Privacy Notice

1. INTRODUCTION

1.1 This Privacy Notice is issued pursuant to the Personal Data Protection Act 2010 (“PDPA”) of Malaysia.

1.2 Catenary Capital Sdn Bhd (“Catenary Capital”, “we”, “our” or “us”) is committed to protecting the personal data of individuals in accordance with applicable data protection laws.

1.3 This Privacy Notice sets out the manner in which we collect, use, process, disclose, store and otherwise handle personal data in connection with our business as an institutional real estate investment management platform.

1.4 By providing your personal data to us, accessing our website, or engaging with us in any capacity, you acknowledge that you have read and understood this Privacy Notice and consent to the processing of your personal data as described herein.

2. DEFINITION OF PERSONAL DATA

2.1 “Personal Data” refers to any information in respect of commercial transactions that relates directly or indirectly to an individual who is identified or identifiable from that information.

2.2 Personal Data processed by us may include, but is not limited to:

(a) Name, identification number (NRIC or passport), nationality and date of birth;

(b) Residential and correspondence address;

(c) Email address and telephone number;

(d) Employment details and professional background;

(e) Financial and investment-related information;

(f) Bank account details (where applicable);

(g) Know-Your-Client (KYC) and Anti-Money Laundering (AML) documentation;

(h) Technical information such as IP address, browser type, and website usage data; and

(i) Any other information voluntarily provided to us.

3. SOURCES OF PERSONAL DATA

3.1 Personal Data may be collected:

(a) Directly from you through forms, correspondence, subscriptions, enquiries or meetings;

(b) During investor onboarding and due diligence processes;

(c) Through our website, including via cookies and analytics tools;

(d) From publicly available sources;

(e) From professional advisers, counterparties, regulators, or affiliated entities; and

(f) From third parties authorised by you.

4. PURPOSES OF PROCESSING

4.1 We process Personal Data for purposes including, but not limited to:

4.1.1 Business and Operational Purposes

(a) Responding to enquiries and communications;

(b) Managing investor and business relationships;

(c) Administering investment mandates and transactions;

(d) Conducting financial analysis and investment assessment;

(e) Managing contracts and service engagements.

4.1.2 Regulatory and Compliance Purposes

(a) Conducting KYC and AML checks;

(b) Assessing investor accreditation status;

(c) Meeting regulatory obligations under the Securities Commission Malaysia and other authorities;

(d) Complying with legal, tax, accounting, and reporting requirements;

(e) Supporting Shariah-compliant mandate processes, where applicable.

4.1.3 Communication and Engagement

(a) Providing updates on our investment strategies and activities;

(b) Sending invitations to briefings, meetings or events;

(c) Distributing research, thought leadership, or corporate communications.

4.1.4 Website and Security Purposes

(a) Monitoring website performance and usage;

(b) Improving digital functionality and user experience;

(c) Ensuring system integrity and cybersecurity.

4.2 We will not process Personal Data for any purpose other than those stated above except where required or permitted by law.

5. DISCLOSURE OF PERSONAL DATA

5.1 Personal Data may be disclosed to the following parties where necessary:

(a) Regulatory authorities and government agencies;

(b) Professional advisers including legal, tax, accounting and audit firms;

(c) Financial institutions and custodians;

(d) Service providers, technology vendors and data processors;

(e) Joint venture partners and affiliated entities;

(f) Counterparties involved in investment transactions.

5.2 All disclosures are made subject to appropriate confidentiality obligations and data protection safeguards.

6. TRANSFER OF PERSONAL DATA OUTSIDE MALAYSIA

6.1 Where necessary for business, regulatory or operational purposes, Personal Data may be transferred to jurisdictions outside Malaysia.

6.2 In such cases, we will take reasonable steps to ensure that the receiving party provides a level of protection comparable to that required under the PDPA.

7. DATA SECURITY

7.1 We implement appropriate technical and organisational measures to protect Personal Data against loss, misuse, unauthorised access, disclosure, alteration, or destruction.

7.2 Access to Personal Data is restricted to authorised personnel on a need-to-know basis.

8. RETENTION OF PERSONAL DATA

8.1 Personal Data will be retained only for as long as necessary to:

(a) Fulfil the purposes stated in this Privacy Notice;

(b) Comply with legal, regulatory or contractual obligations;

(c) Resolve disputes and enforce agreements.

8.2 When Personal Data is no longer required, it will be securely destroyed or anonymised.

9. YOUR RIGHTS

9.1 Subject to the PDPA, you have the right to:

(a) Request access to your Personal Data;

(b) Request correction of inaccurate or incomplete Personal Data;

(c) Withdraw your consent to the processing of your Personal Data, subject to contractual and legal limitations;

(d) Limit the processing of your Personal Data in certain circumstances.

9.2 Requests for access or correction must be made in writing.

9.3 A reasonable administrative fee may be charged for access requests, as permitted under the PDPA.

10. FAILURE TO PROVIDE PERSONAL DATA

10.1 Where Personal Data is required for regulatory compliance, contractual performance, or due diligence purposes, failure to provide such data may result in:

(a) Inability to onboard you as an investor;

(b) Inability to respond to enquiries;

(c) Inability to fulfil contractual obligations; or

(d) Termination of existing arrangements where legally required.

11. COOKIES

11.1 Our website may use cookies and similar tracking technologies to enhance user experience and analyse website traffic.

11.2 You may disable cookies via your browser settings; however, certain website functionalities may be affected.

12. AMENDMENTS TO THIS PRIVACY NOTICE

12.1 We reserve the right to amend this Privacy Notice from time to time to reflect changes in legal, regulatory, or operational requirements.

12.2 The updated version will be published on our website and shall take effect upon publication.

13. CONTACT DETAILS

For any enquiries, requests for access or correction, or withdrawal of consent, please contact:

Data Protection Officer
Catenary Capital Sdn Bhd
Level 9, Integra Tower
348 Jalan Tun Razak
50400 Kuala Lumpur
Malaysia

Email: info@catenarycapital.com
Website: www.catenarycapital.com