to other Users, and your data is then handled as the Privacy Policy says.

5.1 We may suspend or terminate your account, with or without notice, if:
(a) you breach these Terms or your applicable User-type agreement;
(b) you fail to pay any sum when due;
(c) your accreditation or registration lapses, is revoked, or cannot be verified;
(d) we receive a credible complaint or evidence of misconduct, fraud, or harassment;
(e) required by law, court order, or regulatory authority; or
(f) your continued presence on the Platform poses reputational, financial, security, or legal risk to us or other Users.

5.2 You may terminate your account at any time by written notice to hello@wisdomhub.com.my, subject to:
(a) settlement of any outstanding fees or commissions;
(b) fulfilment of confirmed bookings (Trainers/TPs) or honouring confirmed engagements (Clients); and
(c) Clauses surviving termination as specified in Clause 18.

5.3 No refund of pre-paid subscription fees will be made on termination by us for cause, or on voluntary termination by you, unless required by law.

5.4 What happens to your personal data and content when your account closes is set out in Privacy Policy Clause 10.

6. Subscription Fees and Billing

In short. You see the price before you pay, renewals are announced in advance, and credits work the same across every Trainers Hub product.

6.1 Access to certain features is subject to a paid subscription. Current tiers, features, and prices are published at [/pricing] and form part of these Terms.

6.2 Subscriptions are billed monthly or annually in advance, in Ringgit Malaysia (MYR). The Platform [is / is not] registered for Service Tax under the Service Tax Act 2018 (SST registration number: [ST-XXXXXXXX] if applicable). Where SST applies, prices are stated exclusive of SST, and SST will be charged and remitted at the prevailing rate.

6.3 Renewal billing. Payment is processed via our nominated payment gateway. Each billing cycle, the Platform will issue you a payment request (payment link) for the renewal amount. Your subscription renews on successful payment of that request. Where the payment gateway supports tokenised card-on-file billing and you have opted in, renewal charges may instead be collected automatically against your stored card, and you may withdraw that authorisation at any time through your account dashboard.

6.4 Pre-renewal notification. We will send you a renewal reminder by email before each renewal date, and at least fourteen (14) days before the renewal date for annual subscriptions. You may decline renewal by not paying the renewal request, or cancel at any time through your account dashboard or by emailing hello@wisdomhub.com.my. Non-payment places the account in a grace period followed by suspension of paid features; paying a pending renewal request during the grace or dunning period restores the subscription without penalty.

6.5A Annual plans. Annual subscriptions are billed as a single upfront payment; instalment payment of annual plans is not offered. Upgrades take effect immediately with a prorated charge for the remainder of the current cycle. Downgrades take effect at the next renewal; no mid-cycle refunds are given on downgrade. Subscriptions cannot be paused; any pause offered at cancellation is a discretionary retention measure, is capped in duration, and does not extend credit expiry. A mid-cycle cancellation runs to the end of the paid period.

6.5B Credits. Certain Platform actions are metered in credits. Monthly credit grants attached to a subscription tier expire at the end of each monthly cycle and do not roll over. Purchased credit packs are valid for twelve (12) months from purchase. Credit packs are payable by online bank transfer (FPX); card payment is currently available for subscription billing only. Credits have no cash value, are non-transferable, and are not redeemable or refundable except where required by Malaysian law. Credits are held in one wallet on your Platform account and spend across every Trainers Hub product; a customer who uses Programme Builder alone tops up that same wallet. In Programme Builder each AI-generated draft costs ten (10) credits, debited when the draft is requested and reversed if the AI call fails; drafts are free during the pre-launch period (Pre-Launch Registration Terms Clause 7.1). Full credit mechanics are set out in the Trainer and Training Provider Agreement.

6.5C Promotional tier benefits. We may grant promotional access to a paid tier (for example, a launch benefit) for a stated period. Promotional access is shown in your billing dashboard with its end date, is not a paid subscription, does not auto-convert into a paid plan without a renewal payment request being issued and paid, and may not be exchanged for cash.

6.5 We may revise subscription fees on thirty (30) days’ written notice. Continued use after the effective date constitutes acceptance.

6.6 Subscriptions are non-refundable except where required by Malaysian law or expressly stated in these Terms.

6.7 Late payment may attract interest at 1.5% per month (or part thereof) on the outstanding amount, calculated from the due date until full payment.

6.8 E-Invoicing. Where mandatory under the Income Tax Act 1967 and the Inland Revenue Board (“LHDN”) e-Invoicing framework, we will issue e-Invoices via the MyInvois system. You must provide your TIN, SSM number, and SST registration number (if any) to enable e-Invoice issuance.

6.9 Order review and acknowledgement. Before you confirm any purchase through Platform checkout (a subscription, a credit pack, or an engagement payment) you are shown an order summary and can go back and correct any error before confirming. We acknowledge every order by email to your account address without undue delay. An order or acknowledgement is received when the recipient is able to access it (Regulation 6 of the Consumer Protection (Electronic Trade Transaction) Regulations 2024).

7. Platform Administrative Fee

In short. A flat five percent Administrative Fee on each engagement transacted through the Platform, collected at source, and still payable on an engagement you take off the Platform within twelve months of an introduction.

7.1 In addition to subscription fees, the Platform charges a flat Administrative Fee of five percent (5%) on every engagement transacted through the Platform, payable by the Trainer or TP. The rate is the same for all subscription tiers. The Administrative Fee covers payment gateway costs and platform operations, and is further defined in the Trainer and Training Provider Agreement.

7.2 The Administrative Fee is calculated on the applicable Fee Base:
(a) for engagements claimed through HRD Corp — the post-levy amount actually disbursed by HRD Corp to the Training Provider;
(b) for engagements where a TP engages a Trainer directly — the fee agreed between the TP and the Trainer; and
(c) for non-HRD Corp direct engagements under Clause 2.6 — the total fee paid by the Client,
in each case including any SST the supplier charges within that amount, and excluding reimbursable expenses.

7.3 The Administrative Fee is collected at source by payment gateway split at the time the relevant payment is made through Platform checkout, or, where the paying party is its own claim vehicle and no split occurs, is payable by that party through Platform checkout. Payment through the Platform is gated on delivery confirmation by both parties to the engagement, as recorded in-Platform.

7.4 Non-Circumvention. Trainers/TPs introduced to a Client via the Platform must process all engagements with that Client through the Platform for a period of twelve (12) months from first introduction. Off-platform engagements within this period are deemed Platform-originated and the Administrative Fee remains payable.

7.5 If a Trainer/TP breaches Clause 7.4, the Trainer/TP must pay the Platform a sum equal to the Administrative Fee that would have been payable on the off-platform engagement, plus an additional fifteen percent (15%) of that fee as a reasonable pre-estimate of the Platform’s costs of audit, administration, and lost downstream activity (the “Non-Circumvention Recovery”). The parties acknowledge that the Non-Circumvention Recovery is a genuine pre-estimate of loss and is not intended as a penalty for the purposes of section 75 of the Contracts Act 1950.

8. Intellectual Property

In short. Your content stays yours. You give us the licence we need to show it and run the Services; our software and brand stay ours.

8.1 All Platform software, design, branding, trademarks, and documentation are owned by us or our licensors and are protected by the Copyright Act 1987, Trade Marks Act 2019, and applicable international treaties.

8.2 We grant you a limited, non-exclusive, non-transferable, revocable licence to use the Services solely for their intended purpose during your subscription term.

8.3 You retain ownership of content you upload (course outlines, materials, profile information). By uploading, you grant us a worldwide, royalty-free, non-exclusive licence to host, store, reproduce, adapt for formatting, and display that content for the purposes of operating, marketing, and improving the Services.

8.4 You warrant that you have all necessary rights to grant the licence in Clause 8.3 and that your content does not infringe any third-party rights.

8.5 You may not use our name, logo, or branding without prior written consent, except to identify yourself as a User of the Platform.

8.6 Content across Trainers Hub products and AI-assisted content. The licence in Clause 8.3 and the warranty in Clause 8.4 apply to content you create in, or import from, any Trainers Hub product, including a draft produced with AI assistance that you choose to publish. Content you publish on the Platform is shown to other Users and, where your profile is public, to visitors, as the Privacy Policy and the Trainer and Training Provider Agreement describe. You remain responsible for checking an AI-assisted draft before you publish it.

9. Disclaimers

In short. The Services come as they are. We do not promise results, availability, or that HRD Corp will approve any claim.

9.1 The Services are provided “as is” and “as available”. To the maximum extent permitted by law, we exclude all warranties, conditions, and representations not expressly stated in these Terms.

9.2 We do not warrant that:
(a) the Services will be uninterrupted, secure, or error-free;
(b) any specific result will be obtained from use of the Services;
(c) any Trainer/TP listed will be suitable, qualified, or available for any particular Client engagement; or
(d) any HRDF claim will be approved by HRD Corp.

9.3 We do not vet, screen, or background-check Users, and give no warranty as to any User’s identity, character, employment status, honesty, solvency, competence, or suitability. Clause 2.7 sets out what we do and do not check, and applies in full to this Clause 9.

10. Limitation of Liability

In short. Our liability to you is capped, and we are not liable for the acts of other Users or for HRD Corp decisions, except where the law does not allow a cap.

10.1 Nothing in these Terms limits liability for:
(a) death or personal injury caused by negligence;
(b) fraud or fraudulent misrepresentation; or
(c) any other liability that cannot be excluded by Malaysian law.

10.2 Subject to Clause 10.1, our total aggregate liability to you arising out of or in connection with these Terms and the Services in any twelve (12) month period is limited to the greater of (a) MYR 50,000 or (b) the subscription fees paid by you to us in the preceding twelve (12) months.

10.3 We will not be liable for any:
(a) indirect, consequential, special, or punitive loss;
(b) loss of profit, revenue, business, opportunity, or anticipated savings;
(c) loss of data or goodwill;
(d) loss arising from the act, omission, or default of any Trainer, TP, or Client; or
(e) loss arising from HRD Corp claim rejection, audit findings, or regulatory action.

10.4 B2B acknowledgement. Each User acknowledges that it is a commercial party with the opportunity to take independent advice, and that the limitations in this Clause 10 are reasonable in the context of the fees payable for the Services.

11. Indemnity

In short. You cover us for claims that arise from your breach, your content, or your dealings with other Users.

11.1 You agree to indemnify and hold harmless the Platform, its directors, employees, and agents from and against all claims, losses, damages, fines, and reasonable legal costs arising out of:
(a) your breach of these Terms;
(b) your breach of any law including PDPA 2010, the HRD Corp Act 2001, or AMLATFPUAA;
(c) any content you upload; and
(d) any engagement, dispute, or claim between you and another User.

12. Privacy and Data Protection

In short. Your personal data is handled under the Privacy Policy, and your activity record is part of the Services so we can show you your own history and keep the Platform secure.

12.1 Our collection and use of personal data is governed by our Privacy Policy and (where applicable) Data Processing Addendum, each of which is incorporated into these Terms by reference.

12.2 You agree to comply with the Personal Data Protection Act 2010 (“PDPA 2010”) in respect of any personal data you process in connection with the Platform, including obtaining all required consents from data subjects.

12.3 Usage records. Part of the Services is a record of what you do on the Platform while signed in: what you save, view, search, send and publish, and when. We keep that record to show you your own activity, to keep your place, to answer support requests, to keep the Platform secure and to investigate disputes. Privacy Policy Clause 3.6 describes the record and Clause 10 says how long it is kept and how it is reduced. Use of the record for product analytics, and the joining of pre-registration browsing to your account, happen only with the consent you give in the cookie banner.

13. Modifications

In short. You get at least fourteen days’ notice of material changes, and a change that cuts your rights needs your re-acceptance.

13.1 We may amend these Terms from time to time. We will provide at least fourteen (14) days’ notice of material changes by email and/or in-app notification.

13.2 Material changes that adversely affect your rights or expand your obligations will require re-acceptance before continued use.

13.3 We maintain a versioned archive of these Terms at [/terms/archive]. The version applicable to you is the version in force on the date your account is active or your Booking is Confirmed, whichever is later.

14. Force Majeure

In short. Neither side is in breach for delays caused by events outside its control.

14.1 Neither party is liable for delay or failure to perform caused by events beyond reasonable control, including acts of God, war, terrorism, pandemic, government action, internet/telecommunications failure, or labour dispute. The affected party must notify the other promptly and use reasonable efforts to resume performance.

15. Dispute Resolution

In short. Talk first, then AIAC mediation, then AIAC arbitration in Kuala Lumpur. A claim up to MYR 100,000 can go straight to the Sessions Court or Magistrates’ Court.

15.1 The parties will attempt to resolve any dispute amicably through good-faith negotiation within thirty (30) days of written notice.

15.2 If unresolved, the dispute will be referred to mediation administered by the Asian International Arbitration Centre (“AIAC”) in Kuala Lumpur under the AIAC Mediation Rules in force at the time of the dispute.

15.3 If mediation fails within sixty (60) days of commencement, the dispute will be finally resolved by arbitration administered by the AIAC under the AIAC Arbitration Rules, by a sole arbitrator, seated in Kuala Lumpur, conducted in English. The arbitral award is final and binding on the parties.

15.4 Small-claims carve-out. Notwithstanding Clauses 15.2 and 15.3, either party may commence proceedings in the Sessions Court or Magistrates’ Court of Malaysia (in Kuala Lumpur) for any monetary claim where the amount in dispute does not exceed MYR 100,000, without first attempting mediation or arbitration.

16. Governing Law and Jurisdiction

In short. Malaysian law applies, and the Malaysian courts in Kuala Lumpur hear anything arbitration does not.

16.1 These Terms are governed by and construed in accordance with the laws of Malaysia.

16.2 Subject to Clause 15, the parties submit to the exclusive jurisdiction of the courts of Malaysia sitting in Kuala Lumpur.

17. Notices

In short. Write to hello@wisdomhub.com.my; we write to the email address on your account.

17.1 Notices to us must be sent to hello@wisdomhub.com.my and to our registered office.

17.2 Notices to you may be sent to the email address on your account, and are deemed received twenty-four (24) hours after sending, provided no delivery failure notification is received.

17.3 Designated electronic addresses. For the purposes of sections 20, 21 and 24 of the Electronic Commerce Act 2006, the email address on your account and your in-Platform inbox are your designated information processing systems, and hello@wisdomhub.com.my is ours. An electronic message is sent when it leaves the sender’s system and received when it enters the designated system; a message to us that arrives outside 9 am to 6 pm on a working day in Kuala Lumpur is treated as received at 9 am on the next working day. Neither party needs to acknowledge receipt for a message to take effect, and a booking, proposal, or acceptance recorded in-Platform takes effect when it is recorded.

18. General

In short. The housekeeping: what forms the whole agreement, which clauses survive closure, language, stamping, and the acceptance record we keep.

18.1 Entire Agreement. These Terms, the Privacy Policy, the Data Processing Addendum (if applicable), your applicable User-type agreement, and, where you use Programme Builder, the Programme Builder terms constitute the entire agreement between us and supersede all prior discussions, representations, and agreements.

18.2 Severability. If any provision is held unenforceable, the remaining provisions continue in full force.

18.3 No Waiver. Failure to enforce any right does not constitute a waiver.

18.4 No Partnership. Nothing creates a partnership, joint venture, agency, or employment relationship between any User and the Platform.

18.5 Assignment. You may not assign your rights or obligations without our written consent. We may assign in connection with a corporate reorganisation or sale of business on notice to you.

18.6 Survival. Clauses 2 (Platform Role), 7 (Administrative Fee), 8 (IP), 10 (Liability), 11 (Indemnity), 12 (Privacy), 15 (Dispute Resolution), 16 (Governing Law), 18 (General), 19 (Records), 20 (Release), and 21 (Definitions) survive termination.

18.7 Language. These Terms are written in English. A Bahasa Malaysia translation is available at [/terms/bm] and may be used as the operative version where execution by a government body, GLC, or statutory body requires Bahasa Malaysia under the National Language Acts 1963/67. In the absence of an executed Bahasa Malaysia version, the English version prevails.

18.8 Stamping. Where these Terms (or any executed schedule) constitute a chargeable instrument under the Stamp Act 1949, the User responsible for stamping must lodge for stamping within thirty (30) days of execution.

18.9 Acceptance evidence. Records of your acceptance of these Terms (including timestamp, IP address, device fingerprint, and user agent) are retained for the duration of your account plus seven (7) years, and are admissible as evidence under sections 90A–90C of the Evidence Act 1950.

19. Records of Compliance

In short. You keep the records that show an engagement happened as recorded, and you show them to us when a dispute, a regulator, or a fee check needs them.

19.1 In addition to the acceptance records we keep under Clause 18.9, you must keep your own records of each engagement originated through the Platform: the brief or proposal, the Booking confirmation, invoices and receipts, delivery confirmations, and, where the engagement is claimed through HRD Corp, the grant application and claim documents.

