Blackstone Trustee Berhad (“Blackstone”, “we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, store, and otherwise process personal data in connection with our website, enquiries, onboarding, and related services.

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This Privacy Policy is intended to be read together with any engagement letters, mandate documents, application forms, or other notices that we may provide to you from time to time.

This Privacy Policy applies to personal data processed by us in connection with:

• visits to our website;

• enquiries submitted through our website or by email;

• requests for information, onboarding, or service-related communications;

• trustee, custody, client money account, controlled disbursement, governance, reporting, and related administrative services; and

• dealings with clients, prospective clients, beneficial owners, authorised representatives, counterparties, professional advisers, and service providers.

The types of personal data we may collect and process include, where relevant:

• name;

• company / organisation name;

• job title or role;

• email address;

• telephone number;

• correspondence details;

• identification or verification information;

• information contained in enquiry forms, onboarding forms, instructions, and supporting documents;

• information relating to authorised signatories, approval rights, and reporting contacts;

• transaction-related references and records;

• technical information collected through website usage, such as IP address, browser type, device information, and website interaction data.

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Where required for onboarding, compliance, or service delivery, we may also collect supporting documents and records relevant to identity verification, authority, source documents, or other information reasonably necessary for the relevant engagement.

We may collect personal data:

• directly from you;

• from forms, emails, calls, meetings, or other communications with you;

• from your employer, organisation, or authorised representatives;

• from counterparties, professional advisers, banks, financial institutions, or service providers involved in the relevant arrangement;

• from publicly available sources; and

• automatically through your use of our website, including through cookies or similar technologies, where applicable.

We may collect personal data:

• directly from you;

• from forms, emails, calls, meetings, or other communications with you;

• from your employer, organisation, or authorised representatives;

• from counterparties, professional advisers, banks, financial institutions, or service providers involved in the relevant arrangement;

• from publicly available sources; and

• automatically through your use of our website, including through cookies or similar technologies, where applicable.

We may disclose personal data, where relevant and subject to applicable law, to:

• our directors, officers, employees, and authorised personnel;

• professional advisers, including legal, tax, audit, compliance, and other consultants;

• banks, financial institutions, payment-related parties, custodians, and service providers;

• technology, hosting, document management, or administrative service providers;

• counterparties and authorised stakeholders involved in the relevant arrangement;

• regulators, governmental authorities, law enforcement agencies, courts, tribunals, or other authorities; and

• any other person where disclosure is required, permitted, or reasonably necessary under the relevant mandate, engagement, or applicable law.

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We do not sell personal data.

Our website may collect certain technical and usage information automatically, such as IP address, browser type, device information, pages visited, and interaction data. This information may be used for website administration, security, analytics, troubleshooting, and service improvement.

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Where cookies or similar technologies are used, they may help us operate the website, improve user experience, and understand website usage. You may control cookies through your browser settings, although disabling certain cookies may affect website functionality.

Where necessary for service delivery, administration, storage, or support, personal data may be transferred to, stored in, or accessed from locations outside Malaysia, subject to applicable legal requirements and appropriate safeguards.

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Where required by law, consent or other lawful basis for such transfer will be obtained or relied upon as applicable.

We take reasonable practical steps to protect personal data from loss, misuse, unauthorised access, disclosure, alteration, or destruction. These measures may include administrative, organisational, technical, and physical safeguards, access controls, recordkeeping controls, and confidentiality procedures.

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However, no transmission or storage system can be guaranteed to be completely secure. You should take appropriate steps to protect information transmitted to us.

We retain personal data only for as long as necessary for the purposes for which it was collected, for the administration of the relevant engagement, for recordkeeping and audit trail purposes, or as required or permitted by law, regulation, internal governance standards, or legitimate business needs.

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When personal data is no longer required, we may securely delete, destroy, anonymise, or de-identify it, where appropriate.

Subject to applicable law, you may have rights to request access to, correction of, or limitation on the processing of your personal data, and to make enquiries or complaints regarding our handling of personal data.

Where consent is relied upon, you may withdraw consent, subject to legal, contractual, and operational limitations. Withdrawal of consent may affect our ability to provide services, respond to requests, or continue certain arrangements.

Our website may contain links to third-party websites or services. We are not responsible for the privacy, security, or content practices of third-party sites. You should review their privacy policies separately.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, website features, or service operations. The updated version will be posted on our website with the revised effective date.

If you have any questions, requests, or concerns regarding this Privacy Policy or our handling of personal data, please contact:

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Blackstone Trustee Berhad
Company No.: 202301015265 (1509187-A)
C-28-3, Level 28, KL Trillion Corporate Tower, Block C,

338 Jalan Tun Razak, 50400 Kuala Lumpur, Malaysia.

Email: support@blackstonetrustee.com
Website: www.blackstonetrustee.com