Privacy Statement

Sriwijaya Capital Management Pte Ltd (“we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Statement explains how we collect, use, share, disclose and protect your information in accordance with the Personal Data Protection Act 2012 of Singapore.

Personal Information We Collect

We collect Personal Information that is reasonably necessary to deliver our professional services in our business activities. This information may include (but is not limited to):

i. basic personal data (such as your name, date of birth, national insurance number, social security number, address, telephone number(s), e-mail address, occupation and job title);

ii. financial information (such as information relating to your financial health and details of your income and assets); and

iii. any information that you choose to share with us which may be considered personal data.

Use and Disclosure of Personal Information

We will generally use your Personal Information in relation to the provision of professionalservices to you. If considered appropriate we may use your Personal Information for internal communication purposes such as sending you research and investor reports.

Subject to what is permitted at law, we may also disclose your Personal Information to third parties which include:

• Service providers (example external fund administrators, counsels, custodians and consultancy vendors);

• Anybody who represents you, such as finance brokers, lawyers and accountants, advisers, insurers investment/super providers;

• Anyone, where you have provided us consent; and

• Where we are required to do so by law, such as under the Anti-Money Laundering and Courter Terrorism Financing regulations.

We will only enter these types of arrangements or disclose such information where we reasonably believe that the relevant party will only use your Personal Information for the specific purpose for which we supply it to them.

These disclosures may involve overseas storage and other overseas transfer, processing and use of your Personal Information. Further, your data may be disclosed by us to associated firms and vendors which conduct operational, technology and customer service functions in Singapore, Indonesia and other jurisdictions. Prior to transferring your data offshore, we will take appropriate steps to ensure the recipient of the personal data is bound by legally enforceable obligations to provide a standard of protection of the personal data that is at least comparable to the protection under the Singapore Personal Data Protection Act.

Storage of Personal Information Collected

We store all Personal Information collected in secure computer storage facilities, paper-based files and other records, and take steps to protect your Personal Information that we hold from misuse, loss, unauthorised access, modification or disclosure. Organisations who provide support services to us and process your Personal Information on our behalf are required to appropriately safeguard the privacy of the Personal Information provided to them. We may be required by law to maintain records for a significant period of time. However, when we consider information is no longer required or relevant and any legal obligations that may apply to the information held have been met, we will remove details that identify you or we will securely destroy the records.

Updating Personal Information

We aim to maintain up-to-date and accurate personal information. If you believe the personal information that we hold is inaccurate, incomplete or out-of-date, the information will beupdated. We will also take such steps (if any) as are reasonable in the circumstances to give notification of this correction to any third parties to whom it has been previously disclosed by us. If we are unable to accept the changes requested, we will provide you with a written response outlining the reasons for not accepting your request to alter your personal information.

You should keep us informed of any changes to your personal information and promptly advise us of changes when they arise.

Data breach

We have obligations to notify you if there are any data breaches, particularly if the breach may result in significant harm to you or is a wide scale data breach.

Privacy related enquiries

We take the required care when dealing with your personal information. However, if you have any questions or concerns with how we have dealt with your Personal Information, please contact our Privacy Officer at info@sriwijaya.capital. The Privacy Officer will respond as soon as possible confirming receipt of your complaint. Your complaint will be investigated in accordance with our complaints handling policy.

Changes
This Privacy Statement may be updated periodically to reflect changes in our firm’s policies and applicable law. We suggest that you periodically review this Privacy Statement for any update.