19.2 You must keep those records for seven (7) years from the end of the engagement, matching the financial-record retention in Privacy Policy Clause 10, and produce them to us within fourteen (14) days of a written request where we reasonably need them to investigate a dispute between Users, to respond to a regulator or court, or to check the Fee Base declared for an engagement.

19.3 Where we have reasonable grounds to believe that Clause 7.4 (Non-Circumvention) has been breached, you must also give us such records of your engagements with the Client concerned as are needed to establish whether an engagement was Platform-originated and what fee was paid. We will treat what you produce as confidential and use it only for that purpose.

20. Release

In short. If another User wrongs you, your claim is against that User. We may help, but you release us from the claim itself.

20.1 Because we are not a party to any engagement between Users (Clause 2.2), you agree that any claim you have arising out of an engagement, a Booking, a payment, or any other dealing with another User is a claim against that User, and you release us, our directors, employees, and agents from every claim, demand, and loss of any kind arising out of a dispute between you and another User, whether known or unknown at the time of release.

20.2 Nothing in this Clause 20 releases us from liability that Clause 10.1 says cannot be limited, or from our own obligations under this Agreement.

20.3 We may, at our discretion, help a User pursue a claim against another User, for example by providing records under Clause 19 or by suspending the other User’s account under Clause 5. Any help we give is voluntary, may stop at any time, and does not make us a party to the dispute or revive any released claim.

21. Definitions

In short. Capitalised words carry the meanings here, matched to the Trainer and Training Provider Agreement so the two documents read the same.

• “Administrative Fee” means the flat fee of five percent (5%) of the Fee Base payable by a Trainer or TP to the Platform under Clause 7. The Administrative Fee covers payment gateway and platform operations costs.
• “Agreement” or “Terms” means this Trainers Hub User Agreement (Clause 1.1).
• “Booking” means a confirmed engagement between a Trainer or TP and a Client for training services, originated through the Platform.
• “Client” means a Malaysian company seeking corporate training services, shown as “company” on the Platform (Clause 1.2(c)).
• “Confirmed” means the Client has formally accepted a Trainer’s or TP’s proposal or signed an engagement letter through the Platform.
• “Credits” means the metered units described in Clause 6.5B, held in the wallet on your Platform account.
• “Disbursed Amount” means the amount actually paid out by HRD Corp to the claiming Training Provider on an HRD Corp-claimed engagement, net of the HRD Corp levy deduction.
• “Dual Delivery Confirmation” means confirmation recorded in-Platform by both the paying party (Client or TP) and the Trainer that the training has been delivered. Payment through Platform checkout is gated on Dual Delivery Confirmation (Clause 7.3).
• “Fee Base” means: (i) on an HRD Corp-claimed engagement, the Disbursed Amount; (ii) where a TP engages a Trainer directly, the fee agreed between the TP and the Trainer; and (iii) on a non-HRD Corp direct engagement, the total fee paid by the Client, in each case including any SST charged within that amount and excluding reimbursable expenses (Clause 7.2).
• “Full Launch” means the point at which we announce that the marketplace is open for booking, as defined in the Pre-Launch Registration Terms Clause 1.2.
• “HRD Corp” means Pembangunan Sumber Manusia Berhad established under the Pembangunan Sumber Manusia Berhad Act 2001.
• “KYC procedure” means the Know-Your-Customer procedure described in Clause 3.2, as published from time to time.
• “Non-Circumvention Recovery” has the meaning given in Clause 7.5.
• “Platform” means WisdomHub, the online marketplace operated by Trainers Hub Sdn. Bhd., and, where the context is the contracting party, Trainers Hub Sdn. Bhd. itself.
• “Programme Builder” means the programme-outline drafting tool described in Clause 2.10.
• “Services” has the meaning given in Clause 1.1.
• “Trainer” means an individual freelance corporate trainer (Clause 1.2(a)).
• “Trainers Hub products” means WisdomHub, Programme Builder, and any further product we make available under this Agreement on notice to you.
• “Training Provider” or “TP” means a training provider incorporated as Sdn Bhd or registered as a Perkongsian Liabiliti Terhad / PLT (Clause 1.2(b)).
• “User” means any Trainer, Training Provider, Client, or other account holder described in Clause 1.2.

WisdomHub (“we”, “us”, “our”)
Operated by TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T))

Effective Date: [Date]
Last Updated: 12 September 2026 (usage records, visitor cookie, legal bases, deletion method, 2024 amendment commencement)

1. Introduction

1.1 This Privacy Policy explains how we collect, use, disclose, store, and protect your personal data when you use WisdomHub (the “Platform” or “Services”).

1.2 We comply with the Personal Data Protection Act 2010, as amended (including amendments commenced under the Personal Data Protection (Amendment) Act 2024) (together, the “PDPA”) and its subsidiary regulations. We process personal data in accordance with the seven PDPA Principles: General, Notice and Choice, Disclosure, Security, Retention, Data Integrity, and Access.

1.3 Where the Platform is required to register under section 14 of the PDPA as a Class of Data User (Services Class or such other class as may be prescribed), our registration number is [CDU-XXXXXXX] and we will display it on the website footer.

1.4 Where we rely on your consent, we ask for it in a form we can record: a checkbox that starts unticked, or a choice in the cookie banner. We keep the record of what you agreed to, the wording you saw, and when. Simply using the Platform is not treated as consent. Where we process your personal data on a basis other than consent, Clause 5 says which basis.

2. Who We Are and Data Protection Officer

We are the data controller for the personal data described in this Policy.

• Legal name: TRAINERS HUB SDN. BHD.
• Company No.: 202601033142 (1695237-T)
• Class of Data User registration: [Number, if applicable]
• Registered Address: [Address], Malaysia
• Email for data queries: privacy@wisdomhub.com.my

Data Protection Officer (“DPO”):

• Name: [DPO Name]
• Position: [DPO Title]
• Email: privacy@wisdomhub.com.my
• Telephone: [+60 X XXXX XXXX]

The DPO is responsible for monitoring our PDPA compliance, responding to data subject requests, liaising with the Personal Data Protection Commissioner, and overseeing data breach response. The DPO is registered with the Commissioner.

3. Personal Data We Collect

3.1 From all Users

• Full name, email address, mobile number. We do not use passwords: you sign in with a one-time code sent to your email address, and we record when each code was issued and used.
• Login activity, IP address, browser/device identifiers.
• Communications with us and with other Users via the Platform.

3.2 From Trainers (individuals)

• Accreditation documents: your HRD Corp accreditation certificate, your HRD Corp TTT or exemption certificate, and any other professional certificate you choose to upload (PDF). We read the certificate number from the document to check it against HRD Corp’s public register. Uploads are stored in Malaysia-hosted, encrypted private storage, are accessible only to Platform staff performing verification (access is logged), and are never displayed on your public profile.
• NRIC or passport number: we do not ask for a separate identity document. Your certificate carries your NRIC or passport number, and that is the only place we hold it. We do not copy it into our active systems, and it is never displayed. The certificate file is retained under Clause 10. We hold the number because verifying your accreditation is part of the contract you make with us (PDPA section 6(2)(a)) and because, as an online marketplace operator, we must keep a record of each supplier’s identity card or passport number for three years (section 6(2)(c); Regulation 8 of the Consumer Protection (Electronic Trade Transaction) Regulations 2024). Access to the file is limited to verification staff and is logged.
• Profile content you choose to add: profile photo, professional summary, areas of expertise, programmes, articles, testimonials, company logos, and video links.
• Your plan, credit balance and history, and the receipts we issue to you.
• Training history and ratings received (from Full Launch).
• Bank account details, tax identification number (“TIN”), and SST registration number (if applicable). Collected at Full Launch, when a payout, receipt, or e-Invoice first requires them, and used only for split payment through our payment gateway, receipts, and e-Invoicing.

3.3 From Training Providers (Sdn Bhd / PLT)

• Company name, registration number, SSM forms, business address.
• Authorised representative name, position, work email address, and mobile number.
• Directors’ / partners’ information for KYC purposes.
• HRD Corp TP registration number and current accreditation status.
• Bank account, SST registration, tax details.

3.4 From Clients (Corporate)

• Company name, registration number, business address.
• HR / HOD contact: name, work email, mobile, position.
• HRD Corp employer code (for verification only — we do not process levy claims).
• Training briefs and engagement details, which may include limited information about employees (e.g., attendance lists, role descriptions). The Client is the data controller of any such employee data and the Platform acts as a data processor for the limited purpose of facilitating the Booking. The terms of that processing are set out in the Data Processing Addendum auto-executed at Client onboarding.

3.5 Sensitive Personal Data

Where we collect health, religious belief, political opinion, or other sensitive personal data (e.g., a User requests training accommodation), we will obtain explicit consent in accordance with section 40 of the PDPA. Since 1 April 2025 sensitive personal data includes biometric data. We collect none.

3.6 Usage Records and the Visitor Cookie

Usage records. While you are signed in we keep a record of what you do on the Platform: the pages you open, the searches you run, the profiles, briefs and programmes you view, the actions you take (for example saving a trainer, sending a message, publishing a brief), and the time of each. Each record carries your account ID, your session, your IP address and your browser or device identifiers. We keep these records in a form that identifies you for twelve (12) months. After that we reduce them to counts and totals from which nobody can be identified, and delete the identifying copy (Clause 10).

We use usage records for three purposes, and Clause 5 gives the basis for each:
(a) to run the service you have signed up for: showing you what you have saved, viewed and sent, keeping your place, and answering your support requests;
(b) to keep the Platform secure and detect misuse; and
(c) to understand how the Platform is used so we can improve it.

Visitor cookie. If you accept analytics cookies in the cookie banner before you have an account, we set a first-party cookie with a random identifier. It lets us keep the pages you looked at before registering and, if you later register, join that browsing history to your account. If you decline, no visitor cookie is set and nothing you did before registering is linked to you. You can withdraw the choice at any time at the cookie banner; withdrawal stops further linking and we delete the browsing history held under that identifier. The cookie is described in the Cookies Policy.

4. Sources of Personal Data

We collect data:
(a) directly from you when you register, complete a profile, submit a brief, message another User, or contact us;
(b) automatically when you use the Platform (cookies, log files, analytics tools);
(c) from third parties such as HRD Corp (for accreditation verification, with your consent), SSM (publicly available registry information), payment gateways, sanctions/PEP screening services, and your nominated referees.

5. Purposes of Processing

We use personal data for the purposes set out in the table below. The basis on which we rely is also identified. The PDPA allows processing with your consent (section 6(1)(a)) or, without consent, where the processing is necessary for one of the grounds in section 6(2). The two grounds we rely on are section 6(2)(a) (necessary for the performance of a contract to which you are a party) and section 6(2)(c) (necessary for compliance with a legal obligation). The PDPA has no “legitimate interests” ground and we do not claim one.

Where a purpose relies on consent, we ask for it in a form we can record and keep the record (Regulation 3, Personal Data Protection Regulations 2013).

6. Direct Marketing

6.1 We will only send you direct marketing communications where you have given consent (typically via a tick-box at sign-up or in account preferences).

6.2 You may withdraw consent at any time by:
(a) clicking the “unsubscribe” link in any marketing email;
(b) switching it off in Account settings; or
(c) writing to privacy@wisdomhub.com.my.

6.3 We will action your opt-out within fourteen (14) days of receipt and confirm in writing in accordance with section 43 of the PDPA.

7. Disclosure to Third Parties

We disclose personal data only as set out below, and only to the extent necessary:

(a) Other Users on the Platform — to facilitate bookings (e.g., Client sees Trainer profile and contact upon confirmation; Trainer sees Client brief).
(b) Service Providers acting on our behalf: cloud hosting ([provider name] — Malaysia-hosted; our database and document storage are located in Malaysia), payment gateway (Billplz), email delivery provider, customer support tools, MyInvois integration partner, web analytics (Google Analytics 4, loaded through Google Tag Manager, with your consent under the Cookies Policy), web font delivery (Google Fonts, which receives your IP address and browser details when a page loads and sets no cookie), and, where introduced, sanctions/PEP screening providers (none in use at present).
(b1) AI service providers: where a Platform feature uses an external AI service (for example, programme description drafting), only your profile and area-of-expertise text is sent to that provider. Identity documents, certificates, NRIC/passport numbers, and SSM numbers are never sent to any AI service. The provider is named in our sub-processor list at [/legal/sub-processors].
(c) HRD Corp — for accreditation verification, where the User has authorised disclosure.
(d) Professional advisers (lawyers, auditors, accountants) under duties of confidentiality.
(e) Regulators, courts, or law enforcement when required by Malaysian law or legal process.
(f) Acquirers in connection with a merger, acquisition, or asset sale, subject to confidentiality undertakings.

We do not sell personal data to third parties.

A current list of material sub-processors is maintained at [/legal/sub-processors] and refreshed on change.

8. Cross-Border Transfers

8.1 Where we transfer personal data outside Malaysia (for example to Google, whose analytics and font services process your IP address outside Malaysia), we ensure the transfer complies with section 129 of the PDPA as amended on 1 April 2025, relying on one of the following:
(a) the place has in force a law substantially similar to the PDPA, or ensures a level of protection at least equivalent to the PDPA (section 129(2)), which we assess and record in a Transfer Impact Assessment for each non-Malaysian processor;
(b) your consent to the transfer (section 129(3)(a));
(c) the transfer is necessary for performance of a contract with you (section 129(3)(b)); or
(d) we have taken all reasonable precautions and exercised all due diligence to ensure the personal data will not be processed in that place in a way that would contravene the PDPA (section 129(3)(f)), including standard contractual clauses, recognised certifications (ISO 27001, SOC 2 Type II), or binding corporate rules.

8.2 You may request a copy of the safeguards in place for any specified transfer by writing to privacy@wisdomhub.com.my.

9. Security

9.1 We apply reasonable technical and organisational measures to protect personal data, including encryption in transit (TLS), encryption at rest for sensitive fields, role-based access controls, multi-factor authentication for staff with privileged access, audit logging, periodic penetration testing, vulnerability management, and annual staff PDPA training.

9.2 Data breach notification. A personal data breach is any breach, loss, misuse or unauthorised access of personal data (section 4 of the PDPA). If one occurs we will:
(a) notify the Personal Data Protection Commissioner as soon as practicable and within seventy-two (72) hours of the breach where it causes or is likely to cause significant harm, judged on the nature of the data and the likely effect on you (for example, identity or financial data, account credentials, or sensitive personal data), and in any case where more than one thousand (1,000) data subjects are affected;
(b) notify you without unnecessary delay and within seven (7) days of notifying the Commissioner where the breach causes or is likely to cause significant harm to you; and
(c) keep a register of every personal data breach, whether or not notified,
in accordance with section 12B of the PDPA (in force 1 June 2025) and the Commissioner’s Data Breach Notification Guideline (v1.0, 25 February 2025).

9.3 Our internal Incident Response Runbook governs detection, containment, eradication, recovery, notification, and post-incident review. Staff are trained annually on the runbook and tabletop exercises are conducted at least once per year.

10. Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law:

10.1 Disposal record. We keep a written retention schedule for every category above and a record of each disposal, and produce both to the Commissioner on request (Personal Data Protection Standard 2015, Retention Standard 6.1).

10.2 How we delete. When a retention period ends, when you close your account, or when you withdraw a consent that a record depended on, we do one of two things:
(a) delete the record; or
(b) where a record must survive for counts and totals, or because a financial record built on it must be kept, remove from it every field that identifies you or could be joined back to you: name, email address, mobile number, account ID, session ID, visitor cookie identifier, IP address and device identifiers. What remains cannot be linked to you by us or by anyone else, and we test that before we treat it as no longer personal data.
Financial records listed above are kept whole for their statutory period, with your identity in them, because the law requires it.

11. Your Rights as a Data Subject

Under the PDPA, you have the right to:

(a) Access — request a copy of personal data we hold about you (section 30);
(b) Correction — request correction of inaccurate or incomplete data (section 34);
(c) Withdraw consent — for any processing based on consent (section 38). We then stop that processing. Records we keep on the contract or legal-obligation bases in Clause 5 are not affected, but Clause 10.2 applies to your identity in them;
(d) Object to processing that is causing or is likely to cause you substantial and unwarranted damage or distress (section 42), except where the processing is necessary for the contract or a legal obligation;
(e) Limit processing for direct marketing (section 43);
(f) Data portability — ask us, by notice given by electronic means, to transmit your personal data directly to another data controller of your choice (section 43A, in force 1 June 2025). The right is subject to technical feasibility and compatibility of the data format; and
(g) Lodge a complaint with the Personal Data Protection Commissioner.

11.1 To exercise these rights, file the request from Account settings (each request is logged with the time you filed it) or contact privacy@wisdomhub.com.my. We will:
(a) acknowledge receipt within seven (7) days;
(b) respond substantively within twenty-one (21) days of receipt of a verified request, in accordance with sections 31 and 35 of the PDPA;
(c) where extension is necessary due to complexity, notify you with the reason and the extended timeline.

