Privacy Notice

Version 1.0, published and effective 31 August 2026.

1. Introduction

Battrust Investment Bank Limited ("Bank", "we", "us", or "our") is committed to protecting the privacy, confidentiality, and security of your personal data. This Privacy Notice outlines how we collect, hold, process, use, disclose, transfer, retain and otherwise process your personal data in compliance with the laws of Malaysia and regulatory requirements.

Individuals may provide, and may from time to time continue to provide, personal data to the Bank in connection with enquiries, applications, onboarding, the opening, maintenance, operation, review, suspension, restriction, or closure of accounts, custody arrangements, investment advisory services, client-portal access, and other services offered by the Bank. Personal data may also be collected where necessary for the Bank to comply with applicable laws, regulations, guidelines, regulatory requirements, or requests from competent authorities.

The Bank may verify, obtain, or supplement personal data from lawful third-party sources, whether publicly available or privately held, including employers, financial institutions, credit-reporting or due-diligence agencies, the Companies Commission of Malaysia, the Labuan Financial Services Authority, the Malaysian Department of Insolvency, governmental authorities, regulators, and other relevant persons or organisations.

2. Why we process your personal data

We collect, use, disclose, transfer, store, retain, and otherwise process personal data to, among other things: assess and process applications for custody and investment advisory services, accounts, and online access; conduct client onboarding and ongoing due diligence (identity verification, beneficial ownership, source of funds/wealth, tax information); assess the suitability of investment advisory services; operate, monitor, and administer accounts and the client portal; process and execute instructions and transactions; verify the authority of persons acting on a client's behalf; maintain and audit account, transaction, and communication records; calculate and collect fees; perform transaction monitoring, sanctions/PEP/adverse-media screening and other AML/CFT and financial-crime controls; comply with applicable law, regulatory requirements, and lawful requests from competent authorities in Malaysia, Labuan, or elsewhere; manage legal, operational, and cybersecurity risk; establish, exercise, or defend our legal rights; and operate, review, and improve our business, systems, and services.

3. What personal data we collect

Depending on our relationship with you and the services involved, this may include: identity and contact information (name, nationality, date of birth, identification documents, address, phone, email); account and transaction information (account numbers, mandates, beneficial owners, authorised signatories, settlement and payment details, transaction history); financial and suitability information (occupation, income, source of funds/wealth, investment objectives and risk tolerance); compliance and verification information (identity/authority verification, AML/CFT and sanctions-screening results, PEP and adverse-media information); and communications, technical and usage information (correspondence with us, client-portal login and activity records, IP address, device identifiers, cookies).

4. How we collect personal data

We collect personal data directly from you (forms, applications, onboarding documents, the client portal, correspondence); through your use of our services and transactions; from authorised representatives, joint account holders, trustees, or professional advisers connected with you; from banks, custodians, and other service providers; from government, regulatory, and law-enforcement bodies; from sanctions-screening and due-diligence providers; and from publicly available sources where permitted by law.

5. Who we may share it with

Your data is kept strictly confidential. To provide our services and meet legal obligations, we may share personal data with: banks, correspondent banks, custodians, sub-custodians, brokers, and other parties involved in processing transactions or holding assets; our affiliates, professional advisers, auditors, and service providers (including technology, cloud hosting, and cybersecurity providers); persons authorised to act for you (representatives, signatories, trustees); identity-verification, due-diligence, sanctions-screening, and credit-reference providers; governmental, regulatory, tax, judicial, and law-enforcement authorities, including the Labuan Financial Services Authority, where required or reasonably necessary; and, where relevant, parties involved in a merger, acquisition, or similar corporate transaction.

6. Transfers outside Malaysia

Due to the international nature of our business, banking relationships, and technology infrastructure, personal data may be transferred to, stored in, or processed in jurisdictions outside Malaysia, including by overseas banks, custodians, and service providers. Where this occurs, the Bank takes reasonable steps to ensure the transfer is carried out in accordance with applicable Malaysian law, including appropriate contractual, technical, or organisational safeguards.

7. Security

We maintain and periodically review technical, organisational, administrative, and physical security measures appropriate to the personal data we process, including access controls, authentication procedures, secure storage, and system monitoring. Access to personal data is limited to authorised personnel and service providers who require it to perform their duties.

8. How long we keep it

We retain personal data for the duration of your relationship with us and thereafter for as long as reasonably necessary to fulfil the purposes described in this Notice, including meeting legal, regulatory, tax, and record-keeping requirements (including those of the Labuan Financial Services Authority). Where AML/CFT record retention rules apply, we retain relevant records for at least the prescribed period after the end of the relationship. When no longer required, personal data is securely deleted, destroyed, or anonymised.

9. Your rights and choices

Subject to applicable law, you may request access to personal data we hold about you, request correction of data that is inaccurate or out of date, withdraw consent where processing is based on consent, and request that we limit certain use or disclosure of your data, including for direct marketing. To make a request, contact us using the details below. We may need to verify your identity first. Withdrawing consent does not affect the lawfulness of processing already carried out, and may affect our ability to continue providing certain services.

10. Direct marketing

Where permitted by law, we may use your contact details to send information about our services, publications, and market updates. You may opt out at any time by contacting us or using the unsubscribe facility in the relevant communication. This will not affect essential account, security, transaction, or regulatory communications.

11. Cookies

Our website and client portal may use cookies and similar technologies to operate and secure the site, remember preferences, and understand usage patterns. You may adjust your browser settings to refuse or restrict cookies, though this may affect certain website or portal functions.

12. Changes to this Notice

We may amend this Privacy Notice from time to time to reflect changes in applicable law, regulatory requirements, or our practices. The latest version is published on this page with its version number and effective date. Where a change is material, we will notify you through the client portal, email, or another appropriate channel.

13. Contact us

Questions about this Privacy Notice, or requests to exercise your rights, can be directed to our Data Protection Officer / Head of Compliance:

Battrust Investment Bank Limited
Lot F17, First Floor, Paragon Labuan, Jalan Tun Mustapha, 87000 Federal Territory of Labuan
Telephone: 087-413161
Email: compliance@battrustinvestment.com