Astute Fund Management Berhad (“ASTUTE”), (“we”, “us” or “our”) is committed to protecting the privacy of our investors and handling personal data responsibly.

This Notice explains how we collect, use, disclose, retain and protect your personal data in connection with your MasterAccount Application Form, investment account and dealings with us.

In this Notice, “you” or “your” refers to the principal account holder and/or joint account holder, where applicable. If you provide personal data relating to another individual, you must ensure that you are authorised to do so and that the individual has been informed of this Notice where required by applicable laws.

1. About This Notice

1.1 This Notice is issued pursuant to Section 7 of the Personal Data Protection Act 2010 (“PDPA”) and its applicable amendments.

1.2 This Notice should be read together with ASTUTE’s Privacy Notice available on our Website. It provides additional information relating to the collection and processing of personal data in connection with your MasterAccount Application Form.

1.3 You may obtain a copy of this Notice by contacting our Customer Service at:

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

1.4 This Notice applies to personal data relating to individual applicants. The PDPA may not apply to personal data relating to corporate applicants, subject to applicable laws and regulations.

2. 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 identification and contact information, such as your name, identification card or passport number, date of birth, nationality, address, telephone number and email address;
• Employment and occupation information;
• Financial and investment information, including income, assets, bank account details, investment account details, investment holdings and transaction records;
• Information required for customer due diligence, know-your-customer (“KYC”) and anti-money laundering and counter-terrorism financing (“AML/CFT”) purposes;
• Information relating to your investment objectives, risk profile, financial circumstances and investment needs, where applicable;
• Information provided in application forms, declarations, correspondence and supporting documents;
• Information relating to your authorised representatives, joint account holders or other persons acting on your behalf;
• Information relating to enquiries, complaints and other communications with us;
• Information collected through telephone calls, including call recordings where applicable; and
• Any other personal data reasonably necessary for the purposes described in this Notice or as required or permitted by applicable laws and regulations.

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

3. Purposes of Collecting and Processing Your Personal Data

We may collect and process your personal data to:

• Assess and process your application and establish or maintain your investment account;
• Provide and administer our products and services;
• Process subscriptions, redemptions, switches, transfers and other investment transactions;
• Verify your identity and conduct KYC, customer due diligence and AML/CFT checks;
• Assess your investment objectives, risk profile and financial circumstances, where applicable;
• Communicate with you regarding your account, transactions, products, services and administrative matters;
• Prevent, detect and investigate fraud, money laundering and other unlawful activities;
• Manage our business operations, systems, records, risk and internal controls;
• Handle enquiries, complaints and requests relating to your personal data;
• Comply with applicable laws, regulations, regulatory requirements and directions issued by relevant authorities, including the Securities Commission Malaysia, FIMM and EPF/KWSP, where applicable;
• Establish, exercise or defend our legal rights and interests; and
• Carry out any other purpose permitted or required by applicable laws and regulations.

Where permitted by applicable laws, we may also use your personal data to provide information about our products, services, events and promotional activities, subject to your marketing preferences.

4. Sources of Your Personal Data

We may collect your personal data from information provided directly by you through application forms, written instructions, telephone calls, emails and other communications; your authorised representatives, joint account holders, unit trust consultants, distributors or financial advisers; other unit trust management companies, business partners, financial institutions and service providers involved in our dealings with you; regulatory authorities, government agencies and other relevant institutions; publicly available sources; and other sources where permitted or required by applicable laws and regulations.

5. Disclosure of Your Personal Data

We will treat your personal data as confidential. However, we may disclose it, where necessary and appropriate, to:

• Our directors, officers, employees and related entities, where applicable;
• Unit trust consultants, distributors, financial advisers and authorised representatives;
• Custodians, trustees, fund administrators and other parties involved in the administration of investments;
• Banks, financial institutions and payment service providers;
• Information technology, cybersecurity, cloud, hosting and other service providers;
• Auditors, lawyers, accountants, consultants and other professional advisers;
• The Securities Commission Malaysia, FIMM, EPF/KWSP and other regulatory or governmental authorities, where applicable;
• Law enforcement agencies, courts and other parties where required or permitted by law; and
• Other parties where you have provided consent or where disclosure is required or permitted by applicable laws and regulations.