A reasonable fee may apply for access requests as permitted by the PDPA.

12. Cookies and Tracking

12.1 We set strictly necessary cookies (your session, security tokens, and the record of your cookie choice) without asking. We set analytics cookies (Google Analytics 4, loaded through Google Tag Manager, and our own visitor cookie described in Clause 3.6) only if you accept them in the cookie banner, and neither the tags nor the visitor cookie are loaded or set until you do. We set no marketing cookies at present. If we introduce any other category, the banner and the Cookies Policy are updated before it is enabled.

12.2 Detailed information is in our Cookies Policy, published on the Platform as the Cookies section of this Privacy Policy page ([/privacy#cookies]).

13. Children

13.1 The Platform is not directed at, and we do not knowingly collect personal data from, individuals under 18 years of age. If you believe we have inadvertently collected such data, contact us for prompt deletion.

14. Changes to This Policy

14.1 We may update this Policy from time to time. Material changes will be notified via email and/or in-app notice at least fourteen (14) days before taking effect. The “Last Updated” date and “Version” number will reflect the most recent revision. A versioned archive is maintained at [/privacy/archive].

15. Complaints and Contact

If you have a question or complaint about our handling of personal data:

• Email: privacy@wisdomhub.com.my
• Post: Data Protection Officer, [Address], Malaysia

If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commissioner of Malaysia:

Jabatan Perlindungan Data Peribadi (JPDP)
Aras 6, Kompleks Kementerian Komunikasi dan Multimedia
Lot 4G9, Persiaran Perdana, Presint 4
62100 Putrajaya, Malaysia
[www.pdp.gov.my]

16. Languages

16.1 This Policy is issued in Bahasa Malaysia and in English, as section 7(3) of the PDPA requires. The cookie banner and every consent checkbox are shown in both languages. [Bahasa Malaysia version pending.]

Cookies Policy

Effective 18 October 2026 (version 1.5 draft)

WisdomHub (“we”, “us”, “our”)
Operated by TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T))

Effective Date: [Date]
Last Updated: 12 September 2026 (visitor cookie, legal bases, usage records)

This Cookies Policy explains how we use cookies and similar tracking technologies on WisdomHub (the “Platform”). It supplements our Privacy Policy and is consistent with the Notice and Choice Principle of the Personal Data Protection Act 2010 (“PDPA”).

1. What Are Cookies?

Cookies are small text files placed on your device (computer, tablet, phone) when you visit a website. They allow the website to recognise your device and store information about your preferences or past actions.

We also use similar technologies such as local storage, session storage, web beacons, pixels, and software development kits (“SDKs”) in mobile applications. References to “cookies” in this Policy include these other technologies.

2. Categories of Cookies We Use

We classify cookies into four categories. At present we set the first category always, and the analytics category only with your consent. A cookie banner lets you accept or decline analytics cookies when you first visit, and your choice can be changed at the cookie banner. No functional or marketing cookies are set today.

2.1 Strictly Necessary Cookies (always on)

Essential for the Platform to function. Cannot be turned off because the Platform will not work without them.

Examples:

• Session and authentication tokens
• Load balancing
• Security (CSRF protection, fraud detection)
• Cookie consent state itself

Legal basis: For a signed-in User, necessary for the performance of the contract between you and us (PDPA section 6(2)(a)) and for the security we owe you under section 9 (section 6(2)(c)). For a visitor without an account, these cookies hold no information that identifies you: the session token and security token are random values, and the consent record holds only your banner choice.

2.2 Functional Cookies (consent required)

Enable enhanced functionality and personalisation, such as remembering your language preference, dashboard layout, or recently viewed Trainers/TPs.

If you decline, certain features may revert to default settings each visit.

2.3 Analytics Cookies (consent required)

Help us understand how Users interact with the Platform so we can improve it. Aggregate metrics include page views, feature usage, session duration, and error rates.

Two analytics cookies exist. Google Analytics 4 counts visitors. Our own visitor cookie holds a random identifier so that, if you accept, the pages you look at before registering can be joined to your account once you register. If you decline, the visitor cookie is not set and nothing you did before registering is linked to you. Withdrawing your choice at the cookie banner deletes the browsing history held under that identifier (Privacy Policy Clause 3.6 and 10).

Where possible we configure analytics tools with IP anonymisation and PII minimisation.

Legal basis: your consent, given by an accept in the cookie banner and recorded (PDPA section 6(1)(a); Regulation 3, Personal Data Protection Regulations 2013).

2.4 Marketing Cookies (consent required)

Used to deliver targeted advertising and measure ad effectiveness on third-party platforms (e.g., LinkedIn, Meta, Google).

If you decline, you will still see advertising, but it will be less personalised.

3. Specific Cookies We Set

Local browser storage. Your browser also keeps a local copy of a half-finished registration, profile, brief, or programme form so it is not lost if you close the tab. This is browser storage, not a cookie. It never leaves your device and is cleared when the form is submitted.

Usage records. Once you are signed in, what you do on the Platform is recorded on our servers against your account (Privacy Policy Clause 3.6). That is not a cookie and is not switched off by the banner; the banner controls only whether those records are also used for product analytics and whether pre-registration browsing is joined to them.

3A. Cookies we may introduce later (not set today)

None of the following is set at present. Each will be added to Section 3, and the banner in Clause 5.1 enabled, before it is used.

4. Third-Party Cookies

Google Fonts. Our pages load their typefaces from Google Fonts. That is not a cookie: Google receives your IP address and browser details when the font file is requested, and sets nothing on your device. It is listed as a service provider in the Privacy Policy.

Some cookies are set by third parties that provide services on our behalf or measure ad performance. These third parties are listed in the table above and in our Sub-Processor list at [/legal/sub-processors].

Each third-party cookie is subject to that third party’s own privacy and cookies notices. We do not control what third parties do with the data they collect through cookies set on the Platform, beyond the contractual safeguards described in the Data Processing Addendum and our Sub-Processor terms.

5. How to Manage Cookies

5.1 On the Platform

When you first visit, our cookie banner asks whether you accept analytics cookies. Strictly necessary cookies are set either way, because the Platform does not work without them. Your choice, the banner wording you saw, and the time are recorded. You can change your choice at any time at the cookie banner or by clearing the consent record via your browser. Declining after an earlier accept stops Google Analytics 4 and deletes the visitor cookie and the browsing history held under it.

5.2 In Your Browser

Most browsers let you block, delete, or restrict cookies through their settings. The exact steps vary by browser:

• Chrome: Settings → Privacy and security → Cookies and other site data
• Safari: Settings → Privacy
• Firefox: Settings → Privacy & Security
• Edge: Settings → Cookies and site permissions

Blocking strictly necessary cookies will prevent the Platform from working correctly.

5.3 Do Not Track

Most browsers offer a “Do Not Track” (“DNT”) signal. Industry standards on responding to DNT are still developing. We currently treat a “DNT: 1” signal as a request to disable analytics and marketing cookies, equivalent to declining those categories in the cookie banner.

6. Mobile Applications

We have no mobile application at present. If one is released, it may use SDKs and device identifiers (e.g., Advertising ID, Identifier for Vendors) for similar purposes. You can manage these through your device settings:

• iOS: Settings → Privacy & Security → Tracking
• Android: Settings → Google → Ads (reset advertising ID or opt out of personalisation)

7. Children

We do not knowingly use cookies to collect data from individuals under 18 years of age.

8. Updates to This Policy

We may update this Policy from time to time to reflect changes in the cookies we use or in legal requirements. The “Last Updated” date and “Version” number above will reflect the most recent revision. A versioned archive is maintained at [/cookies-policy/archive].

9. Contact

Questions about this Cookies Policy or our use of cookies should be directed to:

• Email: privacy@wisdomhub.com.my
• Post: Data Protection Officer, [Address], Malaysia

10. Languages

This Policy and the cookie banner are issued in Bahasa Malaysia and in English (PDPA section 7(3)). [Bahasa Malaysia version pending.]

This Agreement is between:

TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T)) (“Platform”, “we”, “us”)

and

the individual trainer, sole proprietor, or training provider entity (“you”, “Trainer”, or “TP”) that has registered on WisdomHub.

Effective Date: Date of account approval.
)

This Agreement is supplemental to the Trainers Hub User Agreement. In the event of conflict, this Agreement prevails for the subject matter covered.

1. Definitions

• “Administrative Fee” means the flat fee of five percent (5%) of the Fee Base payable by you to the Platform under Clause 5. The Administrative Fee covers payment gateway and platform operations costs.
• “Booking” means a confirmed engagement between you and a Client for training services, originated through the Platform.
• “Confirmed” means the Client has formally accepted your proposal or signed an engagement letter through the Platform.
• “Disbursed Amount” means the amount actually paid out by HRD Corp to the claiming Training Provider on an HRD Corp-claimed engagement, net of the HRD Corp levy deduction.
• “Dual Delivery Confirmation” means confirmation recorded in-Platform by both the paying party (Client or TP) and the Trainer that the training has been delivered. Payment through Platform checkout is gated on Dual Delivery Confirmation.
• “Fee Base” means: (i) on an HRD Corp-claimed engagement, the Disbursed Amount; (ii) where a TP engages a Trainer directly, the fee agreed between the TP and the Trainer; and (iii) on a non-HRD Corp direct engagement, the total fee paid by the Client — in each case including any SST charged within that amount and excluding reimbursable expenses.
• “HRD Corp” means Pembangunan Sumber Manusia Berhad established under the Pembangunan Sumber Manusia Berhad Act 2001.
• “Roster TP” means an HRD Corp-registered Training Provider admitted to the Platform’s roster that acts as the claim vehicle for a Trainer who is not (and has not nominated) a registered TP, under a separate Roster Agreement with the Platform.
• “Subscription Tier” means the plan you have selected, as published at [/pricing].
• “Umbrella TP” means an HRD Corp-accredited training provider that submits a course under its TP code on behalf of an individual non-accredited Trainer. A Roster TP is an Umbrella TP assigned through the Platform’s roster mechanism.

2. Independent Contractor Relationship

2.1 Nothing in this Agreement creates an employer-employee, agency, partnership, or joint venture relationship between the Platform and you. You are an independent contractor providing training services to your own Clients.

2.2 You acknowledge that:
(a) you set your own rates, working hours, and methodology;
(b) you bear your own business expenses and risks;
(c) the Platform does not provide you with equipment, leave, EPF, SOCSO, or EIS contributions, or any employment-style benefit;
(d) you are responsible for your own income tax, SST (where registered), and statutory contributions; and
(e) you may engage with other platforms or directly with clients, subject to Clause 7 (Non-Circumvention) of the User Agreement.

2.3 Your own employment and third-party obligations. You warrant, on registration and on each Booking you accept, that your registration on the Platform, your listing, and your delivery of training through the Platform do not breach any obligation you owe to a third party, including any:
(a) employment contract, contract for services, or secondment arrangement;
(b) exclusivity, non-compete, non-solicitation, or restraint clause;
(c) moonlighting, outside-employment, conflict-of-interest, or staff-handbook policy of an employer;
(d) professional body rule, practising certificate condition, or licence condition; or
(e) confidentiality or intellectual property obligation owed to an employer or former employer.

2.4 Where any such obligation requires the consent, permission, or waiver of your employer or principal, obtaining it is solely your responsibility. We do not ask you for it, do not verify it, do not hold it, and do not rely on it. You must not deliver training through the Platform during your employer’s working hours, using your employer’s premises, equipment, materials, or confidential information, unless you are permitted to do so.

2.5 We do not check your employment status. We do not enquire into, verify, or monitor whether you are employed, by whom, or on what terms. Your employment status, and any consequence of it, is a matter between you and your employer or principal. User Agreement Clause 2.7 (No Vetting of Users) applies.

2.6 You must notify us promptly at hello@wisdomhub.com.my if you become aware that your continued participation on the Platform breaches, or is alleged by a third party to breach, any obligation described in Clause 2.3. We may suspend your listing under Clause 14 while the position is resolved.

3. Eligibility and Accreditation Verification

3.1 Individual Trainers must:
(a) be at least 18 years of age and a Malaysian citizen or holder of a valid Malaysian work pass;
(b) provide a valid HRD Corp accreditation certificate and a valid HRD Corp TTT certificate or TTT exemption certificate where the Trainer wishes to hold verified status or deliver HRD Corp claimable courses; and
(c) accept that the NRIC or passport number printed on those certificates is the identity reference we rely on, subject to the Privacy Policy Clause 3.2. We do not require a separate identity document, a CV, or references.

3.2 Training Providers must:
(a) be incorporated as Sdn Bhd under the Companies Act 2016 or registered as a PLT under the LLP Act 2012 (or other recognised Malaysian legal form);
(b) provide SSM forms (Section 14/17 Superform, Form 9, Form 24/49, or current equivalents);
(c) provide HRD Corp TP registration certificate and current accreditation status (active);
(d) provide bank account in the registered name of the entity.

3.3 You authorise us to verify accreditation status with HRD Corp, SSM, and any other relevant body, including periodic re-verification (at least annually).

3.4 You must notify us within seven (7) days of any change in your accreditation, registration, shareholding, directorship, or insurance status.

3.5 We may refuse, suspend, or revoke listing if accreditation is invalid, expired, or subject to regulatory action.

4. Listing Terms

4.1 You may publish a profile and course listings via the Platform, subject to:
(a) accuracy and currency of information;
(b) compliance with our Content Guidelines (published separately);
(c) no infringement of third-party IP, defamation, or breach of Malaysian law.

4.2 You retain ownership of your profile content and course materials. You grant us a non-exclusive, royalty-free licence to display, host, and promote them through the Platform (see User Agreement Clause 8).

4.3 We may, at our discretion, edit profile content for formatting, language, or compliance, without altering substantive meaning.

4.4 You must not list:
(a) courses you are not qualified or accredited to deliver;
(b) courses with misleading HRD Corp claim eligibility statements;
(c) duplicate listings designed to inflate search visibility.

4.5 Where a listing is marked “HRDF claimable” or similar, you warrant that you (or your nominated Umbrella TP) hold valid HRD Corp accreditation covering the course and that the course meets the published criteria for the claim scheme indicated.

5. Subscription Tiers, Administrative Fee, and Credits

5.1 A free subscription tier is available. Paid Subscription Tiers unlock additional programme listing slots, monthly credit grants, and other features. Current tiers, features, and prices are published at [/pricing] and form part of this Agreement.

5.2 Administrative Fee. The Platform charges a flat Administrative Fee of five percent (5%) of the Fee Base on every engagement transacted through the Platform. The rate is the same for all Subscription Tiers and all engagement types. The Administrative Fee is not a commission on your professional fee: it is charged on the Fee Base defined in Clause 1 and covers payment gateway and platform operations costs.

5.3 Collection at source. The Administrative Fee is collected by payment gateway split (executed by our nominated gateway, at launch Billplz Sdn. Bhd.; the Platform does not itself accept, hold, or settle the funds) at the moment the relevant payment is made through Platform checkout: the gateway settles the Administrative Fee to the Platform and the balance to you (or, on roster engagements, applies the waterfall in Clause 5.4) simultaneously. Where you are your own claim vehicle and no Platform checkout split occurs, you must pay the Administrative Fee through Platform checkout. The Platform absorbs the payment gateway transaction charge on split payments; you will not be charged the gateway fee separately.

5.4 Roster engagement waterfall. On an engagement where a Roster TP acts as your claim vehicle, the Disbursed Amount is settled in one gateway split as follows: (i) the Administrative Fee (5% of the Disbursed Amount) to the Platform; (ii) the Roster TP’s service fee of fifteen percent (15%) of the Disbursed Amount; and (iii) the remainder (80% of the Disbursed Amount) to you. Both percentages are calculated on the Disbursed Amount itself; the Administrative Fee is borne by you and is not deducted before the Roster TP’s fee is calculated. Worked example on a Disbursed Amount of RM10,080: Platform RM504, Roster TP RM1,512, Trainer RM8,064.

5.5 Payment gate. Payment through Platform checkout is available only after Dual Delivery Confirmation. You must maintain valid payout bank details with the payment gateway; checkout is blocked, and no partial payment is possible, until valid payout details are registered.

5.6 The Administrative Fee is exclusive of SST. If we are SST-registered and required to charge SST on the Administrative Fee, the prevailing rate will be applied and shown on the receipt.

5.7 We may revise tier pricing and/or the Administrative Fee rate on sixty (60) days’ written notice. Engagements already Confirmed will be charged at the rate in force on the confirmation date.

5.8 Credits. Certain Platform actions (for example, responding to a Client brief) are metered in credits:
(a) monthly credit grants attached to your Subscription Tier reset each monthly cycle and do not roll over;
(b) purchased credit packs are valid for twelve (12) months from purchase and survive a tier downgrade until their own expiry;
(c) credits are consumed in the following order: current monthly grant first, then purchased or bonus lots by earliest expiry;
(d) credits have no cash value, are non-transferable, and are non-refundable except where required by Malaysian law;
(e) every credit movement is recorded in an auditable journal visible in your dashboard.

