Privacy Policy

Personal Data Protection and Privacy Policy

This Personal Data Protection Policy (“Policy”) has been prepared pursuant to the Personal Data Protection Act 2010 of Malaysia (the “PDPA”) to explain what personal data Alpha Well Ltd. may collect, use or disclose and sets out how Alpha Well Ltd. will handle personal data in accordance with the PDPA and the laws of Malaysia.

This Policy explains:

• The type of personal data we collect and how we collect it
• How we use your personal data
• The parties that we disclose the personal data to
• Where we transfer your personal data
• The choices we offer, including how to access and update your personal data

For the avoidance of doubt, this Privacy Policy is applicable only if you are an individual. This Policy is also intended to provide corporate and institutional customers (collectively “institutional customers”) with sufficient information to allow them to provide notice to relevant individuals and obtain consent from relevant individuals in relation to Alpha Well Ltd.’s collection, use and disclosure of personal data described in this Policy and/or to allow such institutional customers to determine that their disclosure of the personal data described in this Policy to Alpha Well Ltd. is in accordance with PDPA. Such relevant individuals may include the institutional customer’s beneficial owners, partners, committee members, directors, officers or authorized signatories, representatives, dealers, employees, and other natural persons related to the institutional customer.

Where a relevant individual fails to supply relevant information or data or withdraw consent in respect of use and/or disclosure of relevant information or data as described in this Policy, Alpha Well Ltd. may be unable to open or continue to manage the account or establish or continue to provide financial services to the institutional customer. Alpha Well Ltd. will inform the institutional customer of likely consequences where the relevant individual withdraws consent given or deemed to have been given.

For the purposes of this Policy, please note that:

• “Personal data” refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which an organisation has or is likely to have access. This includes unique identifiers (e.g., NRIC number, passport number); as well as any set of data (e.g., name, address, phone number, occupation, etc.) which when taken together would be able to identify the individual.
• “we”, “us” and “our” refers to Alpha Well Ltd. “you” and “your” refers to you

What Kind of Personal Data We Collect And How We Collect It:

In order to enable us to deal with your inquiries, manage your investment portfolios for you or the organisation that you represent and/or to generally provide you with our products and services (“products and services”), we may need to and/or may be required to collect, use, disclose and store (i.e., “process”) personal data and financial information about you, including but not limited to:

1. personal data to establish your identity and background;
2. personal data to establish your financial standing and creditworthiness, where required; and/or
3. personal data that you provide when you apply for any of our products and services.

We may obtain this information from you and/or from a variety of sources, including but not limited to:

1. through your relationship with us, for example information provided by you in application forms, agreements you enter into with us, when using our products or services;
2. through your verbal and written communications with us;
3. from an analysis of the way you use and manage your investment products and/services with us, from the transactions you make and from the payments which are made to/from your investment(s);
4. from third parties connected with you, such as the organisations that you represent or your financial advisers, subject to your prior consent;
5. information and data collected such as images, photographs, videos, CCTV footage, voice recordings when you participate in events organised by Alpha Well Ltd., such as functions, seminars or contests; and/or
6. from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

How We Use Your Personal Data

We may use your personal data for one or more of the following purposes:

1. to confirm and verify your identity;
2. to assess your application(s) /inquiry(ies) for our products and services;
3. to process your transactions in relation to your investment(s) in any of our products and services;
4. to manage and maintain your investment(s) portfolios/accounts with us;
5. to better manage our business and your relationship with us;
6. to notify you about benefits and changes to the features of products and services;
7. to respond to your enquiries and complaints and generally to resolve disputes;
8. to post your photograph and other visual images of you on Alpha Well Ltd.’s intranet, websites and publications;
9. to update, consolidate and improve the accuracy of our records;
10. to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
11. to conduct research for analytical and/or statistical purposes;
12. for audit, compliance and risk management purposes;
13. to assess financial and insurance risks;
14. to conduct anti-money laundering checks; for crime detection, prevention and prosecution; and/or
15. for any other purpose that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.

We will ask for your consent before using your personal data for a purpose other than those that are set out in this Policy, in the information memorandums/prospectuses and application forms of our funds, in your agreement(s) with us or in the agreement(s) with our institutional customer(s).

