This Personal Data & Information Protection Notice (“Notice”) describes and details the Personal Data Policy of Capital Dynamics Asset Management Sdn Bhd (Co. Reg. No. 389773-H) (“CDAM”) with its place of business at 16.01B, Plaza First Nationwide 161, Jalan Tun H.S Lee 50000 Kuala Lumpur, Malaysia, in usage and management of your Personal Data as defined the Personal Data Protection Act 2010 (“PDPA”) as enacted by the Parliament of Malaysia.

In the event of any conflict between the English version and versions of other languages, the English version shall prevail. CDAM shall have the right to modify, update or amend the terms of this Notice at any time by placing the updated Notice on its website. By continuing to communicate with CDAM or by continuing to use CDAM’s services following the modifications, updates or amendments to this Notice shall signify your acceptance of such modifications, updates or amendments.

Collection and Nature of Personal Data

1. “Personal Data” is defined in Section 4 PDPA and also means, inter alia, information about you which you have provided to CDAM, including your name, identity document number, date of birth, marital status, nationality, assets, income, occupation, contact information, email address, investment objectives and restrictions, particulars of your spouse or family members and bank account information and any information which may identify you, your spouse or family members that has been or may be collected, stored, used and processed by CDAM from time to time, in connection with any service, transaction, survey, questionnaire or communication with CDAM.

2. In addition to the Personal Data that you provide to CDAM directly (i.e. during your communications with CDAM and/or when you engage CDAM to provide services), CDAM may also collect your Personal Data from a variety of sources, including but not limited to any events, conferences, seminars or talks organised or sponsored by CDAM.

Impact Resulting from Failure to Supply Personal Data

3. The provision of your Personal Data is voluntary. However, if you do not provide your Personal Data, CDAM may not be able to (i) communicate with you or (ii) provide you the services you require.

Processing of Personal Data

4. CDAM may use and process your Personal Data for the purposes relating to the services provided by CDAM of which you have requested from CDAM, and for the business activities of CDAM, including but not limited to:

(a) Communication with you for any purpose;

(b) Internal administrative and management purposes;

(c) Provide information to regulatory and governmental authorities in order to comply with statutory and regulatory requirements;
(d) Compliance with all obligations pursuant to laws governing CDAM.

Other purposes

5. CDAM may also use and process your data for other purposes, including, but not limited to:

(a) send you materials such as reports, write-ups as well as other updates;

(b) distribute and/or disseminate information and/or details of events, seminars, conferences and talks which may be of interest to you;

6. If you do not consent to CDAM processing your Personal Data for the purposes listed in Section 5, please notify CDAM using the contact details stated in Section 9 below.

Transfer of Personal Data

7. As CDAM’s information technology storage facilities and servers may be located in other jurisdictions, your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than Malaysia and you provide your consent for such transfer and processing as necessary for business efficacy and efficiency reasons to the following entities:

Disclosure to Third Parties

8. CDAM may engage other companies, service providers or individuals to perform functions on CDAM’s behalf, and consequently may provide access or disclose to your Personal Data to the third parties such as those listed below (not exhaustive):

(a) information technology (IT) service providers;

(b) data entry service providers;

(c) storage facility providers;

(d) banks and financial institutions;

(e) insurance providers;

(f) any professional advisors and external auditors;

(g) regulatory and governmental authorities in order to comply with statutory and government requirements.
Access, Correction & Withdrawal of Consent Requests and Inquiries

9. Subject to any exceptions under applicable laws, you may at any time hereafter request for access to, or for correction or rectification of your Personal Data or limit the processing of your Personal Data, or withdraw consent in storing your personal data, or for any further information from CDAM by contacting:-

Compliance Officer
16.01B, Plaza First Nationwide
161, Jalan Tun H.S Lee
50000 Kuala Lumpur, Malaysia
Telephone No.: (03) 2070 2106/07/08
Facsimile No.: (03) 2070 6653

10. In respect of your right to access and/or correct your Personal Data, CDAM has the right to refuse the your requests to access and/or make any correction to your Personal Data for the reasons permitted under law.

11. In making your Personal Data available to CDAM, you confirm your consent to the matters as set out in this notice and your consent to CDAM to process your Personal Data for the purposes as mentioned, unless you notify us otherwise in writing.