5.9 Promotional tier benefits. Any promotional access to a paid tier (for example, a launch benefit) is shown in your billing dashboard with its end date, is not a paid subscription, and does not auto-convert into a paid plan without a renewal payment request being issued and paid.

6. Booking Process and Confirmation Obligations

6.1 When a Client submits a brief, you may submit a proposal via the Platform within the time stated in the brief.

6.2 If the Client accepts, a Booking is Confirmed through in-Platform acceptance or via a signed engagement letter uploaded to the Platform.

6.3 Once Confirmed, you must:
(a) deliver the training in accordance with the agreed scope, schedule, and standards;
(b) issue all required documentation (training reports, attendance lists, certificates of completion) directly to the Client;
(c) where applicable, support the Client’s HRD Corp claim submission by providing required documents — noting that the HRD Corp claim itself is the Client’s responsibility (see Client Terms of Use Clause 5);
(d) not solicit the Client to engage off-platform during the non-circumvention period (User Agreement Clause 7.4).

6.4 You must update the Platform with the Booking status (scheduled, delivered, completed) within five (5) business days of each milestone.

6.5 Failure to deliver a Confirmed Booking without lawful excuse is a material breach and may attract suspension or removal from the Platform under Clause 14. Cancellation consequences are reputational (ratings, reliability record, and roster service-level strikes where applicable); the Platform does not impose or mediate monetary forfeiture on cancellation.

7. Rating System

7.1 After completion of each Booking, the Client may submit a rating and review of your services.

7.2 You agree to:
(a) accept the rating system as binding;
(b) not solicit, incentivise, or coerce favourable ratings;
(c) not retaliate against a Client for an unfavourable rating;
(d) refer rating disputes to the Platform’s in-house disputes process before any external complaint.

7.3 Passive hosting position. The Platform hosts ratings as user-generated content. We do not pre-moderate or curate ratings for editorial content. On a substantiated complaint that a rating is defamatory, breaches the Defamation Act 1957 or the Communications and Multimedia Act 1998, or is demonstrably false, we will assess and (where appropriate) remove the rating, in line with our published moderation policy. We rely on the safe-harbour position available to passive intermediaries under the Communications and Multimedia Act 1998.

7.4 You may post a single, factual right-of-reply alongside any rating, subject to the same legal standards in Clause 7.3.

7.5 Consistent low ratings or a verified complaint of serious misconduct (e.g., harassment, fraud, falsified credentials) may trigger review and suspension under Clause 13.

8. Claim Vehicle: Own TP, Nominated TP, and Roster TP

8.1 An HRD Corp-claimed engagement requires a registered Training Provider as the claim vehicle. Depending on your circumstances, the claim vehicle is:
(a) your own TP, where you hold (or your entity holds) current HRD Corp TP registration;
(b) a TP you nominate (“preferred TP”), verified by the Platform before first use; or
(c) a Roster TP assigned by the Platform, where you have neither (a) nor (b).

8.2 Roster assignment. Roster TPs are assigned in rotation. An assigned Roster TP has forty-eight (48) hours to accept. If no Roster TP accepts within that window, the engagement may be assigned to a Training Provider affiliated with the Platform’s founders as a last-resort claim vehicle. That affiliation is disclosed here and in the Roster Agreement and TP-facing documentation. The affiliated TP is bound by the Roster Agreement on the same terms as every other Roster TP, earns the same service fee under Clause 8.3(c) and no other payment, and takes no priority in rotation.

8.3 On a Roster TP engagement:
(a) the Roster TP handles HRD Corp claim administration and submission, and receives HRD Corp’s disbursement;
(b) the Roster TP must remit your share through Platform checkout within five (5) working days of receiving the HRD Corp disbursement or Dual Delivery Confirmation, whichever is later;
(c) the Roster TP’s service fee is fifteen percent (15%) of the Disbursed Amount (see Clause 5.4), collected automatically in the settlement waterfall — you do not pay the Roster TP separately;
(d) the Roster TP retains primary responsibility to HRD Corp for claim accuracy;
(e) Roster TPs are bound to the Platform by a separate Roster Agreement covering service levels, remittance obligations, and removal for non-payment. A Roster TP that fails the remittance clock is flagged overdue and persistent default results in removal from the roster;
(f) the arrangement is disclosed to the Client so the Client understands the HRD Corp claim flow.

8.4 The Platform facilitates assignment, settlement, and service-level enforcement but is not the claim vehicle and does not guarantee the Roster TP’s payment or the outcome of any HRD Corp claim. Your recourse for a Roster TP’s non-payment is against the Roster TP, supported by the Platform’s dispute process and roster enforcement under the Roster Agreement.

8.5 Where you use a nominated (preferred) TP under Clause 8.1(b), the commercial terms between you and that TP are your own affair, except that the TP’s share must be stated as a percentage of the Disbursed Amount: you state it when you invite the TP through the Platform, the TP confirms it when it accepts, and it is then fixed for that engagement unless both of you reconfirm a change through the Platform. The TP must settle your share through Platform checkout, and settlement follows Clause 5.4 with the nominated TP’s confirmed percentage in place of the Roster TP’s 15%: the Administrative Fee (5% of the Disbursed Amount) to the Platform, the nominated TP’s share of the Disbursed Amount to the TP, and the remainder to you. The Administrative Fee is borne by you on every path.

9. Receipts, e-Invoicing, Repayment, and Set-Off

9.1 The Administrative Fee is collected at source at the time of each transaction (Clause 5.3) and is computed on the Fee Base, which includes any SST charged within the agreed amount (Clause 1). A formal sales invoice and payment receipt stating the Fee Base, the Administrative Fee, and (where applicable) SST is issued automatically for every transaction, with no minimum size, regardless of the collection path, and is submitted for e-Invoicing validation through the Platform’s accounting intermediary where the LHDN framework applies. The recorded fee amount is identical whether collected by gateway split or paid through checkout.

9.2 LHDN e-Invoicing. Where the e-Invoicing mandate under the Income Tax Act 1967 applies to you or to the Platform, both parties will use the MyInvois system. You must provide:
(a) your TIN;
(b) your SSM or NRIC reference (as applicable);
(c) your SST registration number (if any); and
(d) any other field required by the LHDN e-Invoicing API specification.

9.3 Where the Administrative Fee is payable through checkout rather than collected by split (Clause 5.3), it is due within fourteen (14) days of Dual Delivery Confirmation. Late payment may attract interest at 1.5% per month on the outstanding amount, and unpaid fees older than thirty (30) days may result in account suspension.

9.4 Repayment obligation. Payments made through the Platform’s gateway split are settled instantly and are not reversible by the Platform. You must repay, within fourteen (14) days of written notice with supporting evidence, any amount you received through the Platform that:
(a) was paid to you in duplicate or in error;
(b) HRD Corp requires to be refunded, to the extent your share of the affected engagement is implicated; or
(c) the Platform’s dispute process determines you must refund to the paying party.

On a proven duplicate or erroneous payment, the Platform’s own refund responsibility is limited to returning its Administrative Fee share; the balance disbursed to you by gateway split is recoverable from you by the paying party directly, supported by this Clause 9.4 and the set-off in Clause 9.5.

9.5 Set-off. You authorise the Platform to instruct the deduction of any amount you owe under Clause 9.3 or 9.4 from subsequent payments settled to you through the Platform, and to suspend your account while such amounts remain unpaid past their due date. Set-off is applied against your future payouts before any separate demand is pursued.

9.6 Auto-generated invoice. On Dual Delivery Confirmation, the Platform generates an invoice to your paying party on your behalf from the fields of the confirmation record, which is the source of truth for the engagement. This is on by default. Where settlement runs through Platform checkout, the auto-generated invoice is mandatory: the checkout amount is locked to the invoiced amount and cannot be edited by the payer. On engagements settled outside Platform checkout, you may opt out in your dashboard if you prefer to issue invoices from your own accounting system. Where you are SST-registered (your profile records your SST registration number), the invoice states your service fee and SST by back-calculation inside the agreed total, so the agreed figure does not change; if you are not SST-registered you must not charge SST. The auto-generated document is a standard invoice only — it is not an LHDN e-Invoice and carries no e-Invoicing validation. Its issue date starts the payment clocks in this Agreement. You remain responsible for your own tax compliance in respect of your professional fee under the Service Tax Act 2018 (if SST-registered) and the Income Tax Act 1967, including issuing your own e-Invoice where the LHDN mandate applies to you.

10. Withholding Tax and Non-Resident Trainers

10.1 If you are a non-resident of Malaysia for income tax purposes, the Client (or other payer) may be required to withhold tax under section 109B of the Income Tax Act 1967 on payments to you for technical services performed in Malaysia (currently at 10%, subject to applicable double tax agreement reliefs).

10.2 You will provide a current Certificate of Tax Residence and bear any withholding tax liability that arises from your non-resident status. The Platform will not gross up payments to compensate for withholding tax unless expressly agreed in writing.

11. Conduct Standards and Insurance

11.1 You must:
(a) deliver training professionally, lawfully, and to the agreed standard;
(b) respect confidentiality of Client information (see Clause 12);
(c) treat the Client and learners with dignity and respect, free from harassment or discrimination;
(d) comply with workplace safety standards on the Client’s premises (Occupational Safety and Health Act 1994 and, in Sabah/Sarawak, applicable state labour ordinances);
(e) hold professional indemnity insurance with minimum coverage of MYR 250,000 per claim and MYR 500,000 aggregate during your time on the Platform, and provide evidence of cover on request.

11.2 You must not:
(a) make false claims about your accreditation, experience, or course outcomes;
(b) breach HRD Corp claim requirements through false attendance reporting, course content misrepresentation, or grant misuse;
(c) engage in conflict of interest without disclosure;
(d) bring the Platform into disrepute.

12. Confidentiality

12.1 Any non-public information you receive about a Client (employee data, business strategy, training needs analysis) is confidential. You may use it only to deliver the Booking and must not disclose it without consent except where required by law.

12.2 This obligation survives termination indefinitely.

13. IP in Course Content

13.1 You retain ownership of course materials you create.

13.2 Unless otherwise agreed in writing between you and the Client, you grant each Client a non-exclusive, perpetual, royalty-free licence to use the materials internally for the purposes for which they were delivered.

13.3 You warrant that all materials are your original work or are properly licensed, and that delivery does not infringe any third-party rights.

14. Suspension and Removal

14.1 We may suspend your listing or terminate this Agreement, with or without notice, if:
(a) accreditation lapses, is revoked, or cannot be verified;
(b) you breach this Agreement, the User Agreement, or applicable law (including PDPA, HRD Corp Act 2001, AMLATFPUAA);
(c) you fail to deliver a Confirmed Booking without lawful excuse;
(d) you breach the non-circumvention clause (User Agreement Clause 7.4);
(e) you receive consistent verified low ratings or serious complaints;
(f) you fail to pay the Administrative Fee, or any repayment due under Clause 9.4, when due;
(g) you provide false or misleading information;
(h) you engage in fraud, harassment, discrimination, or misconduct;
(i) we are required to do so by law, court order, or regulator.

14.2 On termination:
(a) all outstanding Administrative Fees and repayment amounts become immediately payable;
(b) you must complete or, where mutually agreed, transfer any Confirmed Bookings still in progress, subject to Client agreement;
(c) Clauses 5 (Administrative Fee for past Bookings), 9 (Receipts, Repayment, and Set-Off), 10 (Withholding), 11 (Conduct), 12 (Confidentiality), and 15 (Indemnity) survive termination.

15. Indemnity

15.1 You indemnify the Platform against all claims, losses, damages, fines, and reasonable legal costs arising out of:
(a) your delivery (or non-delivery) of training;
(b) any claim by a Client, learner, or HRD Corp arising out of your services or your accreditation status;
(c) any breach of this Agreement;
(d) any breach of PDPA, intellectual property rights, or other applicable law; and
(e) any claim brought by your employer, former employer, principal, or professional body arising out of your registration on, listing on, or delivery of training through the Platform, including any alleged breach of the obligations described in Clause 2.3.

15.2 Save for indemnity claims arising from fraud, wilful default, IP infringement, or breach of PDPA / confidentiality, your aggregate liability under this Clause 15 in any twelve (12) month period is capped at the greater of (a) MYR 100,000 or (b) the Gross Training Fees you earned through the Platform in the preceding twelve (12) months.

16. Limitation of Liability

16.1 Platform liability limits in the User Agreement Clause 10 apply to this Agreement.

17. General

17.1 Variation. We may amend this Agreement on thirty (30) days’ notice. Material changes affecting the Administrative Fee rate require sixty (60) days’ notice (Clause 5.7).

17.2 Assignment. You may not assign without our consent.

17.3 Governing law and dispute resolution. As per User Agreement Clauses 15 and 16, including the small-claims carve-out.

17.4 Entire agreement. This Agreement and the User Agreement constitute the entire agreement between us in respect of the subject matter.

These Client Terms of Use govern use of WisdomHub (the “Platform”) by Malaysian corporate Clients. The Platform shows a Client as a “company”; the two words mean the same party.

Operated by TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T)).

This document is supplemental to the Trainers Hub User Agreement. In the event of conflict, this document prevails for the subject matter covered.

Effective Date: [Date]

1. Who Can Register

1.1 The Platform is for use by Malaysian-registered companies (Sdn Bhd, PLT, sole proprietorship, partnership, or statutory body) seeking corporate training services.

1.2 The individual registering must:
(a) be at least 18 years of age;
(b) be a duly authorised representative of the Client (e.g., HR Manager, Head of Department, Director); and
(c) have authority to bind the Client to engagements with Trainers/TPs.

1.3 We may require verification, including:
(a) SSM documents (Section 14/17 Superform, Form 9, Form 24/49, or current equivalents);
(b) a signed Authorisation Letter from a director, partner, or company secretary confirming the registrant’s authority — required at first-time signup for the Client entity; and
(c) for higher-value engagements, cross-check against SSM director records and/or company secretarial confirmation.

1.4 The registrant warrants that they have authority to bind the Client. Where authority is later disputed, the registrant remains personally liable for engagements they confirmed on behalf of the purported Client.

2. Account Registration

2.1 You must provide accurate, current, and complete information, including company name, registration number, business address, and authorised user contact details.

2.2 You are responsible for all activity under your account. You must maintain credential confidentiality and notify us promptly of unauthorised access.

2.3 You may add additional authorised users (e.g., HR team members). Each authorised user is bound by these Terms and the User Agreement, and you remain primarily responsible for their actions.

3. Brief Submission

3.1 You may submit a training brief through the Platform setting out your training needs (topic, audience, dates, budget, location, special requirements).

3.2 You warrant that all information submitted is accurate and not misleading.

3.3 You authorise the Platform to share the brief with relevant Trainers/TPs, who may submit proposals.

3.4 You may withdraw a brief at any time before booking confirmation. You may be required to compensate Trainers/TPs for substantial work already undertaken at your express request (e.g., bespoke proposal development beyond a standard quote).

4. Booking Confirmation Obligations

4.1 A Booking is Confirmed when you:
(a) accept a proposal through the Platform; or
(b) sign and upload an engagement letter or purchase order.

4.2 A Confirmed Booking creates a legally binding contract between you and the Trainer/TP for the training services described.

4.3 You must:
(a) honour the Confirmed Booking, including provision of venue (where applicable), participant lists, pre-work coordination, and access;
(b) pay the agreed training fee in accordance with the engagement letter;
(c) participate in scheduled delivery dates or reschedule in good faith and with reasonable notice;
(d) provide post-training documentation reasonably required by the Trainer/TP for HRD Corp claims (e.g., signed attendance, evaluation forms).

4.4 The Platform is not a party to the Booking. Disputes about delivery, quality, or payment are between you and the Trainer/TP, although the Platform offers in-house dispute facilitation as a goodwill service.

5. HRDF Levy Responsibility

5.1 The HRD Corp (HRDF) levy is the Client’s own statutory obligation under the Pembangunan Sumber Manusia Berhad Act 2001. Eligible employers (currently those with ten (10) or more Malaysian employees, paying 1% of monthly wages, subject to current HRD Corp regulations) must register and pay the levy directly to HRD Corp.

5.2 The Platform does not collect, hold, disburse, or claim HRD Corp levy on your behalf. All grant applications, claims, and reimbursements are processed directly between you, the claiming Training Provider, and HRD Corp through the eTRiS portal, under the applicable claim scheme. Where the scheme provides for disbursement to the Training Provider, HRD Corp pays the Training Provider directly; the Platform receives no part of the claim.

5.3 Where a listing or marketing material on the Platform displays a designation such as “HRDF claimable”, “HRD Corp claimable”, or similar, that designation reflects the Trainer/TP’s self-declared and (where verifiable) Platform-checked accreditation status only. It is not a guarantee that HRD Corp will approve any specific claim, grant, or reimbursement.