Disclosure of Your Personal Data

As a part of providing you with our products and services and the management and/or operation of the same, we may be required or need to disclose information about you and/or your investment portfolios with us to the following third parties:

1. companies and/or organisations that act as our agents and/or professional advisers;
2. companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions that you have requested;
3. any other person notified by you as authorised to give instructions on your behalf;
4. any third party as a result of any restructuring of your investments or the sale of debts, or the acquisition or sale of any company by Alpha Well Ltd. or its related companies, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and/or
5. any competent authority(ies) and/or regulator(s),

subject at all time to any laws, (including regulations, guidelines and/or obligations) applicable to Alpha Well Ltd..

We will otherwise treat your personal data as private and confidential and will not disclose your information to anyone outside Alpha Well Ltd. except:

1. where you have given permission;
2. where we are required or permitted to do so by law, regulations or guidelines;
3. where required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over Alpha Well Ltd.;
4. where we may transfer rights and obligations under this agreement;
5. where we are required to meet our obligations to any relevant regulatory authority.

Security of Your Personal Data

Alpha Well Ltd. places great importance on ensuring the security of your personal data. We regularly review and implement up-to-date technical and organisational security measures when processing your personal data.

Employees of Alpha Well Ltd. are trained to handle the personal data securely and with strict confidentiality, failing which they may be subject to disciplinary action.

Retention of Your Personal Data

Alpha Well Ltd. will retain your personal data in compliance with this Policy, in the terms and conditions of the trust deeds of our funds, in your agreement(s) with us or in the agreement(s) with the institutional customer:

1. for the duration of your relationship with us;
2. for such period as may be necessary to protect the interests of Alpha Well Ltd. and/or its customers as may be deemed necessary; and/or
3. where otherwise required by the law.

Transfer of Your Personal Data Outside Of Malaysia

Our information technology storage facilities and servers may be located in other jurisdictions outside of Malaysia. This may include, but not limited to, instances where your personal data may be stored on servers located outside Malaysia. In addition, your personal data may be disclosed or transferred to entities located outside Malaysia or where you access the Site from countries outside Malaysia. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Malaysia under the laws of Malaysia. You hereby epressly consent to us transferring your personal data outside of Malaysia for such purposes. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of

Malaysia shall not use your personal data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your personal data.

What If Personal Data Provided By You Is Incomplete?

It may be obligatory for you in some instances to provide certain personal data to enable us to process your application or provide you with our products or services. If you are unable to or decline to provide such obligatory personal data, we may not be able to process your application or provide you with the said products or services.

Your Rights To Access And Correct Your Personal Data

We can assist you to access and correct your personal data provided to us.

Where you wish to have access to your personal data in our possession, or where you are of the opinion that such personal data held by us is inaccurate, incomplete, misleading or where relevant, not up to date, you may make a request to us by contacting us at the address detailed at the end of this Policy.

We will use reasonable efforts to comply with your request to access or correct your personal data within 21 days of receiving your completed request.

Please note that we may withhold access to your personal data in certain situations, for example when we are unable to confirm your identity, where the information reveals personal data about another person, where such information is subject to legal privilege or if such provision of information will be contrary to national interest or if such refusal is permitted under PDPA. Nevertheless, we will notify you of the reason(s) for not being able to accede to your request, subject to any legal or regulatory constraints.

Please also note that Alpha Well Ltd. may use its discretion in allowing the corrections requested and/or may require further documentary evidence of the new information to avoid fraud and inaccuracy.

You can also assist us to keep your personal data (such as your current mailing address) up to date, as it will enable us to serve you better.

Enquiries/Complaints/Communication

If you have any questions about this Privacy Policy, or have any further queries, or would like to make a complaint or data access or correction request in respect of your personal data, you may contact us at the contact details below:

ALPHA WELL LTD.

Mailing Address : Level 4, Unit 350-407, Office A, Labuan Times Square, Jalan Merdeka, 87000 Federal Territory of Labuan, Malaysia.

Attention : Data Protection Officer

Email address : support@alphawell.co