This Privacy Policy sets out how Alta Sdn. Bhd. (formerly known as Fundnel Technologies Sdn. Bhd. (Company No.: 201701014864 (1229029-H)) ("Alta MY") manages and information or Personal Data (as defined in the Personal Data Protection Act 2010 of Malaysia and related legislation (collectively, the “PDPA”) as updated from time to time) you may provide when you access and use this Website or any of Alta MY's Services.

This Privacy Policy forms part of the Website Agreements together with the Terms of Use, and all capitalized terms that are used but not defined in this Privacy Policy have the meaning given to them in the Terms of Use. We reserve the right to change, modify, add, or delete any part of this Privacy Policy at our sole discretion at any time.

In accessing or using the Website or any Service, you agree to be bound by, and will be deemed to have read, understood, and agreed to the practices and policies outlined in this Privacy Policy, as updated from time to time. If at any time you disagree with any part of this Privacy Policy, please promptly discontinue your access to or use of the Website or Services. Please also note that if you do not provide us with any of the information we request, or withdraw your consent to us collecting and using your Personal Data, we may not be able to provide, or continue providing you with, access to or use of the Website or Services.

If you access or use the Website or Services on behalf of another individual (such as your child) or an entity (such as your employer), you represent that you are authorised by such individual or entity to (i) accept this binding Privacy Policy on such individual’s or entity’s behalf, and (ii) consent on behalf of such individual or entity to our collection, use, and disclosure of such individual’s or entity’s information as described in this Privacy Policy.

This Privacy Policy does not apply to Third Party Sites you may access through, or in the course of your use of, the Website or Services. Your rights in relation to those third parties will be governed entirely by the privacy statements or terms and conditions of those Third Party Sites.

For purposes of this Privacy Policy, “Personal Data” has the same meaning as set out in the PDPA and generally refers to information in respect of commercial transactions that can identify you when taken alone or together with other information. This includes information such as your name and contact details.

We collect Personal Data through various means, including when you:

- voluntarily provide the same to us;
- contact us or request that we contact you;
- access or use the Website;
- access, use, or request for any Services; and
- interact with any of our employees.

Alta MY shall not knowingly collect or attempt to collect your Personal Data through fraudulent, unlawful, or deceptive practices.

You hereby acknowledge, confirm and consent that we may collect, record, hold, store and/or process your personal data for the purposes of our business, including but not limited to the following:

- to verify your identity as required by the Securities Commission Malaysia and any applicable law;
- to enable us to perform our contractual or other obligations to you or any other person accessing or using the Website or Services;
- to comply with any compliance and disclosure requirements of any and all governmental and /or quasi government departments, agencies, regulatory and/or statutory bodies;
- to comply with any legal obligation binding on us under any law, rule, regulation, by-law, order, guideline, directive, policy and such other requirements in force and as amended from time to time;
- for the purposes of record-keeping in the ordinary course of our business;
- to operate, monitor, improve, or administer the Website or Services;
- to provide you with access to the Website;
- to provide you with the Services or any other services you may request;
- to respond to or otherwise contact you and process your requests or complaints; and
- for any other purpose relating to activities on the Platform that a reasonable person would consider appropriate in the circumstances.

Alta MY shall not knowingly use your Personal Data for, or to facilitate, any fraudulent, unlawful, or deceptive purpose.

You hereby acknowledge, confirm and consent that we may disclose your Personal Data to our affiliates or to third parties, including but not limited to our trustee, banks, Issuers, agent, contractor, supplier, professional adviser where:

- necessary or otherwise reasonably required to facilitate the investment process (e.g., verification of identity by trustee, bank or company secretary), to maintain or provide continued access to the Website, the Services, or any other services you may request;

- necessary or otherwise reasonably required for Alta MY to comply with its legislative or regulatory obligations, any request from a regulator, government body, or other authority, or Alta MY's own processes and policies;

- necessary or otherwise reasonably required for Alta MY to perform its obligations under the Website Agreements or other agreements binding upon it;necessary or otherwise reasonably required to respond to you, contact you, or otherwise address your requests or complaints;

- Alta MY has reason to believe that doing so will be appropriate or necessary for it to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Website, Alta MY's interests, or any Alta MY employee;

- Alta MY is the subject of a takeover and your personal information forms part of Alta MY's assets to be transferred to the acquiring entity; oryou disclose such information to third parties in the course of accessing or using the Website.

You are responsible for maintaining the accuracy of the Personal Data you submit to us. If your Personal Data changes, you may correct it, delete inaccuracies, or amend it by making the relevant changes in your account or by contacting us at enquiry@alta.exchange. We will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. If you provide any information that is or becomes, or that we may reasonably suspect is, untrue, inaccurate, out of date, or incomplete, we may at our sole discretion discontinue your access to or use of the Website or Services.

There may be circumstances where Alta MY will not correct, delete, or update your Personal Data. The full list is set out in s 36(1) of the PDPA and include situations where we are:

- not supplied with enough information as we would reasonably require to verify the identityof the owner of the Personal Data;
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- unable to verify whether your Personal Data is inaccurate, incomplete, misleading or not up-to-date; or
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- unable to verify whether the correction to yourPersonal Data is accurate, complete, not misleading or up-to-date.