5.4 You are solely responsible for:
(a) confirming your HRD Corp registration status and levy compliance;
(b) verifying — at the proposal stage — that the selected Trainer/TP and course are eligible for the claim scheme you intend to use (e.g., HRDCorp Claimable Course, SBL Khas);
(c) submitting accurate grant applications and claims to HRD Corp;
(d) compliance with HRD Corp post-training documentation requirements;
(e) any audit response or repayment obligation imposed by HRD Corp.

5.5 The Platform makes no representation that any particular Trainer/TP, course, or arrangement (including Umbrella TP arrangements) will be approved or reimbursed by HRD Corp. We will not be liable for any rejected, deferred, or clawed-back claim.

5A. Payment

5A.1 HRD Corp-claimed engagements. Where the engagement is claimed through HRD Corp, no payment is collected from you through the Platform. HRD Corp disburses the approved claim amount directly to the claiming Training Provider, and settlement to the Trainer occurs through Platform checkout between the TP and the Trainer. You pay no deposit on an HRD Corp-claimed engagement.

5A.2 Non-HRD Corp direct engagements (reseller arrangement). Where the engagement is not claimed through HRD Corp and you elect the Platform operator’s reseller arrangement, the Platform operator contracts with you as principal for delivery of the training through its engaged Trainer. On this path:
(a) a deposit of fifty percent (50%) of the agreed fee is payable to the Platform operator’s designated account to confirm the engagement, against a proforma invoice or quotation (not a tax invoice);
(b) the remaining fifty percent (50%) becomes due when delivery is confirmed by both you and the Trainer in-Platform, and is payable within fourteen (14) days of that confirmation;
(c) the Platform operator pays the Trainer as its own vendor after delivery; you have no payment obligation to the Trainer directly;
(d) late payment of the balance may attract interest at 1.5% per month on the outstanding amount, and suspension of further engagements until payment clears.

5A.3 Delivery confirmation. Settlement steps through the Platform are gated on confirmation of delivery by both parties to the engagement, recorded in-Platform. Confirmation by both parties is the point of no return: once dual confirmation is recorded, payments are final and no refund is given. Disputes raised after dual confirmation are handled through the Platform’s dispute process as administrative rulings and reputational consequences, not as payment reversals.

5A.4 Payment method. Engagement payments (deposits and balances) are payable by online bank transfer (FPX) through the Platform’s nominated gateway. Card payment is currently available for subscription billing only.

6. Cancellation

6.1 Cancellation terms are governed by the engagement letter between you and the Trainer/TP. In the absence of specific terms in that engagement letter, the following Platform default applies:

(a) cancellation fourteen (14) days or more before the confirmed training date (as recorded in the final confirmation record) carries no charge and no fault, and any deposit paid is refunded in full;
(b) cancellation less than fourteen (14) days before the confirmed training date attracts a cancellation retention of ten percent (10%) of the agreed fee, applied where a deposit has been paid by withholding it from the deposit refund. The retention is allocated five percent (5%) to the Platform (administration) and five percent (5%) to the Trainer (preparation compensation). The Platform records the cancelling party in every case, and the cancellation is reflected in that party’s reliability record and ratings. The Platform administrator may waive the retention and the reliability consequence in cases of genuine emergency. The 14-day line aligns with HRD Corp grant timelines, under which a date or trainer change inside 14 days forces a claim resubmission;
(c) other than the retention in Clauses 6.1(b) and 6.2 applied to deposits the Platform operator itself holds, the Platform does not collect, hold, or mediate cancellation deposits or penalties between you and a Trainer/TP. Any further compensation for work already performed at your express request (Clause 3.4) or for non-recoverable costs is a matter between you and the Trainer/TP under the engagement letter.

6.2 Reseller path deposits. Where you cancel a non-HRD Corp engagement under Clause 5A.2 after paying a deposit: cancellation fourteen (14) days or more before the confirmed training date entitles you to a full refund of the deposit; cancellation less than fourteen (14) days before the confirmed training date entitles you to the deposit less the 10% retention described in Clause 6.1(b).

6.2A Postponement instead of cancellation. Instead of cancelling, you may postpone the engagement. The Platform operator will hold the deposit for up to three (3) months and the engagement remains with the same Trainer; if the Trainer is no longer available at reactivation, the date is renegotiated. If the engagement is not reactivated within three months, it is treated as cancelled and the refund position in Clause 6.2 applies as at the date of postponement.

6.3 Cancellations due to force majeure (acts of God, government order, declared public health emergency) are treated as no-fault, subject to any compensation for non-recoverable costs already incurred being agreed between you and the Trainer/TP.

6.4 Rescheduling (as opposed to cancellation), with the mutual agreement of the Trainer/TP, does not count as a cancellation for the purposes of Clause 6.1(b).

7. Rating Submission Requirements

7.1 Within fourteen (14) days of training completion, you must submit a rating and review of the Trainer/TP via the Platform.

7.2 The rating must be:
(a) honest and based on actual experience;
(b) free of personal attacks, discriminatory language, or matters unrelated to the training delivered;
(c) compliant with the Defamation Act 1957 and the Communications and Multimedia Act 1998.

7.3 The Platform may publish your rating, typically with your company name (not individual reviewer name). By submitting a rating, you grant us a perpetual licence to display, aggregate, and use it for Platform improvement and marketing.

7.4 Moderation. The Platform hosts ratings as user-generated content under a passive intermediary model. On a substantiated complaint that a rating is defamatory or otherwise unlawful, we will assess and (where appropriate) remove the rating in line with our published moderation policy. The reviewed Trainer/TP has a right of reply (see Trainer and Training Provider Agreement Clause 7.4).

7.5 Failure to submit ratings on multiple Bookings may affect your account standing and access to certain Platform features.

8. Confidentiality of Trainer Information

8.1 Information you receive about Trainers/TPs (rates, methodologies, profile information not visible publicly) is confidential. You may use it only to evaluate and engage Trainers/TPs via the Platform.

8.2 You must not, for a period of six (6) months from first introduction of a particular Trainer/TP via the Platform:
(a) engage that specific Trainer/TP directly outside the Platform; or
(b) share that Trainer/TP’s contact details with third parties without consent.

8.3 You must not at any time:
(a) use Platform data to build a competing service;
(b) scrape, harvest, or systematically extract Trainer/TP information from the Platform.

8.4 Breach of Clause 8.2 entitles the Platform to recover damages equivalent to the Administrative Fee that would have been payable on the off-platform engagement (as a reasonable pre-estimate of loss), plus reasonable enforcement costs.

9. Personal Data and Data Processing Addendum

9.1 When you upload employee or participant data (e.g., attendance lists), you act as the data controller under the PDPA 2010 and confirm that you have obtained the necessary notices and consents from those individuals.

9.2 You authorise the Platform to process such data solely to facilitate the Booking. The Platform acts as a data processor for this limited purpose.

9.3 The terms of that processing are set out in the Data Processing Addendum (the “DPA”), which is auto-executed on your behalf at first-time signup and is available at [/legal/dpa]. The DPA addresses controller instructions, sub-processors, security measures, breach notification, audit rights, and return/deletion on termination.

10. Acceptable Use

10.1 You agree not to:
(a) submit fictitious briefs (e.g., for competitive intelligence purposes);
(b) post offensive, discriminatory, or unlawful content;
(c) use the Platform to procure services that breach Malaysian law;
(d) engage in collusive practices to manipulate Trainer pricing or ratings.

11. Subscription / Access Fees

11.1 Subscription fees, if any, are payable in accordance with the pricing published at [/pricing-clients]. Billing is monthly or annual in advance, exclusive of SST. Where access is free of charge, this Clause 11 does not apply.

[BUSINESS DECISION NEEDED: Confirm whether the Client side is free, freemium, or paid, and finalise pricing page before launch.]

12. Limitation of Liability

12.1 To the maximum extent permitted by Malaysian law:

(a) the Platform’s total aggregate liability to you in any twelve (12) month period is limited to the greater of (i) MYR 50,000 or (ii) the subscription/access fees paid by you to us in the preceding twelve (12) months;

(b) we are not liable for any indirect, consequential, special, or punitive loss, including loss of business, profit, opportunity, anticipated savings, or data;

(c) we are not liable for the act, omission, default, or insolvency of any Trainer/TP, nor for the quality, suitability, accuracy, or outcome of any training delivered;

(d) we are not liable for HRD Corp claim rejection, audit findings, repayment demands, or any tax or regulatory consequence;

(e) we are not liable for delays or failures caused by force majeure or any third-party service we rely on (e.g., cloud hosting, payment gateways).

12.2 Nothing in this clause excludes liability for death or personal injury caused by our negligence, fraud, or any liability that cannot be excluded by Malaysian law.

12.3 B2B acknowledgement. You acknowledge that you are a commercial entity with the opportunity to take independent advice, and that the limitations in this Clause 12 are reasonable in the context of the fees payable (or absence of fees) for access to the Services. Nothing in this Clause limits any non-excludable statutory right that may apply where the Client is, by virtue of its legal form, a “consumer” under the Consumer Protection Act 1999.

13. Account Suspension and Termination

13.1 We may suspend or terminate your account for breach, non-payment, regulatory requirement, or any reason set out in the User Agreement Clause 5.

13.2 You may terminate by written notice, subject to honouring any Confirmed Bookings and outstanding obligations.

14. Dispute Resolution and Governing Law

14.1 Disputes between you and the Platform are subject to good-faith negotiation, AIAC mediation, and AIAC arbitration in Kuala Lumpur, as set out in the User Agreement, including the small-claims carve-out (User Agreement Clause 15.4) permitting Sessions Court or Magistrates’ Court proceedings for monetary claims under MYR 100,000.

14.2 Disputes between you and a Trainer/TP are matters between those parties, although the Platform’s in-house disputes process is available as a goodwill service.

14.3 These Terms are governed by the laws of Malaysia. Subject to the arbitration clause, the courts of Malaysia have exclusive jurisdiction.

15. General

15.1 Modifications. We may amend these Terms on fourteen (14) days’ notice. Material changes that adversely affect your rights or expand your obligations require re-acceptance.

15.2 Versioning. A versioned archive of these Terms is maintained at [/client-terms/archive].

15.3 Entire agreement; severability; no waiver; survival. As per User Agreement Clauses 18.1–18.6.

15.4 Notices. Send notices to hello@wisdomhub.com.my. We will use the email address on your account.

This Data Processing Addendum (the “DPA”) forms part of the Client Terms of Use and the Trainers Hub User Agreement between:

TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T)) of [Registered Address], Malaysia (“Platform”, “Processor”, “we”), and

the Malaysian-registered corporate Client (“Client”, “Controller”, “you”) that has registered on WisdomHub.

Effective Date: Date of Client account approval.

This DPA is auto-executed on your behalf at first-time signup and is binding on the Client and the Platform from the Effective Date. In the event of conflict between this DPA and any other agreement between us, this DPA prevails for matters relating to the processing of Personal Data.

1. Definitions

Capitalised terms not defined here have the meaning given in the Trainers Hub User Agreement or Client Terms of Use.

• “PDPA” means the Personal Data Protection Act 2010, as amended (including amendments commenced under the Personal Data Protection (Amendment) Act 2024), together with its subsidiary regulations and orders.
• “Personal Data” has the meaning given in section 4 of the PDPA — information that relates directly or indirectly to a data subject who is identified or identifiable.
• “Sensitive Personal Data” has the meaning given in section 4 of the PDPA — personal data on physical or mental health, political opinions, religious beliefs, commission or alleged commission of an offence, or any other class prescribed by the Minister.
• “Data Subject” means an individual whose Personal Data is processed under this DPA — primarily the Client’s employees, contractors, or training participants.
• “Controller” means the person who controls the processing of Personal Data (the Client).
• “Processor” means the person who processes Personal Data on behalf of and under the instructions of the Controller (the Platform).
• “Sub-Processor” means any third party engaged by the Platform to process Personal Data on its behalf for the purposes of this DPA.
• “Personal Data Breach” means any breach of personal data, loss of personal data, misuse of personal data or unauthorised access of personal data (section 4 of the PDPA, as amended), and includes accidental or unlawful destruction, alteration or disclosure.
• “Processing” has the meaning given in the PDPA and includes collection, recording, holding, storage, use, disclosure, and erasure of Personal Data.
• “JPDP” means Jabatan Perlindungan Data Peribadi (the Personal Data Protection Commissioner of Malaysia).
• “Services” means the Platform’s marketplace, dashboard, communications, and related services made available to the Client.

2. Background and Scope

2.1 The Client uses the Platform to source and engage Trainers and Training Providers (“Trainers/TPs”) for corporate training. In doing so, the Client may upload or transmit Personal Data of its employees, contractors, and training participants (e.g., participant lists, attendance records, training needs analyses, post-training feedback).

2.2 In relation to such Personal Data:
(a) the Client is the Controller;
(b) the Platform is a Processor; and
(c) any Trainer/TP that receives the Personal Data from the Client (with the Platform’s facilitation) is a separate Controller in respect of training delivery, not a Sub-Processor of the Platform.

2.3 In relation to data about the Client’s authorised users and account-holders themselves (e.g., HR Manager profile, login records), the Platform acts as Controller. That processing is governed by the Privacy Policy and not by this DPA.

3. Subject Matter, Duration, Nature, and Purpose of Processing

Set out in Annex 1 (Processing Details) below and incorporated by reference.

4. Categories of Data Subjects and Personal Data

Set out in Annex 1 (Processing Details) below.

5. Controller (Client) Obligations

5.1 The Client warrants and undertakes that, in respect of any Personal Data made available to the Platform:
(a) the Client has a lawful basis under the PDPA for the processing (including any required consents under sections 6 and 40);
(b) the Client has issued all required notices under section 7 of the PDPA (Notice and Choice Principle) to the relevant Data Subjects, in both English and Bahasa Malaysia where applicable;
(c) the Personal Data is accurate, up-to-date, and not excessive for the purpose;
(d) the Client will not upload Sensitive Personal Data without first obtaining explicit consent from each Data Subject under section 40 of the PDPA and notifying the Platform in writing;
(e) the Client will provide documented instructions to the Platform sufficient to enable the Platform to process the Personal Data lawfully;
(f) the Client will not instruct the Platform to process Personal Data in breach of the PDPA or any other applicable law.

5.2 The Client retains responsibility for responding to Data Subject requests received by it directly. The Platform will assist in accordance with Clause 9.

6. Processor (Platform) Obligations

6.1 The Platform will:
(a) Process only on documented instructions. Process Personal Data only on the documented instructions of the Client, including with regard to transfers outside Malaysia. The Client’s instructions are reflected in the Client Terms of Use, this DPA, and any in-product workflows initiated by the Client.
(b) Legal exception. Where the Platform is required by Malaysian law to process Personal Data otherwise than on the Client’s instructions, the Platform will (where not prohibited by law) notify the Client of the legal requirement before processing.
(c) Confidentiality. Ensure that all personnel authorised to process Personal Data are subject to a written confidentiality obligation that survives termination of employment or engagement.
(d) Security. Implement and maintain the technical and organisational measures set out in Annex 2 (the “Security Measures”).
(e) Assistance. Assist the Client to comply with the Client’s obligations under the PDPA (including responding to Data Subject requests, conducting data protection impact assessments where applicable, and notifying Personal Data Breaches), taking into account the nature of the processing and the information available to the Platform.
(f) Sub-processors. Engage Sub-Processors only in accordance with Clause 7.
(g) Records. Maintain records of categories of processing activities carried out on behalf of the Client in a form sufficient to demonstrate compliance with the PDPA.
(h) Cooperation. Make available to the Client all information reasonably necessary to demonstrate compliance with this DPA, and cooperate with reasonable audits and inspections under Clause 13.
(i) Return or deletion. On termination, return or delete Personal Data in accordance with Clause 12.

6.2 The Platform will appoint and maintain a Data Protection Officer (“DPO”) as section 12A of the PDPA requires of a data processor, registered with the Personal Data Protection Commissioner, with contact details published in the Privacy Policy. The DPO is the primary point of contact for Client queries on this DPA. The Platform complies directly with the Security Principle in section 9 of the PDPA in respect of the Personal Data, as section 5(1A) requires of a data processor.

7. Sub-Processors

7.1 The Client provides general authorisation for the Platform to engage Sub-Processors to process Personal Data, subject to this Clause 7.

7.2 A current list of approved Sub-Processors is set out in Annex 3 and maintained at [/legal/sub-processors].

7.3 The Platform will:
(a) impose written data protection obligations on each Sub-Processor that are no less protective than those set out in this DPA;
(b) remain fully liable to the Client for the acts and omissions of each Sub-Processor; and
(c) give the Client at least thirty (30) days’ written notice (by email and in-product notification) of any intended addition or replacement of a Sub-Processor.

7.4 The Client may object to the use of a new Sub-Processor on reasonable data protection grounds by written notice within fourteen (14) days of the Platform’s notification. The parties will discuss the objection in good faith. If the objection cannot be resolved within thirty (30) days, the Client may terminate this DPA and the affected Services, without penalty, on written notice. Pre-paid fees for unused subscription periods will be refunded on a pro-rata basis.