We will take reasonable steps to ensure that third parties handling your personal data on our behalf maintain appropriate confidentiality and security safeguards.

6. Your Rights and Choices

Subject to applicable laws and relevant conditions, you may:

• Request access to your personal data held by us;
• Request the correction of inaccurate, incomplete, misleading or outdated personal data;
• Withdraw your consent where the processing is based on consent;
• Request to limit the processing of your personal data, where applicable; and
• Opt out of receiving direct marketing communications from us.

Requests may be submitted using the contact details in Section 1.3. We may require verification of your identity and may charge applicable fees permitted by law. Withdrawal of consent or restriction of processing may affect our ability to provide certain products or services or maintain your investment account, but will not affect the lawfulness of prior processing.

7. Provision of Personal Data

The provision of certain personal data is necessary for us to process your application, establish or maintain your investment account, process transactions and comply with applicable legal and regulatory requirements. If you do not provide the required personal data, we may be unable to process your application, provide certain products or services, or execute your instructions or transactions. Where provision is voluntary, we will inform you where reasonably practicable.

8. Marketing Preferences

Where permitted by applicable laws, we may contact you regarding our products, services, events and promotional activities. If you do not wish to receive direct marketing communications, contact us at enquiry@astutefm.com.my or 03-2095 9999. You may also use the unsubscribe facility provided in our electronic marketing communications, where available.

You may continue to receive essential non-promotional communications relating to your account, transactions, contractual obligations or regulatory matters.

9. Security of Your Personal Data

We will take reasonable technical, physical and organisational measures to protect your personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction. Where your personal data is processed by service providers on our behalf, we will take reasonable steps to ensure that appropriate security and confidentiality measures are maintained.

10. Retention of Your Personal Data

We will retain your personal data for the duration of your relationship with us and for as long as necessary to fulfil the purposes for which it was collected, comply with applicable legal and regulatory requirements, maintain relevant records, resolve disputes and protect our legal rights and interests.

As a general practice, ASTUTE will retain relevant personal data and records for seven (7) years, unless a longer retention period is required or permitted by applicable laws, regulations or regulatory requirements. When your personal data is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it in accordance with our applicable policies, procedures and legal or regulatory requirements.

11. Cross-Border Transfer of Personal Data

Where necessary, we may transfer or allow access to your personal data outside Malaysia to our service providers, business partners, regulatory authorities or other relevant parties. Where such transfers take place, we will take reasonable steps to ensure that your personal data is protected in accordance with applicable laws and regulatory requirements.

12. Personal Data of Other Individuals

If you provide personal data relating to another individual, including a joint account holder, authorised representative, beneficial owner or any other relevant person, you confirm that you are authorised to provide such information. You should inform the individual about this Notice and obtain any consent required by applicable laws before providing their personal data to us.

13. Personal Data Relating to Minors

You should not provide personal data relating to a minor unless you are the minor’s parent or legal guardian or are otherwise legally authorised to do so. Where required, we may request additional information or consent from the relevant parent or legal guardian before collecting or processing the minor’s personal data.

14. Contact Us

If you have questions, requests or complaints concerning the collection, use, disclosure or handling of your personal data, please contact us:

Customer Service
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

We will endeavour to respond to your enquiries and requests within a reasonable period and in accordance with applicable laws and our internal procedures.

15. Amendments to This Notice

We may amend or update this Notice from time to time to reflect changes in our business operations, products, services, policies, legal requirements or regulatory obligations. The updated version will be made available through appropriate channels, including our Website where applicable.

Last Updated: Sept 2026