We may from time to time be required to transfer Personal Data collected in accordance with this Privacy Policy to locations outside Malaysia (e.g., due to the physical locations of our servers). If such transfer is required, you hereby acknowledge and consent to such transfer and Alta MY will comply with its obligations under the PDPA for as long as the Personal Data remains in Alta MY's possession or under Alta MY's control during the transfer. Alta MY will also take appropriate steps to ensure that the recipient located outside Malaysia is legally obliged (e.g., through contractual obligations) to provide to the Personal Data with a level of protection comparable to that required under the PDPA.
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We will retain your Personal Data for as long as required for the purpose(s) for which it was collected and for our compliance with legal obligations on recordkeeping imposed upon us as a regulated financial institution under Malaysia law. Generally, we do not retain Personal Data for a period of longer than seven (7) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. We may also aggregate or anonymise your Personal Data solely for analytic purposes. In such a case, you will no longer be identifiable from the aggregated or anonymised Personal Data, and we may retain such data for as longer as we require.

Alta MY has taken reasonable measures to ensure the security of your Personal Data stored with us, whether in electronic or physical form. This includes protecting your Personal Data from improper or unauthorised access, use, disclosure, modification, appropriation, destruction, and loss. Nevertheless, you acknowledge and agree that communications through the Internet are inherently insecure and all Personal Data you transfer to Alta MY via the Internet is done so at your sole risk. Alta MY does not warrant, represent, guarantee, or otherwise assure that the Personal Data you provide will never be accessed, copied, used, or disposed of in breach of Alta MY's security measures, and you agree not to hold Alta MY or any of its affiliates liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, Alta MY will, as far as reasonably possible, promptly notify all affected persons.
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Alta MY is not responsible, and will not be held liable, for any damage or loss, or misuse, theft, or other compromise of Personal Data, arising directly or indirectly from any unauthorised use of or access to any User’s electronic devices used to access or use the Website or Services.

A cookie is a text file that a web page server stores in your local browser cache. Alta MY uses cookies for various purposes, including strictly necessary cookies (required to operate the Website); analytical cookies (to perform analytics on how people access and browse the Website);functionality cookies (that recognise you and enable Alta MY to customise your user experience on the Website); and targeting cookies (that record your visits to and movement on the Website for purposes of making advertisements shown to you more relevant to your interests). Third parties (such as analytics software) may also use cookies for performance or targeting purposes. Alta MY has no control over cookies from third parties.

You may change your browser settings to decline any or all cookies when accessing the Website. You may also delete stored cookies by changing your browser settings. However, please note doing so may adversely affect your access to or use of the Website. For example, you may not be able to fully load all features or functionalities of the Website. Alta MY shall not be held liable for any loss or damage resulting from deletion or rejection of cookies.

Your Internet Service Provider allocates an IP address to your computer so that it may access the Internet. IP addresses may be dynamic (e.g., they change each time you connect to the Internet) or static (e.g., specific to your computer). Alta MY may collect this IP address to facilitate its administration of the Website, including by diagnosing server problems and collecting aggregated information.

Subject to the exceptions referred to in s 32 of the PDPA, you have the right to request a copy of your Personal Data we hold. Please send your request for such a copy to enquiry@alta.exchange. We may impose an administrative charge for this. We will send you your Personal Data within twenty-one (21) days from the date receiving your request. If we cannot do so, we will notify you in writing and provide you with your Personal Data to the best extent possible.
We may also refuse, in writing, your request for your Personal Data if:

- we are not supplied with enough information as we would reasonably require to verify your identity as the owner of the Personal Data;
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- we are not supplied with enough information as we would reasonably require in order to locate your Personal Data;
the burden or expense of extracting your Personal Data is disproportionate to the privacy risk imposed due to your Personal Data;
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- providing access would constitute a violation of an order of a court;
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- providing access would disclose confidential commercial information;

- such access to Personal Data is regulated by another law; or
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- any other reasons set out in s 32 of the PDPA apply.

If you no longer agree to Alta MY using your Personal Data to contact you for non-essential communications (such as promotional and marketing-related information regarding the Services), you may let us know by changing your account settings or sending an email to enquiry@alta.exchange.

You may contact our Data Protection Officer at privacy@alta.exchange should you have any further queries.

You may request that Alta MY deletes your Personal Data under certain circumstances, such as when you withdraw your consent to our use, collection, disclosure, transfer, or storage of your Personal Data as set out in this Privacy Policy. However, please note that we may not always be able to accede fully to such requests, including where we are required to comply with other legal obligations on retaining your Personal Data.
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Please note that should you withdraw consent as described above, Alta MY may not be able to provide you with Services or access to the Website. You acknowledge and agree that Alta MY may cease such access or provision promptly without any liability.

Contact 
‍You may contact us at enquiry@alta.exchange should you have any further queries.

This Privacy Policy is governed by and shall be construed in accordance with the laws of Malaysia. In the event of any dispute arising out of or in connection with this Privacy Policy, such dispute shall be attempted to be resolved amicably between you and members of our senior management team. Unresolved disputes will then be referred to the oversight body comprising our Board of Directors, Chief Executive Officer, and such other person or persons deemed appropriate by Alta MY to be part of the oversight body. Failing this, the dispute shall be submitted to a single arbitrator to be appointed by the parties in dispute or, failing agreement within fourteen (14) days after either party in dispute has given to the other party in dispute a written request to concur in the appointment of an arbitrator, a single arbitrator to be appointed by the Chairman for the time being of the Asian International Arbitration Centre (“AIAC”) and such submission shall be a submission to arbitration in accordance with the Rules of the AIAC as presently in force by which the parties in dispute agree to be so bound. The place of arbitration shall be Kuala Lumpur and the arbitration shall be conducted wholly in the English language. The outcome of the arbitration shall be final and binding on the parties.