7.5 In an emergency (e.g., to maintain continuity of a critical service), the Platform may engage a substitute Sub-Processor without prior notice provided that it notifies the Client as soon as practicable and the substitute is bound by equivalent obligations.

8. Security Measures

8.1 The Platform will implement and maintain the Security Measures set out in Annex 2, which take into account the state of the art, cost of implementation, and the nature, scope, context, and purposes of processing, as well as the risk to Data Subjects.

8.2 The Platform may update the Security Measures from time to time, provided that the level of security is not materially reduced. The Annex will be updated and made available to the Client on the Platform’s legal information page.

9. Data Subject Rights Assistance

9.1 The Platform will assist the Client, by appropriate technical and organisational measures, in fulfilling the Client’s obligations to respond to requests by Data Subjects exercising their rights under the PDPA, including:
(a) right of access (section 30);
(b) right to correct (section 34);
(c) right to withdraw consent (section 38);
(d) right to prevent processing for direct marketing (section 43);
(e) right to data portability (section 43A, in force 1 June 2025): a request made by electronic means, subject to technical feasibility and compatibility of the data format.

9.2 Where a Data Subject submits a request directly to the Platform that relates to Personal Data processed on behalf of the Client, the Platform will:
(a) acknowledge receipt to the Data Subject within seven (7) days;
(b) inform the Data Subject that the Client is the relevant Controller and provide the Client’s contact details (where authorised) or redirect the request;
(c) notify the Client of the request without undue delay and within five (5) business days; and
(d) provide reasonable assistance to enable the Client to respond within the PDPA timelines.

9.3 The Client is responsible for the substantive response to Data Subject requests relating to Personal Data for which it is the Controller.

10. Personal Data Breach Notification

10.1 The Platform will notify the Client of a Personal Data Breach affecting Personal Data processed under this DPA without undue delay and in any event within forty-eight (48) hours of becoming aware of the Breach.

10.2 The notification will, to the extent then known:
(a) describe the nature of the Breach, including the categories and approximate number of Data Subjects and records concerned;
(b) provide the DPO’s contact details;
(c) describe the likely consequences; and
(d) describe the measures taken or proposed to address the Breach and mitigate its effects.

10.3 The Platform will provide further information in updates as it becomes available and will reasonably assist the Client to:
(a) notify the Personal Data Protection Commissioner as soon as practicable and within seventy-two (72) hours of the Breach where it causes or is likely to cause significant harm (section 12B of the PDPA; Data Breach Notification Guideline v1.0, 25 February 2025, paragraphs 5 and 6), significant harm being judged on the nature of the data and the likely effect on the Data Subjects (for example, identity or financial data, account credentials, or sensitive personal data), and in any case where more than one thousand (1,000) Data Subjects are affected; and
(b) notify affected Data Subjects without unnecessary delay and within seven (7) days of the notification to the Commissioner where required (Guideline paragraph 9.1).

10.4 The Platform’s notification under this Clause 10 does not constitute an admission of fault or liability.

10.5 Both parties will document each Personal Data Breach affecting the Personal Data, whether or not notified, in a breach register recording the facts, effects, and remedial action (Guideline paragraph 14.1).

11. Cross-Border Transfers

11.1 Where the Platform transfers Personal Data outside Malaysia in the course of providing the Services (e.g., to cloud hosting Sub-Processors), it will ensure compliance with section 129 of the PDPA, relying on one of the following:
(a) the Client’s consent (deemed given through acceptance of this DPA, the Client Terms of Use, and the Privacy Policy);
(b) the transfer is necessary for performance of the contract between the Client and the Platform, or for the Client’s instructions;
(c) the place has in force a law substantially similar to the PDPA, or ensures a level of protection at least equivalent to the PDPA (section 129(2) as amended), as recorded in the Platform’s Transfer Impact Assessment (“TIA”); or
(d) the Platform has taken all reasonable precautions and exercised all due diligence to ensure the Personal Data will not be processed in that place in a way that would contravene the PDPA (section 129(3)(f)), including standard contractual clauses, recognised certifications (ISO 27001, SOC 2 Type II), or binding corporate rules.

11.2 The Platform will provide a copy of the TIA on reasonable request.

12. Return or Deletion of Personal Data

12.1 On termination or expiry of the Client’s account, or at any time on the Client’s written request, the Platform will (at the Client’s election):
(a) return all Personal Data in a structured, commonly used, machine-readable format; or
(b) securely delete all Personal Data, including from backups (in accordance with the Platform’s backup rotation schedule, typically within ninety (90) days).

12.2 The Platform may retain Personal Data only to the extent required by Malaysian law (e.g., Income Tax Act 1967 record-keeping, Companies Act 2016, e-Invoice records), and only for the duration of that legal requirement. Such retained data remains subject to the Security Measures and confidentiality obligations of this DPA.

12.3 On reasonable request, the Platform will certify in writing the completion of return and/or deletion.

13. Audit Rights

13.1 The Platform will make available to the Client all information reasonably necessary to demonstrate compliance with this DPA, including by providing:
(a) the Platform’s most recent independent third-party audit reports (e.g., SOC 2 Type II, ISO 27001 certification, where held);
(b) responses to standard security questionnaires; and
(c) summaries of the Security Measures and Sub-Processor due diligence.

13.2 Where the information made available under Clause 13.1 is, in the Client’s reasonable opinion, insufficient to demonstrate compliance, the Client may, once per twelve (12) month period and on at least thirty (30) days’ prior written notice, conduct an audit or inspection of the Platform’s processing activities relevant to this DPA, subject to:
(a) audits conducted during normal business hours and in a manner that minimises disruption;
(b) reasonable confidentiality undertakings;
(c) no access to other Clients’ data, source code, or commercially sensitive information unrelated to this DPA; and
(d) the Client bearing its own costs and the Platform’s reasonable costs of the audit (unless the audit reveals material non-compliance, in which case the Platform bears its own costs).

13.3 More frequent audits may be conducted following a Personal Data Breach or where required by a regulatory authority.

14. Liability and Indemnity

14.1 The aggregate liability of each party under this DPA is subject to the liability caps and exclusions in the Trainers Hub User Agreement Clause 10 and the Client Terms of Use Clause 12, except that:
(a) nothing in this Clause 14 limits liability for fraud, wilful default, or any liability that cannot be excluded by Malaysian law; and
(b) the parties acknowledge that a breach of this DPA may give rise to regulatory liability under the PDPA that is personal to the party in breach and is not limited by the contractual caps.

14.2 Each party will indemnify the other against fines, regulatory penalties, and reasonable legal costs lawfully imposed on the indemnified party by JPDP or a court of competent jurisdiction, to the extent caused by the indemnifying party’s breach of this DPA.

15. Term and Termination

15.1 This DPA commences on the Effective Date and continues until the earlier of:
(a) termination of the Client’s account; or
(b) the parties’ agreement to terminate this DPA.

15.2 The provisions of Clauses 6.1(g) (records), 10 (breach notification), 12 (return / deletion), 13 (audit), and 14 (liability) survive termination.

16. General

16.1 Governing law and dispute resolution. This DPA is governed by the laws of Malaysia. Disputes are resolved in accordance with the Trainers Hub User Agreement Clauses 15 and 16 (including the small-claims carve-out).

16.2 Variation. The Platform may amend this DPA on thirty (30) days’ written notice. Material changes that adversely affect the Client’s rights or expand the Client’s obligations require re-acceptance.

16.3 Severability. If any provision is held unenforceable, the remaining provisions continue in full force.

16.4 Order of precedence. In the event of conflict: (a) this DPA prevails over the Client Terms of Use and Trainers Hub User Agreement in respect of Personal Data processing; (b) the Annexes form part of this DPA; (c) Annex 1 (Processing Details) prevails over the body of the DPA in respect of factual scope details.

ANNEX 1 — PROCESSING DETAILS

1. Subject Matter

The processing of Personal Data of the Client’s employees, contractors, and training participants by the Platform, for the purpose of facilitating corporate training engagements brokered through the Platform.

2. Duration

For the duration of the Client’s account, plus any retention period required by Malaysian law (see Clause 12).

3. Nature and Purpose of Processing

• Storing participant lists and attendance records uploaded by the Client.
• Relaying training briefs and participant information to selected Trainers/TPs.
• Hosting messaging between the Client and Trainers/TPs.
• Generating reports, certificates, and post-training documentation flow.
• Supporting HRD Corp claim documentation flow (Platform does not submit claims).
• Storing post-training feedback collected from participants on behalf of the Client.

4. Type of Personal Data

• Identification data: full name, employee ID, work email, work mobile.
• Employment data: job title, department, role.
• Training participation data: courses attended, attendance, scores, completion status, feedback responses.
• Communication data: messages and attachments exchanged via the Platform.

The Client must not upload Sensitive Personal Data without first notifying the Platform in writing and obtaining explicit consent from each Data Subject.

5. Categories of Data Subjects

• Employees of the Client.
• Contractors and freelancers engaged by the Client.
• Training participants invited by the Client (whether employees or third parties).

6. Frequency of Processing

Continuous, for the duration of the Client’s account.

7. Retention Period

In accordance with Clause 12 of this DPA and the retention table in the Privacy Policy.

ANNEX 2 — TECHNICAL AND ORGANISATIONAL SECURITY MEASURES

The Platform implements and maintains the following measures, which may be updated provided that the level of security is not materially reduced.

1. Access Control

• Role-based access control with principle of least privilege.
• Multi-factor authentication required for all staff and administrative access.
• Strong password policy and credential management.
• Quarterly review of user access rights.
• Immediate revocation of access on staff exit.

2. Encryption

• TLS 1.2 or higher for all data in transit between Client, Platform, and Sub-Processors.
• AES-256 (or equivalent) for Personal Data at rest in production databases.
• Encrypted vault for NRIC images and other sensitive identity documents, with access logged.

3. Network and Application Security

• Firewall and intrusion detection at network perimeter.
• Web application firewall (WAF) in front of public endpoints.
• Regular vulnerability scanning and patching.
• Annual third-party penetration testing.
• Secure software development lifecycle including code review and dependency scanning.

4. Logical Segregation

• Logical separation of Client data within multi-tenant infrastructure.
• Separation of production, staging, and development environments.
• Production data not used in non-production environments without anonymisation.

5. Operational Security

• Documented change management process.
• Backup and disaster recovery procedures with periodic restore testing.
• Centralised logging with retention of at least twelve (12) months.
• 24/7 security monitoring (SIEM).

6. Personnel Security

• Background verification on hire for staff with privileged access.
• Mandatory PDPA and information security training on hire and at least annually thereafter.
• Written confidentiality undertakings from all personnel.

7. Incident Response

• Documented Incident Response Runbook covering detection, containment, eradication, recovery, notification, and post-incident review.
• 24/7 on-call rotation for security incidents.
• Tabletop exercises at least annually.

8. Supplier Management

• Documented Sub-Processor due diligence process before engagement.
• Periodic review of material Sub-Processors at least annually.

9. Certifications and Audits

• The Platform pursues and maintains [ISO 27001 / SOC 2 Type II — confirm current certification status].

ANNEX 3 — LIST OF APPROVED SUB-PROCESSORS

The Platform engages the following Sub-Processors as at the Effective Date. The current list is maintained at [/legal/sub-processors].

WisdomHub
Operated by TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T))

Effective Date: [Date]
Last Updated: [Date]

These Acceptable Use and Content Guidelines (the “Guidelines”) supplement the Trainers Hub User Agreement, the Trainer and Training Provider Agreement, and the Client Terms of Use. Breach of these Guidelines is a breach of those agreements and may result in content removal, account suspension, or termination.

1. Purpose

These Guidelines explain what content and conduct are acceptable on WisdomHub, and what is not. They apply to:

• profiles and course listings published by Trainers and Training Providers;
• briefs and requirements published by Clients;
• messages exchanged between Users via the Platform;
• ratings and reviews; and
• any other content uploaded, posted, or transmitted on the Platform.

2. Core Principles

We require all content and conduct on the Platform to be:

• Accurate — truthful, current, and not misleading;
• Lawful — compliant with Malaysian law including the PDPA 2010, Communications and Multimedia Act 1998, Defamation Act 1957, Copyright Act 1987, Trade Marks Act 2019, Penal Code, and Sedition Act 1948;
• Respectful — free from harassment, discrimination, and personal abuse; and
• Professional — appropriate to a B2B corporate training marketplace.

3. Prohibited Content

You must not upload, post, or transmit content that:

3.1 Is illegal or harmful

• Infringes the intellectual property rights of any person (copyright, trade mark, design, patent, confidential information).
• Is defamatory under the Defamation Act 1957 (e.g., false statements that damage reputation).
• Is obscene, pornographic, or sexually exploitative.
• Promotes or glorifies violence, terrorism, or extremism.
• Promotes or facilitates illegal gambling, illegal drugs, or other criminal activity.
• Breaches the Sedition Act 1948 or otherwise threatens public order in Malaysia.
• Discloses another person’s Personal Data in breach of the PDPA.

3.2 Is misleading

• Falsely claims qualifications, accreditation, or experience (e.g., listing a TTT certificate you do not hold).
• Falsely describes a course as “HRDF claimable” when the Trainer/TP is not accredited and has no valid Umbrella TP arrangement.
• Misrepresents prices, outcomes, or attendee qualifications.
• Uses deceptive thumbnail images, course titles, or descriptions.

3.3 Is discriminatory or harassing

• Discriminates on the basis of race, ethnicity, religion, national origin, gender, sexual orientation, disability, age, or political belief, contrary to Article 8 of the Federal Constitution and to general standards of professional conduct.
• Targets, threatens, intimidates, or harasses any specific individual.
• Uses slurs, hate speech, or content designed to incite hatred against any group.

3.4 Is technically harmful

• Contains malware, viruses, trojans, or other malicious code.
• Contains links or redirects designed to phish, scam, or otherwise deceive.
• Exploits or attempts to exploit security vulnerabilities in the Platform.

3.5 Is commercially abusive

• Spam — unsolicited promotional content unrelated to the User’s training needs.
• Duplicate listings or duplicate accounts designed to game search or ratings.
• Content placed solely to attract traffic to off-Platform channels in breach of the non-circumvention clause.
• Reviews or ratings written by the Trainer/TP themselves, by competitors with intent to harm, or in exchange for any inducement.

4. Prohibited Conduct

In addition to prohibited content, you must not:

4.1 Circumvent the Platform

• Engage with another User off-Platform with the intent or effect of avoiding the Administrative Fee, during a non-circumvention period (see User Agreement Clause 7.4 and Client Terms of Use Clause 8).
• Solicit another User’s contact details outside of the Platform’s official messaging.
• Use the Platform purely as a directory while transacting elsewhere.

4.2 Manipulate the rating or search system

• Trade favours for ratings, or coerce ratings.
• Submit ratings about Trainers/TPs you have not actually engaged.
• Create fake accounts to inflate or deflate ratings.
• Engage in keyword stuffing in profile or listing text.

4.3 Misuse Client or participant data

• Use Personal Data received via the Platform for purposes other than delivering the engaged Booking.
• Share participant data with third parties without lawful basis.
• Retain participant data beyond the period needed for the engagement and any post-engagement HRD Corp claim window.

4.4 Misuse the Platform

• Scrape, data-mine, or use automated tools to extract Platform content.
• Reverse engineer the Platform.
• Probe, scan, or test the vulnerability of the Platform without prior written consent.
• Submit fictitious briefs (e.g., for competitive intelligence).
• Use the Platform’s branding, name, or logo without consent except to identify yourself as a User.

5. Trainer / Training Provider-Specific Guidelines

5.1 Profile content

• One profile per individual Trainer or TP entity. No duplicate or “shadow” profiles.
• Photographs must be of the actual Trainer; stock or AI-generated images are not permitted.
• Credentials, qualifications, and accreditation status must be evidenced on request.
• Past client logos or testimonials may only be displayed with that client’s written consent.

5.2 Course listings

• Course title must accurately describe the content.
• Learning outcomes must be specific and realistic.
• Duration, mode (in-person / virtual / hybrid), and prerequisites must be stated.
• Where the listing is marked “HRDF claimable”, you must hold valid accreditation directly or via an uploaded Umbrella TP sub-contract.
• A disclaimer note must accompany every HRDF-claimable listing: “Subject to HRD Corp approval; the Platform does not guarantee claim acceptance.”

5.3 Communications with Clients

• Initial communications must run through the Platform’s messaging.
• Off-Platform contact details (email, phone, WhatsApp) may be exchanged only after a Booking is Confirmed.
• All quotes must be communicated through the Platform’s proposal flow.

6. Client-Specific Guidelines

6.1 Briefs

• Briefs must reflect a genuine training need.
• Budget, dates, location, and audience size must be accurate.
• Briefs must not be used to harvest pricing information without intent to engage.

