Astute does not sell your personal information to third parties. We only disclose or share personal information where permitted or required under applicable laws and regulations, or where necessary to provide our services and fulfil our obligations to you.

1. General

Astute Fund Management Berhad (“ASTUTE”) (“the Company”, “we”, “us” or “our”) is the holder of a Capital Markets Services Licence issued under the Capital Markets and Services Act 2007, authorising ASTUTE to carry out regulated activities including fund management and dealing in securities restricted to unit trusts.

At ASTUTE, we respect the privacy and confidentiality of your personal data and are committed to protecting it in accordance with the Personal Data Protection Act 2010 (“PDPA”), applicable regulations, guidelines and other relevant laws.

This Privacy Notice explains how ASTUTE collects, obtains, uses, discloses, stores, retains and protects your personal data when you interact with us, use our website, apply for or use our products and services, or otherwise provide personal data to us.

This Privacy Notice should be read together with any other notices, terms and conditions, application forms, agreements or contractual documents that may apply to your relationship with ASTUTE.

For the purposes of this Privacy Notice, “personal data” or “personal information” means information relating directly or indirectly to an individual who can be identified from that information, whether alone or in combination with other information in our possession or control.

2. Types of Personal Data We Collect

Depending on the nature of your relationship and dealings with us, we may collect and process personal data including, but not limited to:

• Personal information required to establish your identity and background.
• Financial and investment information, including income, assets and financial circumstances; bank account and payment details; investment account details and account balances; investment holdings and transaction details; and information relating to subscriptions, redemptions, switches and other transactions.
• Compliance and due diligence information, including information required for customer due diligence, know-your-customer (“KYC”) and anti-money laundering and counter-terrorism financing (“AML/CFT”) purposes; risk profile, investment objectives and financial needs, where applicable; information in application forms, declarations and supporting documents; and information obtained from authorised representatives or other persons acting on your behalf.
• Communications and website information, including information relating to complaints, enquiries and communications with us, and technical information collected when you use our website or electronic services, such as IP address, browser type, device information and website usage information.
• Other information reasonably necessary for the purposes described in this Privacy Notice or as required or permitted by applicable laws and regulations.

Where applicable, we may also collect sensitive personal data or other information that is subject to additional legal requirements. Such information will be processed in accordance with applicable laws.

3. How We Collect Your Personal Data

We may collect your personal data from various sources, including:

• Directly from you when you complete account opening or application forms; subscribe to or transact in our products and services; provide information through our website or other electronic channels; communicate with us; submit enquiries, requests or complaints; or participate in surveys, events or other activities organised by us.
• Your authorised representatives, distributors, consultants, agents or other persons acting on your behalf.
• Third parties or institutions involved in providing or administering our products and services, including custodians, trustees, fund administrators, financial institutions and other service providers, where applicable.
• Regulatory authorities, government agencies and other authorised sources; publicly available sources where permitted by law; and information generated through your transactions, account activities and interactions with ASTUTE.
• Other sources where you have provided your consent or where collection is otherwise permitted or required by applicable laws and regulations.

Where we receive personal data about you from another person or organisation, we may use such information for the purposes described in this Privacy Notice or for other purposes permitted or required by law.

4. Purposes for Collecting and Processing Your Personal Data

We may collect, use, process and disclose your personal data to process and assess your application; open, establish, maintain and administer your account and investment relationship; process subscriptions, redemptions, switches, transfers and other investment transactions; and provide, administer and manage our products and services.

We may also use your data to understand your investment objectives, financial circumstances and requirements; conduct KYC, customer due diligence and AML/CFT checks; verify identity; and prevent, detect and investigate fraud, money laundering, terrorist financing and other unlawful activities.

Other purposes include complying with laws, regulations, guidelines, court orders and directions; fulfilling reporting obligations to relevant authorities and institutions, including where applicable the Securities Commission Malaysia, Federation of Investment Managers Malaysia (“FIMM”) and Employees Provident Fund (“EPF/KWSP”); conducting audits, compliance reviews, risk assessments and governance activities; and managing our business operations, internal controls, information systems and business continuity arrangements.

We may further use your data to respond to enquiries and complaints; maintain, update and improve our records, products, services, systems and processes; conduct research, analysis and statistical activities; manage stakeholder relationships; communicate with you regarding your account, transactions, products, services and regulatory matters; send permitted product, service, event or promotional information; protect or enforce our legal rights; appoint and manage service providers and advisers; facilitate corporate transactions; and for any other purpose disclosed to you or permitted or required by law.

Where we intend to use your personal data for a new purpose that is materially different from the purposes stated in this Privacy Notice, we will provide the appropriate notice and, where required, obtain your consent.

5. Disclosure of Your Personal Data

We will treat your personal data as confidential and will only disclose it where necessary for the purposes described in this Privacy Notice, where you have authorised or consented to disclosure, or where disclosure is permitted or required by applicable laws and regulations.

Where necessary, your personal data may be disclosed to ASTUTE’s directors, officers and employees; related corporations or affiliates; distributors, unit trust consultants and authorised representatives; custodians, trustees and fund administrators; banks and financial institutions; EPF/KWSP; the Securities Commission Malaysia, FIMM and other regulatory authorities; government agencies and law enforcement authorities; auditors, lawyers, accountants and other professional advisers; IT, cybersecurity, cloud, technology and other service providers; parties acting on your behalf; parties involved in a corporate transaction; and any other person or organisation where permitted or required by law.

Where we appoint third parties to process personal data on our behalf, we will take reasonable steps to ensure appropriate confidentiality, security and data protection obligations are imposed on them.

