PERSONAL DATA AND PRIVACY NOTICE

Albertstein Sdn Bhd (Company No: 202601014045 (1676143K)) (the "Company" or “we”) respects your privacy. We treat and view your personal data seriously.

This Personal Data and Privacy Notice is issued to all our clients and/or customers pursuant to the requirements of the Malaysia Personal Data Protection Act 2010 ("Act").

For the purpose of this Personal Data and Privacy Notice, "Personal Data" shall have the meaning as ascribed to it in the Act. We may change this Personal Data and Privacy Notice (“Notice”) from time to time without prior notice and you are advised to check the said notice on a regular basis.

This Notice explains how we collect, use, and disclose your Personal Data. The processing of your Personal Data is also subject to applicable laws. The Personal Data that you provide to us now or from time to time, or have previously provided to us, will be used, processed, and continue to be used and processed by us in accordance with this Notice (as amended, varied, or revised from time to time).

Words importing the singular include the plural and vice versa.

Personal Data

In the course of your dealings with us, we will request that you provide data and information about yourself and/or your organization to enable us to enter into transaction with you or to deliver the necessary services, products and/or deliverables in connection with our business.

Such Personal Data may include information concerning name as per identity card, preferred name, identity card number, age, contact number, residential address, e-mail address, birth date, gender, occupation, designation, bank account details, information of spouse/ children such as name and birth date, and other such data necessary for the performance of our services to you.

Certain information requested by us are mandatory which you must provide and agree to the processing of such mandatory information by us, failing which, we will not be able to provide you the relevant service, products or information and updates.

Sensitive Personal Data

Sensitive Personal Data may include information as to physical or mental health or condition, religious beliefs or other beliefs of a similar nature, political opinions, the commission or alleged commission of an offence, and any other personal data prescribed under the Act.

We do not collect Sensitive Personal Data from you unless required by applicable laws. If you do not want your Sensitive Personal Data collected by us, please do not submit it.

If you do choose to submit your Sensitive Personal Data to us, such data shall then be deemed to be and will be treated by us as Personal Data which will be subject to the principles, terms and scope of this Notice.

Consent to Processing of Personal Data

By providing your Personal Data to the Company, you hereby consent to the collection, use, processing, storage, transfer and disclosure of your Personal Data in accordance with this Notice and as permitted under the Act.

Accuracy of Personal Data

You represent and warrant that all Personal Data provided to the Company is true, accurate, complete and not misleading. You undertake to promptly notify the Company of any changes to your Personal Data and to provide updated information as may be necessary to ensure the continued accuracy of the Personal Data held by the Company.

For the avoidance of doubt, the Company and/or its employees or authorized officers or agents will not be responsible for any personal data submitted by you to us that is inaccurate, misleading, incomplete or not updated.

Personal Data of Third Parties

Where you provide Personal Data relating to any third party, including but not limited to your spouse, children, dependents, directors, shareholders, employees, beneficial owners, authorized representatives or other related persons, you confirm and warrant that:

• you have obtained all necessary consents, approvals and authorizations from such individuals for the disclosure of their Personal Data to the Company;
• you have informed such individuals of the Company's collection, use, disclosure and processing of their Personal Data as set out in this Notice; and
• the Company may rely on your representation that such consent has been duly obtained.

How is your Personal Data collected?

• when you sign up to purchase our services or products, register your interest in purchasing our services or products, or to obtain information and updates regarding our services or products;
• when you visit our websites or social networking sites;
• when you enter contests or respond to surveys, promotions or questionnaires;
• from third party sources such as credit reference agencies, fraud prevention agencies and publicly available sources of information; or
• pursuant to any transaction or inquiry or communication made with or to us.

Why do we collect Personal Data?

Collection of personal data is relevant in connection with our business process, execution, including delivery of services and/or deliverables and client and/or customer relationship management.

Personal Data you provide will be collected, used and otherwise processed by us for, amongst others, the following purpose:

• assessing, evaluating and managing investment opportunities and transactions;
• conducting due diligence on investors, prospective investors, portfolio companies, counterparties and other relevant parties;
• the delivery of services, products or deliverables and the marketing of such services, products or deliverables whether present or future, to you;
• administering and managing investor relationships and communications;
• facilitating subscriptions, investments, capital calls, distributions, payments and related financial transactions;
• to facilitate payment for our services;
• member or client and/or customer relationship management procedures;
• those purposes specifically provided for in any service or deliverable offered by us;
• conducting training programs, client and/or customer promotional activities, marketing and client and/or profiling activities in connection with our services, products and related deliverables;
• our internal record keeping;
• meeting any legal or regulatory requirements relating to our provision of services and deliverables and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to us;
• enable us to send you information by e-mail, telecommunication means (telephone calls or text messages) or social media about products and services offered by selected third parties that we think may interest you;
• conducting anti-money laundering (AML), counter-terrorism financing (CTF), sanctions screening, fraud prevention, risk assessment, background checks, regulatory reporting and compliance activities;
• establishing, exercising or defending legal rights and claims; and
• protecting the Company's legitimate business interests and ensuring compliance with internal policies and procedures.