6.2 Ratings and reviews

• Ratings must reflect actual experience with the engaged Trainer/TP.
• Reviews must be specific, factual, and focused on the training delivered.
• Personal attacks, off-topic complaints, and unsubstantiated allegations are not permitted.
• Ratings must be submitted within fourteen (14) days of training completion (see Client Terms of Use Clause 7.1).

6.3 Participant data

• Upload only the participant data necessary for the engagement.
• Obtain participant notices and consents under the PDPA before uploading.
• Do not upload Sensitive Personal Data without explicit consent and prior written notification to the Platform.

7. Reporting Violations

If you see content or conduct that breaches these Guidelines:

• Email: hello@wisdomhub.com.my
• In-Platform: click “Report” on the relevant profile, listing, message, or rating.

Provide as much detail as possible (URL, screenshots, context). We treat reports confidentially. Retaliation against a User who reports in good faith is itself a breach of these Guidelines.

8. Enforcement

Our Moderation Policy (separate document) sets out how we assess reports and what action we take. Possible outcomes include:

• No action (where no breach is found).
• Warning.
• Content edit or removal.
• Listing or rating removal.
• Temporary account suspension.
• Permanent account termination.
• Referral to law enforcement or regulators.

Repeated or serious breaches will be treated more severely. Fraudulent listings, false accreditation claims, and breaches of the PDPA may be reported directly to HRD Corp, JPDP, or law enforcement.

9. Updates

We may update these Guidelines from time to time. Material changes will be notified by email and in-app notification at least fourteen (14) days in advance.

10. Contact

Questions about these Guidelines:

• Email: hello@wisdomhub.com.my
• Post: Trust & Safety, [Address], Malaysia

WisdomHub
Operated by TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T))

Effective Date: [Date]
Last Updated: [Date]

This Moderation Policy explains how we assess and act on content and conduct concerns on WisdomHub (the “Platform”). It supports the Trainers Hub User Agreement, Trainer and Training Provider Agreement, Client Terms of Use, and Acceptable Use and Content Guidelines.

1. Our Approach

We host User content (profiles, listings, messages, ratings, briefs) as a passive intermediary. We do not pre-moderate or editorially curate User content. We rely on the safe-harbour position available to intermediaries under the Communications and Multimedia Act 1998 and general Malaysian common law principles.

When a concern is brought to our attention through a report, a regulator’s notice, or our own detection systems, we assess it under this Policy and take proportionate action.

We balance three interests:

• the affected User’s reputation, business, and rights;
• the reporting User’s experience and rights;
• the wider Platform community’s trust in the integrity of the marketplace.

2. Scope

This Policy applies to:

• Profiles of Trainers, Training Providers, and Clients;
• Course listings and brief postings;
• Ratings and reviews;
• Messages exchanged via Platform messaging;
• Conduct in connection with a Booking (e.g., harassment, no-shows, fraud).

It does not apply to disputes about commercial deliverables (e.g., quality of training delivered), which are resolved through the Platform’s in-house dispute facilitation service and, ultimately, between the Trainer/TP and Client.

3. Reporting Channels

A concern may reach us through:

• In-Platform “Report” button on any profile, listing, message, or rating;
• Email to hello@wisdomhub.com.my;
• Notice from a regulator (JPDP, HRD Corp, MCMC, police);
• Court order or other legal process;
• Detection by our automated tooling (e.g., known-malware scanning, profanity filters).

We treat all reports as confidential, except where disclosure is required by law or to fairly investigate a counter-allegation.

4. Triage and Severity

On receipt of a report, we assign one of three severity levels:

4.1 Critical (response within 24 hours)

• Imminent risk to safety or to a Data Subject’s rights.
• Material breach of the PDPA (e.g., bulk disclosure of Personal Data).
• Clear fraud, financial crime, or impersonation.
• Court order, criminal investigation, or regulator’s notice.

4.2 High (response within 3 business days)

• Defamation allegation supported by specifics.
• False accreditation claims (e.g., fabricated TTT certificate).
• Coordinated rating manipulation.
• Harassment, hate speech, or discriminatory conduct.

4.3 Standard (response within 10 business days)

• Disputed but not facially defamatory ratings or reviews.
• Profile inaccuracies that do not amount to fraud.
• Off-topic, low-quality, or duplicate content.
• General complaints about tone or professionalism.

5. Investigation

For each report, we will:

1. Acknowledge receipt to the reporter within the timeframe above.
2. Preserve the relevant content (snapshot to evidence vault) so it cannot be deleted or edited during investigation.
3. Notify the affected User of the substance of the concern (typically without identifying the reporter) and invite a written response within five (5) business days.
4. Gather evidence:

• The content itself.
• Surrounding context (messages, timeline, account history).
• Documentary evidence (e.g., HRD Corp accreditation database checks, SSM records).

5. Assess against the Acceptable Use and Content Guidelines and Malaysian law, with input from legal/compliance for High/Critical reports.
6. Decide and document the outcome (see Clause 6).
7. Communicate the outcome to the reporter and the affected User.

The DPO and an independent senior reviewer are involved in any decision that may engage the PDPA or the Defamation Act 1957.

6. Outcomes

Possible outcomes are:

We pick the least intrusive outcome that is reasonably necessary to address the breach.

7. Specific Categories

7.1 Ratings and reviews

We will assess removal requests where the rating is alleged to be:

• Defamatory under the Defamation Act 1957 — requires specific identification of the false statement of fact and evidence of falsity; pure opinion is not defamation.
• Unlawful under another Malaysian law (e.g., CMA 1998, Sedition Act 1948).
• In breach of Guidelines (off-topic, personal attack, harassment, manipulated).

In a borderline case we will typically leave the rating in place but attach the affected User’s right-of-reply. We are not obliged to act on every removal request and we are not the arbiter of who is “right” in a commercial dispute.

7.2 Accreditation fraud

A claim of false accreditation (e.g., TTT certificate, HRD Corp TP status) will be checked against:

• The HRD Corp public TP/TTT directory (or HRD Corp’s verification API where available).
• The certificate uploaded at onboarding.
• The Trainer/TP’s written response.

If accreditation cannot be substantiated, the listing is suspended pending evidence within seven (7) days, after which it is removed.

7.3 PDPA-related reports

A report alleging breach of the PDPA (e.g., unauthorised disclosure of participant data) is routed to the DPO and treated as a Critical incident. If a Personal Data Breach is confirmed, the Incident Response Runbook is triggered and notification timelines under the PDPA (including the 72-hour JPDP notification, where applicable) apply.

7.4 Communications and Multimedia Act 1998 reports

Reports alleging offensive, indecent, or menacing content under the CMA 1998 are reviewed by Trust & Safety with legal input. Where a court or MCMC issues a notice, we comply within the period stipulated.

8. Appeals

The User affected by a moderation decision may appeal by writing to hello@wisdomhub.com.my within fourteen (14) days of being notified of the decision. The appeal will be reviewed by a person not involved in the original decision and a final decision will be communicated within fourteen (14) days of receipt.

Appeals are limited to:

• New evidence not previously considered.
• Errors in the application of these Guidelines.
• Disproportionate outcome.

The appeal decision is final, save for the User’s right to pursue legal remedies.

9. Counter-Notice (for content removed on third-party complaint)

Where content is removed on the basis of a third-party complaint, the affected User may submit a counter-notice to hello@wisdomhub.com.my asserting that the content does not breach these Guidelines or Malaysian law. We will consider the counter-notice and, where appropriate, restore the content. We are not obliged to restore content where doing so would expose the Platform to legal risk.

10. Transparency

We aim to publish an annual Transparency Report summarising:

• Volume of reports received, by category;
• Outcomes (action / no action);
• Government and court orders received and complied with;
• Average response times.

The first Transparency Report will be published at [/transparency] within 12 months of the Effective Date.

11. Records and Retention

We retain moderation case files (report, evidence, decision, communications) for seven (7) years from closure, consistent with Income Tax Act 1967 record-keeping and to enable defence of any subsequent claim.

Personal Data within case files is processed under the Privacy Policy. Affected Users may exercise PDPA rights subject to applicable exemptions (including the legal claims defence exemption in section 39).

12. Updates

We may update this Policy from time to time. Material changes will be notified at least fourteen (14) days in advance.

13. Contact

• Trust & Safety: hello@wisdomhub.com.my
• Appeals: hello@wisdomhub.com.my
• DPO (PDPA matters): privacy@wisdomhub.com.my
• Post: Trust & Safety, [Address], Malaysia

This Agreement is between:

TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T)) (“Platform”, “we”, “us”)

and

the HRD Corp-registered Training Provider that has applied for and been admitted to the Platform’s roster (“you”, the “Roster TP”).

Effective Date: Date of roster admission.

This Agreement is supplemental to the Trainers Hub User Agreement and the Trainer and Training Provider Agreement. In the event of conflict, this Agreement prevails for roster engagements.

1. Definitions

Terms defined in the Trainers Hub User Agreement and the Trainer and Training Provider Agreement have the same meaning here. In addition:

• “Assignment” means the Platform’s offer to you of a Roster Engagement, made in rotation among Roster TPs.
• “Claim Pack” means the complete set of documents HRD Corp requires for the grant claim on a Roster Engagement.
• “Disbursed Amount” means the amount actually paid by HRD Corp to you on a Roster Engagement, net of the HRD Corp levy deduction.
• “Dual Delivery Confirmation” means confirmation recorded in-Platform by both the Client-facing party and the Trainer that the training has been delivered.
• “Roster Engagement” means an engagement on which you act as the claim vehicle for a Trainer under this Agreement.
• “Roster Service Fee” means your fee of fifteen percent (15%) of the Disbursed Amount, collected automatically in the settlement waterfall. The Platform’s Administrative Fee is not deducted before your fee is calculated; it is borne by the Trainer.

2. Admission and Standing

2.1 Admission to the roster is by application, is at the Platform’s discretion, and requires:
(a) current registration as a Training Provider with HRD Corp;
(b) SSM registration documents in the name of your entity;
(c) a bank account in the registered name of your entity, registered with the Platform’s payment gateway; and
(d) such other verification as the Platform’s onboarding procedure requires.

2.2 You must notify us within seven (7) days of any change to your HRD Corp registration, accreditation status, SSM particulars, directorship, or bank account.

2.3 We track your HRD Corp licence expiry. Your roster participation is automatically paused thirty (30) days before licence expiry and resumes on verified renewal.

2.4 No listing or subscription fee is charged for roster participation at this time. Your compensation is the Roster Service Fee. We may introduce a roster fee on sixty (60) days’ written notice.

3. Role of the Roster TP

3.1 On a Roster Engagement you act as the claim vehicle: you register the programme as required, handle HRD Corp claim administration, submit the Claim Pack, receive HRD Corp’s disbursement, and settle the Trainer’s share through Platform checkout.

3.2 You do not deliver the training, and you acquire no employment, agency, or exclusive relationship with the Trainer by reason of a Roster Engagement.

3.3 You retain primary responsibility to HRD Corp for the accuracy and completeness of the claim, in accordance with the Pembangunan Sumber Manusia Berhad Act 2001 and HRD Corp’s published requirements.

3.4 The sub-contract between you and the Trainer for each Roster Engagement is set out in Schedule A and is deemed entered into on your acceptance of the Assignment, unless you and the Trainer execute a superseding written sub-contract and upload it to the Platform before kickoff.

4. Assignment and Service Levels

4.1 Assignments are offered in rotation, filtered by the Trainer’s location (state). You must accept or decline an Assignment within twenty-four (24) hours; an Assignment binds you only on your acceptance, and a decline routes it to the next Roster TP in rotation. No response within that window counts as a decline. Roster participation is non-exclusive, and roster membership is not published to other Roster TPs or to the public.

4.2 If no Roster TP accepts an Assignment within forty-eight (48) hours of first offer, the engagement may be assigned to a Training Provider affiliated with the Platform’s founders as a disclosed last-resort claim vehicle. That TP sits outside the normal rotation, receives Assignments only under this clause, and is paid the Roster Service Fee under Clause 5.2 and nothing more.

4.3 On an accepted Assignment you must:
(a) hold the kickoff coordination with the Trainer and the Client within three (3) working days of acceptance;
(b) submit the complete Claim Pack to HRD Corp within seven (7) calendar days of Dual Delivery Confirmation, and record the submission in your Platform dashboard (signed attendance and declaration checklist) — the recorded submission marks the point where your filing responsibility ends and HRD Corp’s processing begins; and
(c) update the engagement status in-Platform at each milestone.

4.4 Service-level strikes. A missed deadline under Clause 4.1 or 4.3, without a cause accepted by the Platform, is a strike. Two (2) strikes in any six (6) month period results in suspension from the roster pending admin review.

5. Money: Settlement Waterfall and the Remittance Clock

5.1 On receipt of the Disbursed Amount you must initiate settlement of the Trainer’s share through Platform checkout within five (5) working days of the later of:
(a) your receipt of the Disbursed Amount; or
(b) Dual Delivery Confirmation.

5.2 Settlement is executed by the payment gateway’s split payment at the time of checkout, in this order:
(a) the Platform’s Administrative Fee: five percent (5%) of the Disbursed Amount;
(b) your Roster Service Fee: fifteen percent (15%) of the Disbursed Amount; and
(c) the remainder (80% of the Disbursed Amount) to the Trainer.
Both percentages are calculated on the Disbursed Amount. Worked example on a Disbursed Amount of RM10,080: Platform RM504.00, Roster TP RM1,512.00, Trainer RM8,064.00.

5.3 The Platform absorbs the payment gateway transaction charge on the split. Checkout is blocked until the Trainer’s payout details are registered with the gateway; if checkout is blocked for that reason, the remittance clock is suspended until the Trainer registers valid details, and you must notify the Platform.

5.4 Overdue remittance. If you miss the deadline in Clause 5.1:
(a) the engagement is flagged overdue and placed on the Platform’s overdue list;
(b) the Trainer’s dispute process opens automatically;
(c) you are suspended from new Assignments until the remittance clears; and
(d) persistent default results in removal from the roster under Clause 8 and may be reported to the Trainer and, where appropriate, pursued as a debt claim by the Trainer with the Platform’s records in support.

5.5 The Trainer’s share is at all times money owed by you to the Trainer. You hold it for onward settlement, must not apply it to any other purpose, and must not set off against it any amount the Trainer allegedly owes you except through the Platform’s dispute process.

6. HRD Corp Clawback and Repayment

6.1 If HRD Corp reduces, rejects after payment, or claws back a claim on a Roster Engagement, the parties will cooperate in good faith to allocate the repayment in the same proportions as the settlement waterfall, and the Trainer’s repayment obligation under the Trainer and Training Provider Agreement (Clause 9.4) applies to the Trainer’s share.

6.2 You must notify the Platform within three (3) working days of any HRD Corp audit query, clawback demand, or claim rejection affecting a Roster Engagement.

7. Conduct

7.1 You must not, for a period of twelve (12) months after a Roster Engagement, engage the Trainer or solicit the Client of that engagement off-Platform. Off-Platform engagements within this period are deemed Platform-originated and the Administrative Fee remains payable.

7.2 Access to engagement threads and Trainer or Client contact information is provided solely to perform this Agreement. Poaching, side-dealing, or misuse of thread access is misconduct attracting immediate removal from the roster without prior strikes.

7.3 You must comply with the PDPA 2010 in respect of personal data received through the Platform, use it only to perform the Roster Engagement, and delete it when no longer required for the claim record.

8. Suspension, Removal, and Termination

8.1 We may suspend or remove you from the roster if:
(a) your HRD Corp registration lapses, is suspended, or is revoked;
(b) you accumulate strikes under Clause 4.4;
(c) you miss a remittance deadline and fail to cure promptly, or default persistently;
(d) you breach Clause 7;
(e) you provide false or misleading information; or
(f) required by law, regulator, or HRD Corp direction.

8.2 Either party may terminate this Agreement on thirty (30) days’ written notice. Termination does not affect accrued obligations, and you must complete claim administration and remittance for all Roster Engagements in progress.

8.3 Clauses 3.3, 5, 6, 7, and 9 survive termination.

9. Liability

9.1 The Platform facilitates Assignments, settlement mechanics, and service-level enforcement. The Platform is not the claim vehicle, not a party to the claim, and does not guarantee HRD Corp approval, the timing of HRD Corp disbursement, or the Trainer’s performance.

9.2 You indemnify the Platform against claims, losses, fines, and reasonable legal costs arising from your claim administration, your breach of HRD Corp requirements, your failure to remit, or your breach of this Agreement.

9.3 The liability caps in the Trainers Hub User Agreement Clause 10 apply.

10. Disclosure and General

10.1 Founder-affiliated TP. A Training Provider affiliated with the Platform’s founders participates as the disclosed last-resort claim vehicle described in Clause 4.2. It is subject to this Agreement on the same terms, including the Roster Service Fee in Clause 5.2 (no other fee, rebate, or payment), the service levels, the remittance clock, and the overdue consequences, and it takes no priority in rotation.

10.2 Governing law, dispute resolution (including the small-claims carve-out), notices, variation, and assignment follow the Trainers Hub User Agreement.