6. Marketing and Promotional Communications

Where permitted by applicable laws, ASTUTE may use your personal data to provide information about products, services, events and other communications that may be relevant to you. If you do not wish to receive marketing or promotional communications, you may contact us using the details in this Privacy Notice.

Your request to opt out will not affect communications necessary for the administration of your account, transactions, contractual obligations, regulatory requirements or other non-promotional purposes.

7. Personal Data Provided to Us by Others

If you provide personal data relating to another individual to ASTUTE, you should ensure that you are authorised to provide it and, where required, that the relevant individual has been informed of this Privacy Notice and has provided the necessary consent. This may include information relating to authorised representatives, directors, beneficial owners, joint investors or other relevant persons.

8. If You Do Not Provide Required Personal Data

In certain circumstances, personal data is necessary for us to process your application, establish or maintain your account, process transactions, provide products and services, or comply with legal and regulatory requirements. If you do not provide the required personal data, we may not be able to process your application, open or maintain your account, process your transactions, provide certain products or services, or comply with applicable requirements. Where information is optional, we will inform you where reasonably practicable.

9. Security of Your Personal Data

ASTUTE takes the security and confidentiality of your personal data seriously. We implement reasonable technical and organisational measures to protect it against loss, misuse, unauthorised access, disclosure, alteration, destruction or other unlawful processing.

These measures may include appropriate information security and access controls; restricting access to authorised personnel on a need-to-know basis; physical, technical and organisational safeguards; confidentiality obligations for employees and service providers; employee training and awareness; and periodic reviews of our security measures and controls.

While we take reasonable steps to protect your personal data, no method of transmission or electronic storage can be guaranteed to be completely secure.

10. Retention of Your Personal Data

We retain personal data for as long as necessary for the purposes for which it was collected, to manage your investment account and records, process investment transactions, comply with legal and regulatory requirements, fulfil reporting and record-keeping obligations, resolve disputes and complaints, enforce our agreements, protect our legal rights and interests, or for other purposes permitted or required by law.

As a general practice, ASTUTE retains personal data for seven (7) years in accordance with its applicable retention policy, unless a longer period is required or permitted by law, regulation or legitimate legal, compliance or other purposes. When no longer required, we will take reasonable steps to securely delete, destroy or anonymise the information.

11. Transfer of Personal Data Outside Malaysia

Where necessary for our products and services, business operations or service-provider arrangements, your personal data may be transferred to, stored in or processed outside Malaysia. Where this occurs, ASTUTE will take reasonable steps to ensure the transfer complies with applicable data protection laws and appropriate safeguards are implemented. This may include situations where service providers or technology systems are located or operated outside Malaysia.

12. Your Rights and Choices

Subject to applicable laws and relevant conditions or exceptions, you may request access to personal data held by ASTUTE, and request correction or updating of inaccurate, incomplete, misleading or outdated data. We may verify your identity and may be permitted or required by law to refuse or limit access in certain circumstances.

Where processing is based on consent, you may withdraw consent by contacting us. Withdrawal may affect our ability to provide certain products or services or process certain transactions, but will not affect the lawfulness of prior processing. You may also ask ASTUTE to stop using your data for direct marketing, subject to applicable laws and regulatory requirements. Other rights under applicable laws will be handled in accordance with legal requirements.

13. Website Privacy and Cookies

When you visit the ASTUTE website, we may collect technical and navigational information such as IP address, browser type, device information, pages visited, date and time of access and other information relating to your interaction with our website. We may use this information to operate and maintain the website; monitor and improve its performance, security, usage and functionality; identify and resolve technical problems; and improve the information and services provided.

Our website may use cookies and similar technologies to support functionality, security, performance and, where applicable, analytics. Cookies are small text files stored on your device by your web browser. You may manage or disable cookies through your browser settings, although disabling certain cookies may affect the availability or functionality of website features. ASTUTE handles cookie information in accordance with applicable laws and this Privacy Notice.

14. Data Breaches and Security Incidents

ASTUTE maintains procedures for managing suspected or confirmed personal data breaches and security incidents. Where required by applicable laws or regulatory requirements, we will take appropriate steps to assess, manage and report a breach and notify affected individuals and/or relevant authorities within the applicable timeframe.

15. Accuracy of Your Personal Data

We rely on you to provide accurate, complete and up-to-date personal data. Please inform us promptly of changes to your personal information so that we can update our records. ASTUTE may request supporting documents or additional information where necessary to verify or update your data.

16. Enquiries, Requests and Complaints

If you have questions, concerns, requests or complaints regarding this Privacy Notice or the way ASTUTE handles your personal data, please contact us:

Designated Contact Person: Head of Compliance
Astute Fund Management Berhad
3rd Floor, Menara Dungun, 46, Jalan Dungun, Damansara Heights, 50490 Kuala Lumpur
Telephone: 03-2095 9999
Email: enquiry@astutefm.com.my

When submitting a request, please provide sufficient information for us to identify you and understand the nature of your request. We may request additional information or documents to verify your identity. We will endeavour to respond within a reasonable period and in accordance with applicable laws and our internal procedures.

17. Amendments to This Privacy Notice

ASTUTE may revise or update this Privacy Notice from time to time to reflect changes in our business practices, products and services, applicable laws, regulatory requirements or data protection practices. Where appropriate, the revised Privacy Notice will be published on our website. We encourage you to review it periodically to remain informed about how we collect, use, disclose and protect your personal data.

Your continued use of our website, products or services following publication of an updated Privacy Notice will be subject to the updated Privacy Notice, to the extent permitted by applicable laws.

Last Updated: Sept 2026