What are the effects arising from failure to provide Personal Data?

The failure to supply such Personal Data will /may:

• result in us being unable to provide clients and/or customers with the services, products and/or deliverables requested;
• result in us being unable to update you on our services, products, deliverables and/or launches;
• result in our inability to conduct necessary due diligence or comply with legal and regulatory obligations; or
• result in your inability to receive invitations to promotional activities organised by us/our agents.

Disclosure

Personal Data provided to us will generally be kept confidential, but you hereby consent and authorize us to provide or disclose Personal Data to the following categories of parties:

• any person to whom we are compelled or required to do so under law or in response to a regulatory authority or government agency;
• statutory authorities and industry regulators, tax authorities, courts, tribunals, and other competent authorities where disclosure is required or permitted by law, regulation, court order or regulatory requirement;
• our auditors, consultants, accountants, insurers, lawyers, or other financial or professional advisers; and
• portfolio companies, investment partners, co-investors, financing institutions, custodians, fund administrators, transaction counterparties and other service providers where such disclosure is reasonably necessary for investment evaluation, transaction execution, administration, regulatory compliance, risk management or the provision of services and/or deliverables by the Company.

We may also disclose your personal data if required to do so by law or in good faith, if such action is necessary to protect and defend rights or property of the Company.

Safety and Security of Personal Data

We shall keep and process Personal Data in a secure manner. We endeavor, where practicable, to implement the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of Personal Data and the accidental loss or destruction of, or damage to, such Personal Data.

We have implemented reasonable technology, policies and measure designed for securing and protecting your privacy from unauthorised access, improper use, disclosure and alteration, we will make reasonable updates to its security measures from time to time and ensure authorised third parties use the Personal Data for the purpose set herein and to adequately ensure the confidentiality of the Personal Data.

Whilst we will use its best endeavours to maintain a security plan deemed adequate by us to protect your Personal Data, we make no guarantee that the website will be free from security breaches, especially due to unauthorised actions of third parties such as, but not limited to spoof attacks, session hacking, sniffing or tampering. We shall not be held responsible for any loss or damage, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction as a result of such actions.

Our web site may contain links to other sites and pages. By activating a link, such as for example by clicking on the banner of an advertiser, you leave our web site and the Company does not exercise control over any Personal Data or any other information you give to any other entity after you have left our web site.

Data Transfer & Sharing

Where we consider it necessary or appropriate for the purposes of data storage or processing or providing any service or deliverable on our behalf to you, we may transfer, store, process or disclose Personal Data to affiliated companies, service providers, professional advisers, business partners or other third parties located within or outside Malaysia where such transfer is necessary for the purposes described in this Notice.

The Company shall take reasonable steps to ensure that any recipient of Personal Data located outside Malaysia is subject to obligations of confidentiality and security standards comparable to those required under applicable data protection laws and regulations.

Retention of Personal Data

The Company shall retain Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal, regulatory, tax, accounting or reporting obligations, or to protect the Company's legal interests.

Upon expiry of the applicable retention period, the Company may securely destroy, delete, anonymize or otherwise dispose of the Personal Data in accordance with its internal policies and applicable laws.

Your Rights of Access and Correction

You have the right to request access to, and correction of Personal Data held by us and in this respect, you may:

• check whether we hold or use such Personal Data and request access to such date;
• request that we correct any Personal Data that is inaccurate, incomplete or out-of-date;
• request that we specify or explain its policies and procedures in relation to data and types of Personal Data handled by us;
• request to withdraw your consent to the processing of your Personal Data, subject to legal, regulatory and contractual restrictions; and
• request that the Company cease or limit the processing of your Personal Data for direct marketing purposes.

Marketing Communications

Where you have provided your consent, the Company may send you information relating to investment opportunities, products, services, events, promotions, market updates and other communications that may be of interest to you.

You may withdraw your consent to receive such communications at any time by notifying the Company in writing or by following the unsubscribe instructions contained in the relevant communication.

Contact Details

If you have any questions regarding this Notice or wish to exercise any of your rights under the Act, please contact:

Please provide proof of your identity, address and sufficient information to enable us to identify you when submitting your request to us. The Company reserves the right to amend, revise or update this Personal Data and Privacy Notice from time to time. Any such amendment shall take effect upon publication on the Company's website or notification to you through appropriate means.