At Arctic Tern Advisory Sdn Bhd (Company No. 202401014623 (1560473-K)), we are committed to protecting your privacy in accordance with the Personal Data Protection Act 2010 of Malaysia (“PDPA”).

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; and
• the choices we offer, including how to access and update your personal data.

Privacy Notice

Arctic Tern Advisory Sdn Bhd (“we” or “us”) is committed to protecting your personal data in line with the Personal Data Protection Act 2010 (“PDPA”). This policy explains how we deliver your rights and protections under the PDPA. It may be updated by us occasionally.

This Privacy Notice applies to individuals whose personal data are collected and processed by us (the “data subject”). For the purposes of this Privacy Notice, the term “personal data” is defined as per the Personal Data Protection Act 2010 (“Act”) as follows:

Personal Data refers to any information pertaining to commercial transactions that:

• Is processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
• Is recorded with the intention that it should wholly or partly be processed by such equipment; or
• Is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system.

Personal data relates directly or indirectly to an identified or identifiable data subject from that information, or from that and other information in the possession of a data user. This includes any sensitive personal data and expression of opinion about the data subject but excludes any information processed for the purpose of credit reporting business conducted by a credit reporting agency under the Credit Reporting Agencies Act 2010.

We are committed to preserving the confidentiality, security, and integrity of the personal data you provide. In accordance with the Act, this Privacy Notice outlines how we handle your personal data and inform you of the options available for accessing or restricting our use of your personal data.

1. We may collect and process personal data such as:

• Your name, nationality, date and place of birth, ID/passport number, gender, resident status, marital status, address, contact number, email, dependents, occupation details, income range, net worth, liabilities, source of funds/income, tax information;
• Data from regulators and government agencies; and
• Any other relevant information needed for our legal compliance, services/products.

2. We collect your personal data for the following purposes:

• Assess your application for our services/products;
• Provision of services/products requested by you for facilitating daily operational processes;
• To inform you of new products or services from us or our affiliates through marketing materials, emails, or calls;
• To comply with legal or regulatory requirements or as directed by regulatory or government bodies;
• For risk profiling and conducting money laundering and terrorism financing checks and other background checks;
• To create directories or database whether for publication or not;
• To attend to your enquiries and generally to enable resolution of a concern or complaint;
• For delivery of notices and statements; and
• For such other purposes that is incidental or ancillary or in furtherance to the above purposes.

The personal data collected will be retained by us for the duration permitted/required under Malaysian law, which may extend to periods after termination of your contractual relationship with us.

3. We collect your personal data from various sources, including but not limited to:

• Information you have provided us;
• Information from third parties (such as your authorised representatives, your financial adviser, your agent, your bank, if funds are transferred to and from of your bank account); and
• Information in the public domain.

4. We maintain the security of your personal data as follows:

• We maintain adequate security control systems to safeguard the confidentiality and security of your personal data;
• Access to your personal data by our staff is strictly on a need-to-know basis; and
• Where we appoint third party service providers, agents or contractors to provide services to us, we ensure that these third parties observe similar security measures as adopted by us.

5. We may disclose your personal data to:

• Our directors, officers and dealer’s representatives for purposes relating to your application and use of our services/products;
• Our related, associated or affiliated companies;
• Regulatory bodies such as Bank Negara Malaysia, Securities Commission, Bursa Malaysia Securities Berhad, clearing house and other regulatory bodies which have oversight over us and our activities;
• Any third-party service provider, agent or contractor who have been appointed by us to provide services to us whether in or outside Malaysia subject to sufficient security controls over the information;
• Our auditors, lawyers, consultants and other advisors;
• Parties authorised by you; and
• Any other party to whom such disclosure is required by law or regulatory requirement or pursuant to a Court order notwithstanding that any such persons may be outside Malaysia, for any of the above Purposes or any other purpose for which your personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above Purposes.

6. Your rights and choices

• You have the right to access and request for correction of your personal data which is inaccurate, incomplete or not updated.
• For the above purposes, please contact the personnel whose details are given in the contact information below. In accordance with the Act: -
  • we may charge a fee for processing your request for access; and
  • we may refuse to comply with your request for access or correction.
• If you do not wish to receive marketing/advertisement/promotional material from us, you have the right to request that we stop contacting you or sending you marketing/advertisement/ promotional materials. Such request may be made via email to the contact personnel named below.
• It is obligatory that you supply us with the personal data requested by us. If you choose not to supply us with your personal data or withdraw or limit the use of your personal data, we may reject your application for the services/products requested or we may not be able to continue providing you with the services/products you have requested.

By submitting your personal data to us, you formally agree to the processing of your personal data in accordance with the aforementioned terms.

7. Amendments and Contact

• You will be notified of any material amendments to this Privacy Notice. Such notification may be mailed to you and form part of our monthly statement to you, notified to you via emails and/or accessible from our website at www.arctictern.com.my. If you continue to use our services/products, you shall be deemed to have agreed to accept such changes.
• Complaints or enquiries relating to any matter concerning your personal data can be made to the following personnel:

Arctic Tern Advisory Sdn. Bhd.
Compliance & Legal Department
Unit 10.05, Level 10, Amcorp Tower, Amcorp Trade Centre
18, Persiaran Barat
46050 Petaling Jaya, Selangor Darul Ehsan