Personal Data Protection Notice

1. Introduction

FIRST PAVILION CAPITAL SDN. BHD. respects your privacy and is committed to protecting your personal data.

This Personal Data Protection Notice explains how we collect, use, disclose, store and otherwise process personal data in connection with:

Our website.
Investor and business enquiries.
Founder and investment-proposal submissions.
Meetings, events and communications.
Recruitment applications.
Our business relationships.
Our investment-management and corporate activities.

In this Notice, “First Pavilion Capital”, “the Company”, “we”, “us” and “our” refer to FIRST PAVILION CAPITAL SDN. BHD.

2. Personal Data We May Collect

Depending on your interaction with us, we may collect:

Identification and contact information

Name.
Email address.
Telephone number.
Correspondence address.
Nationality and country of residence.
Identity-document information, where legally required.

Professional and business information

Employer or organisation.
Job title and professional background.
Business contact details.
Directorship, shareholding or ownership information.
Information contained in business plans, pitch decks and investment proposals.

Investor-related information

Where necessary for eligibility, onboarding, due diligence or regulatory purposes:

Investor classification.
Investment experience.
Source-of-funds or source-of-wealth information.
Financial and investment information.
Tax-residency information.
Know-your-customer and anti-money-laundering information.
Information about authorised representatives and beneficial owners.

Website and technical information

IP address.
Browser type.
Device type.
Operating system.
Website activity.
Referring website.
Cookie identifiers.
Date and time of access.
Approximate location derived from an IP address.

Communication information

Emails and correspondence.
Meeting notes.
Enquiry records.
Event registrations.
Feedback and complaints.
Marketing preferences.

Recruitment information

Curriculum vitae.
Academic and employment history.
Professional qualifications.
References.
Salary information.
Interview and assessment information.

3. How We Collect Personal Data

We may obtain personal data:

Directly from you.
Through our website and online forms.
From your employer, organisation, representative or adviser.
From companies seeking investment.
From investors and business partners.
From regulatory and government authorities.
From professional advisers and service providers.
From public records, corporate registries and publicly accessible sources.
Through cookies, analytics services and similar technologies.
During meetings, conferences and business events.

Where you provide personal data about another individual, you confirm that you are authorised to provide that information and have informed the individual about this Notice where required.

4. Purposes of Processing

We may process personal data to:

Respond to enquiries.
Assess investment proposals and business opportunities.
Conduct preliminary reviews, evaluation and due diligence.
Communicate with founders, investors, advisers and business partners.
Determine investor eligibility.
Carry out investor onboarding.
Verify identity and conduct compliance checks.
Comply with anti-money-laundering, counter-terrorism-financing and sanctions requirements.
Administer funds, investments and investor relationships.
Manage portfolio-company relationships.
Prepare reports and business records.
Organise meetings and events.
Recruit and assess potential employees, interns or contractors.
Protect our website, systems, personnel and property.
Detect or prevent fraud, misconduct and security incidents.
Establish, exercise or defend legal rights.
Satisfy legal, regulatory and reporting obligations.
Improve our website and services.
Send corporate updates or marketing communications where permitted.
Carry out internal administration, risk management, audit and governance.

5. Whether Providing Data Is Mandatory

Some personal data is requested voluntarily.

However, certain information may be required to:

Respond meaningfully to your enquiry.
Evaluate an investment proposal.
Confirm eligibility for an investment opportunity.
Complete onboarding or due diligence.
Enter into or perform an agreement.
Comply with applicable legal and regulatory requirements.

Where required information is not provided, we may be unable to continue the relevant process, provide access to information, establish a business relationship or accept an investment application.

6. Disclosure of Personal Data

We may disclose personal data, where appropriate, to:

Companies within our corporate group.
Funds, investment vehicles and portfolio companies associated with us.
Directors, officers, employees and authorised representatives.
Fund administrators, custodians, trustees and banks.
Auditors, lawyers, tax advisers, consultants and other professional advisers.
Information-technology, website, cloud, cybersecurity and data-storage providers.
Know-your-customer, screening and verification providers.
Regulators, government agencies, law-enforcement bodies and courts.
Prospective purchasers, investors or transaction parties in connection with a corporate transaction.
Other parties authorised by you or permitted by law.

We do not sell personal data to advertisers.

7. International Transfers

Some service providers, group companies or recipients may be located outside Malaysia.

Where personal data is transferred outside Malaysia, we will take reasonable steps to ensure that the transfer is conducted in accordance with applicable Malaysian personal-data-protection requirements and that appropriate safeguards are applied.

8. Security

We apply reasonable administrative, organisational, physical and technical measures intended to protect personal data against:

Loss.
Misuse.
Unauthorised access.
Unauthorised disclosure.
Alteration.
Accidental destruction.
Malicious activity.

No internet transmission or storage system is completely secure. We therefore cannot guarantee absolute security.

9. Retention

We retain personal data only for as long as reasonably necessary for:

The purposes described in this Notice.
Our legitimate business and record-keeping needs.
Compliance with contractual, legal and regulatory obligations.
Handling disputes or legal claims.

When personal data is no longer required, we will take reasonable steps to delete, destroy or anonymise it, subject to legal and technical limitations.

10. Your Rights

Subject to applicable law and any permitted exceptions, you may request to:

Access personal data held about you.
Correct inaccurate or incomplete personal data.
Withdraw consent previously provided.
Limit or prevent processing in certain circumstances.
Stop receiving direct-marketing communications.
Request data portability where the legal right applies.
Obtain information concerning how your data is processed.

We may need to verify your identity before processing a request.

Some requests may be restricted where fulfilling them would conflict with applicable law, regulatory obligations, legal privilege, confidentiality duties or the rights of another person.

11. Direct Marketing

We may send corporate news, event invitations, industry insights or other communications where permitted.

You may unsubscribe at any time by:

Using the unsubscribe link in an email.
Contacting us at [PRIVACY@DOMAIN.COM].
Updating your communication preferences where that functionality is available.

Opting out of marketing does not prevent us from sending administrative, contractual, regulatory or transaction-related communications.

12. Cookies

Our website may use cookies and similar technologies to:

Operate and secure the website.
Remember visitor preferences.
Understand website performance.
Measure website usage.
Improve content and functionality.

Further information is available in our Cookie Notice.

13. Children

Our website and services are not intended for children.

We do not knowingly collect personal data from children through this website. A parent or guardian who believes a child has provided personal data should contact us.

14. Third-Party Websites

Our website may contain links to websites operated by other organisations.

We are not responsible for the privacy practices or content of those websites. Visitors should review the privacy notice of each third-party website they access.

15. Changes to This Notice

We may update this Notice from time to time.

The updated version will be published on this page with a revised “Last updated” date. Material changes may also be communicated through another appropriate channel.

16. Contact and Data Requests

Questions, complaints and requests concerning personal data may be directed to:

Privacy Contact / Data Protection Officer
FIRST PAVILION CAPITAL SDN. BHD.
Email: info@fpcapital.com
Telephone: +603-2740 3333
Address: Suite 23.02, 23rd Floor,
Menara JKG, No. 282,
Jalan Raja Laut,
50350 Kuala Lumpur

Where the organisation meets the applicable thresholds, a DPO must be appointed. Current official guidance identifies thresholds including processing personal data relating to more than 20,000 individuals, sensitive or financial information relating to more than 10,000 individuals, or conducting regular and systematic monitoring.