Schedule A — Roster Engagement Sub-Contract (Trainer and Roster TP)

Deemed terms between the Trainer and the Roster TP for each Roster Engagement, entered into on the Roster TP’s acceptance of the Assignment:

1. The Roster TP will register the programme, administer and submit the HRD Corp claim, and receive the disbursement as claim vehicle. The Trainer will deliver the training and provide all documents the Roster TP reasonably requires for the Claim Pack within five (5) working days of request.
2. The Trainer warrants the accuracy of the content, attendance, and delivery information supplied for the claim. The Roster TP warrants that it holds current HRD Corp registration covering the programme.
3. The Roster TP will settle the Trainer’s share through Platform checkout within the remittance clock in Clause 5.1 of the main Agreement. The Trainer’s share is the remainder after the Platform Administrative Fee and the Roster Service Fee, per the waterfall in Clause 5.2.
4. If HRD Corp claws back or reduces the claim, each party repays its share proportionately, per Clause 6.1 of the main Agreement.
5. Neither party will engage the other, or the Client, off-Platform in breach of the applicable non-circumvention periods.
6. Disputes go first to the Platform’s dispute process. This sub-contract is governed by the laws of Malaysia.

These terms apply to an HRD Corp-registered Training Provider that sources and engages Trainers through the Platform as a buyer (“you”, the “TP Buyer”).

Operated by TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T)) (“Platform”, “we”, “us”).

Effective Date: [Date]

These terms are supplemental to the Trainers Hub User Agreement and the Trainer and Training Provider Agreement. In the event of conflict, these terms prevail where you act as a buyer of training delivery.

1. Scope

1.1 These terms govern engagements where you find a Trainer through the Platform and engage them to deliver training for your own client or programme, whether or not the engagement is claimed through HRD Corp.

1.2 Where you act as a claim vehicle on the Platform’s roster, the Roster Training Provider Agreement applies instead. Where you list your own programmes for sale, the Trainer and Training Provider Agreement applies.

2. Engagement and Fee

2.1 The fee for the Trainer’s delivery is the fee you and the Trainer agree in-Platform (the “Negotiated Fee”). The Negotiated Fee, not any claim value, is the Fee Base for the Platform’s Administrative Fee.

2.2 The Platform’s Administrative Fee of five percent (5%) of the Negotiated Fee is payable by the Trainer and is deducted at source in the checkout split. You pay no Platform fee on the engagement as buyer.

2.3 Your commercial arrangement with your own client, including any margin, is your own affair and does not affect the Negotiated Fee or the split.

3. Mandatory Payment Channel

3.1 You must pay the Negotiated Fee through Platform checkout. The payment gateway splits it at the time of payment: five percent (5%) to the Platform and ninety-five percent (95%) to the Trainer. Off-Platform payment of a Platform-originated engagement is a breach of the non-circumvention provisions of the Trainers Hub User Agreement.

3.2 Checkout is available only after Dual Delivery Confirmation (delivery confirmed in-Platform by both you and the Trainer), and is blocked until the Trainer has registered valid payout details with the payment gateway. No partial payment is possible.

3.3 The Platform absorbs the payment gateway transaction charge on the split.

4. Payment Deadline

4.1 Where the engagement is claimed through HRD Corp, you must complete checkout no later than fourteen (14) days after your receipt of the HRD Corp disbursement. The 14-day period is a term of your use of the Platform, is shown on the engagement record, and is measured from the claim receipt date you record in-Platform (which the Platform may verify).

4.2 Where the engagement is not claimed through HRD Corp, you must complete checkout within fourteen (14) days of Dual Delivery Confirmation, unless the engagement record states a shorter period agreed with the Trainer.

4.3 You must record your HRD Corp claim submission and claim receipt dates on the engagement record within three (3) working days of each event.

5. Overdue Payment

5.1 If you miss the deadline in Clause 4:
(a) the engagement is flagged overdue on day fourteen and placed on the Platform’s overdue list;
(b) the Trainer’s dispute process opens automatically;
(c) new engagement capability is suspended until payment clears; and
(d) persistent default results in account suspension or removal under the Trainers Hub User Agreement, and the Platform’s records of the engagement, the deadline, and the flag are available to the Trainer in support of recovery.

5.2 The debt for the Negotiated Fee is owed by you to the Trainer. The Platform operates the checkout rail, the deadline, and the enforcement levers, but is not the paymaster and does not guarantee your payment.

6. Delivery Confirmation and Claims

6.1 You must record delivery confirmation promptly and honestly. Withholding confirmation to delay the payment clock, without a genuine delivery dispute raised in the dispute process, is a breach of these terms.

6.2 Where you claim the engagement through HRD Corp, you are the claiming Training Provider: you retain primary responsibility to HRD Corp for the claim and its accuracy. The Platform is not a party to the claim.

6.3 If HRD Corp rejects or claws back your claim after you have paid the Trainer, recovery of the Trainer’s share (if any is properly recoverable) proceeds under the Trainer’s repayment obligation (Trainer and Training Provider Agreement Clause 9.4), through the Platform’s dispute process. Checkout payments are settled instantly and are not reversible by the Platform.

7. Conduct

7.1 Non-circumvention under the Trainers Hub User Agreement Clause 7.4 applies to Trainers you engage through the Platform.

7.2 Access to Trainer profiles, contact details, and engagement threads is provided to perform the engagement. Poaching or side-dealing is misconduct attracting suspension or removal.

7.3 You must comply with the PDPA 2010 in respect of personal data received through the Platform.

8. General

8.1 Suspension and termination follow the Trainers Hub User Agreement Clause 5. On termination, outstanding payment obligations to Trainers under Clause 4 survive and remain enforceable.

8.2 Governing law, dispute resolution (including the small-claims carve-out), notices, variation, and liability caps follow the Trainers Hub User Agreement.

These terms govern your use of WisdomHub during its pre-launch period, before the marketplace opens for booking and payment.

Operated by TRAINERS HUB SDN. BHD. (Company No. 202601033142 (1695237-T)) of [Registered Address], Malaysia (“Platform”, “we”, “us”).

Effective Date: [Date]

1. What the Pre-Launch Period Is

1.1 The Platform is not yet operating as a marketplace. During the pre-launch period we allow Trainers and Training Providers (“you”) to register an account, upload accreditation documents, and build and publish a public profile, so that the marketplace has content on the day it opens.

1.2 The pre-launch period begins on the Effective Date and ends when we announce that the marketplace is open for booking (“Full Launch”). We may end, extend, pause, or restart the pre-launch period at any time.

1.3 These terms apply only during the pre-launch period, and only to pre-launch registration. They are supplemental to the Trainers Hub User Agreement and, where they conflict with it, these terms prevail for the pre-launch period only.

2. What Is Not Available Yet

2.1 During the pre-launch period there is no:
(a) client-side search, browsing, brief submission, or enquiry;
(b) booking, proposal, quotation, or engagement of any kind;
(c) payment, checkout, invoicing, split, or disbursement;
(d) HRD Corp claim facilitation or roster assignment;
(e) rating, review, or dispute process;
(f) subscription billing, credit purchase, or Administrative Fee.

2.2 No contract for training services is formed during the pre-launch period, between you and us, or between you and any other person, through the Platform. Nothing shown to you during the pre-launch period is an offer capable of acceptance.

2.3 Registering during the pre-launch period does not reserve, guarantee, or create any entitlement to work, bookings, enquiries, ranking, placement, or visibility after Full Launch.

3. Eligibility

3.1 You may register during the pre-launch period only if you meet the eligibility requirements of the Trainers Hub User Agreement Clause 3 and the Trainer and Training Provider Agreement Clause 3, namely that you are at least eighteen (18) years old, are lawfully able to provide training services in Malaysia, and are registering on your own behalf or with authority to bind the entity you name.

3.2 We may decline, defer, or reverse any pre-launch registration at our discretion, without giving reasons.

4. Your Profile Before and After Full Launch

4.1 A profile you build during the pre-launch period is not public. Until Full Launch it is visible only to you and to our verification and support staff. It is not shown to companies or training providers, is not listed in any search, and is not indexed by search engines.

4.2 At Full Launch, once you have accepted the Full Launch terms under Clause 12, your profile becomes public. The following are then shown publicly: your name, profile photo, professional summary, areas of expertise, programmes, published articles, testimonials and company logos you have added (marked as self-declared until a rating from a booking made on the Platform is recorded), and your accreditation status with a link and QR code to HRD Corp’s public register.

4.3 The following are never shown publicly, before or after Full Launch: your email address, mobile number, NRIC or passport number, bank or payout details, and any certificate or identity document you upload.

4.4 After Full Launch you may unpublish your profile at any time from your account settings. Unpublishing removes it from public view going forward; it does not retrieve copies already cached, indexed, or saved by third parties.

4.5 During the pre-launch period, and only where you have given the separate consent in the Consent and Communications Texts Clause 3, we may show your name, profile photo, and public profile content in our own launch communications, for example on the pre-registration site and in our newsletter to companies. You may withdraw that consent at any time, which stops future use.

5. Accuracy, and What We Do Not Check

5.1 You are responsible for the accuracy of everything you enter or upload. You must not misstate your accreditation, experience, qualifications, or course outcomes.

5.2 During the pre-launch period we check the HRD Corp accreditation certificate and the TTT or exemption certificate you upload against HRD Corp’s public registers, and show the result on your dashboard as a status. A status reflects what the register showed on the day we checked. It is a document check, not an endorsement: Trainers Hub User Agreement Clause 2.8 applies in full. We do not verify any other document you upload.

5.3 We do not vet, screen, or background-check Users. Trainers Hub User Agreement Clause 2.7 applies in full during the pre-launch period.

5.4 We may require you to re-submit a document for verification at or after Full Launch where it has expired, where the register no longer matches it, or where we have reason to doubt it, before your profile becomes bookable.

6. Your Own Employment and Other Commitments

6.1 You warrant that your registration, your published profile, and your intended delivery of training through the Platform do not breach any employment contract, service contract, exclusivity, non-compete, non-solicitation, moonlighting policy, staff handbook, professional rule, licence condition, or other obligation you owe to any third party.

6.2 You are solely responsible for obtaining any consent, permission, or waiver your employer or principal requires. We do not ask for it, do not check it, and do not hold it.

6.3 You indemnify us against any claim brought against us by your employer, principal, or any other third party arising out of your registration, your profile, or your participation in the pre-launch period. Trainer and Training Provider Agreement Clause 15 (Indemnity), including its liability cap, applies to this indemnity.

7. Fees and Promotional Benefits

7.1 Pre-launch registration is free. No subscription, credit, listing, or Administrative Fee is charged during the pre-launch period. Programme Builder, our outline-drafting tool, is available at no charge during the pre-launch period; a draft you publish is profile content under Clauses 4 and 5. From Full Launch each draft is charged in credits at the rate shown in the tool.

7.2 The early member benefit. If you register during the pre-launch period and meet the qualifying conditions in Clause 7.3, you will receive three (3) months of Pro, our top subscription tier, at no cost, with all Pro features unlocked. No payment card is required. This is a commitment, not a statement of intention.

7.3 Qualifying conditions. To qualify you must, on or before the Full Launch date, have completed all five of the following:
(a) the contact fields of your Trainer profile, being your full name, mobile number, state, and primary area of expertise;
(b) your bio;
(c) uploaded your HRD Corp accreditation certificate, and had it checked under Clause 5.2;
(d) uploaded your HRD Corp Train-the-Trainer (“TTT”) certificate or your TTT exemption certificate, and had it checked under Clause 5.2; and
(e) published at least one (1) programme on your profile.

Your dashboard shows which of the five items you have completed. Meeting them after the Full Launch date does not qualify you. Where a check under (c) or (d) is delayed on our side, the date you uploaded the document counts.

7.4 When it starts and what it covers. The three months run from the Full Launch date, or from the date you accept the Full Launch terms under Clause 12 if that is later. The benefit is a promotional tier benefit under Trainers Hub User Agreement Clause 6.5C: it is not a paid subscription, does not auto-convert into a paid plan without a renewal payment request being issued and paid, has no cash value, and is not transferable or exchangeable for cash. Pro features are available only from Full Launch; they do not operate during the pre-launch period.

7.5 Once you qualify, we will not withdraw it. If you have met the Clause 7.3 conditions on or before the Full Launch date, we will honour the benefit. We may change the qualifying conditions, the length, or the tier for registrations made after we publish the change, and we will publish any such change before it takes effect. A change never applies retrospectively to a registrant who has already qualified.

7.6 Registering without meeting the Clause 7.3 conditions does not affect your account, your profile, or your ability to use the Platform at Full Launch. It affects only this benefit.

7.7 Featured at launch. If, in addition to the five items in Clause 7.3, you have completed all six of the following on or before the Full Launch date, your profile appears in the featured trainers row that companies see first when the marketplace opens, ahead of search results:
(a) an introduction or past-training video on your profile;
(b) at least one published article;
(c) at least one testimonial or company logo;
(d) at least one additional programme beyond the one required by Clause 7.3(e);
(e) your industry experience on your profile, being at least one industry, the years you worked in it, and a short description; and
(f) your training experience on your profile, being the years you have delivered training and a short description.

The featured row is a placement, not a ranking guarantee, and lasts for the period we state on the launch offer page. Clauses 7.4 to 7.6 apply to it as they apply to the three-month benefit.

8. Personal Data

8.1 The Privacy Policy applies in full to the pre-launch period. It sets out what we collect, why, how long we keep it, where it is hosted, and your rights.

8.2 During the pre-launch period we collect and process your data to create and publish your profile, to verify your eligibility, to communicate with you about the launch, and to prepare the marketplace for opening.

8.3 If you never activate. If you register during the pre-launch period and do not accept the Full Launch terms under Clause 12 within ninety (90) days of Full Launch, we will delete or anonymise the account, the profile, and any uploaded accreditation documents, save for records we are required to retain by law. We will email you before we do this.

8.4 You may request access to, correction of, or deletion of your data at any time during the pre-launch period, through account settings or at privacy@wisdomhub.com.my. Deletion during the pre-launch period removes your registration entirely; it is not a suspension.

8.5 Consent for marketing email, and consent for use of your profile content in our marketing, are captured separately and are optional. Withdrawing either does not affect your registration. See the Consent and Communications Texts, Clauses 3 and 4.

9. Communications

9.1 We will send you service messages about the pre-launch period and the launch itself (registration confirmation, a short series of emails that help you finish setting up your profile, verification requests, profile notices, launch announcements, and the Clause 12 re-acceptance request). These are not marketing and are sent whether or not you opt in to marketing email. They do not promote paid plans, offers or anyone else’s services; they may tell you where you stand on the Clause 7 benefit.

9.2 Marketing email (tips, our news and promotions) is sent only if you opt in, at registration or later in Account settings, and you may unsubscribe at any time.

10. We Are Not Obliged to Launch

10.1 We may change the scope, features, pricing, timing, or design of the Platform at any time before Full Launch, and we may delay Full Launch or not launch at all.

10.2 We are not liable to you for any cost, loss of opportunity, loss of profit, wasted time, or wasted expenditure arising from a delay to Full Launch, a change to the Platform, or a decision not to launch. Do not incur cost, turn down work, or make commitments to third parties in reliance on Full Launch happening on any particular date or at all.

11. Conduct

11.1 The Acceptable Use and Content Guidelines apply in full during the pre-launch period, including the rules on prohibited content, misrepresentation of accreditation, and off-Platform solicitation.

11.2 We may unpublish a profile, suspend an account, or remove a registration during the pre-launch period on the grounds set out in Trainers Hub User Agreement Clause 5.1, and additionally where a profile is incomplete, dormant, duplicated, or plainly not genuine. During the pre-launch period we may do this without notice, because no engagement, booking, or payment is affected.

12. Moving to Full Launch

12.1 These terms expire at Full Launch. They are not renewed and do not survive, except Clauses 6.3 (indemnity), 8 (personal data), 10.2 (no liability for non-launch), and 13, which survive.

12.2 At Full Launch we will ask you to accept the Trainers Hub User Agreement and the Trainer and Training Provider Agreement in force at that time. Your profile does not become bookable until you accept them. Acceptance is logged with the document version, timestamp, and account ID.

12.3 If the Full Launch terms differ materially from what was described to you during the pre-launch period, we will say so plainly in the re-acceptance request rather than relying on your acceptance alone.

13. Liability, Governing Law, and Disputes

13.1 Trainers Hub User Agreement Clause 10 (Limitation of Liability) applies to the pre-launch period. Given that no fee is paid and no service is booked during the pre-launch period, our aggregate liability arising out of the pre-launch period is limited to the cap in that clause.

13.2 Trainers Hub User Agreement Clauses 15 (Dispute Resolution), 16 (Governing Law and Jurisdiction), and 17 (Notices) apply to these terms. These terms are governed by Malaysian law.

13.3 Nothing in these terms limits liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any liability that cannot lawfully be limited.