1. Introduction

Capital Technology and Ventures Limited ("CTV", "we", "us", "our") is the data controller in respect of personal data processed in connection with our business activities. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data relating to clients, prospects, counterparties, and visitors to this website.

CTV is registered in the Federal Territory of Labuan, Malaysia and processes personal data in accordance with applicable data protection legislation across our operating jurisdictions, including:

  • The Malaysian Personal Data Protection Act 2010 (PDPA) and Labuan personal data protection requirements aligned thereto;
  • The Singapore Personal Data Protection Act 2012 (PDPA), where data subjects are located in Singapore;
  • The Hong Kong Personal Data (Privacy) Ordinance (PDPO), where data subjects are located in Hong Kong;
  • The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, where data subjects are located in the United Kingdom; and
  • The Digital Personal Data Protection Act 2023 (DPDP Act), where data subjects are located in India.

By engaging with CTV or using this website, you acknowledge that your personal data will be processed in accordance with this policy.

2. Information We Collect

CTV collects personal data through direct interactions, due diligence processes, and automated means when you use this website.

2a. Contact and Relationship Information

When you submit an enquiry form, correspond with us by email, or engage with CTV in a professional capacity, we collect information including: full name; email address; telephone number; organisation name; job title or role; and the subject matter of your enquiry or mandate.

2b. Due Diligence and KYC/AML Information

For clients and counterparties entering into a transactional or advisory relationship with CTV, we collect — as required by applicable anti-money-laundering (AML) and know-your-customer (KYC) regulations — identity documents (passport, national identity card); proof of address; information on beneficial ownership and control structures; source-of-wealth and source-of-funds documentation; and, where applicable, information on Politically Exposed Person (PEP) status.

2c. Technical Data

When you visit this website, we automatically collect certain technical information: IP address; browser type and version; device type; pages visited and time spent; and referring URL. This data is collected for security, fraud prevention, and website performance purposes.

2d. Marketing and Communication Preferences

Where you have opted in, we hold your contact details and preferences to send you insights, market commentary, and firm updates. You may withdraw this consent at any time by contacting us at ops@captechventures.net.

3. How We Use Personal Data

CTV uses personal data for the following purposes:

  • Servicing client mandates and advisory engagements — to perform our obligations under engagement letters, transactional documentation, and ongoing advisory relationships;
  • KYC/AML and counter-terrorism financing (CTF) compliance — to meet obligations under the Labuan Financial Services Authority (LFSA) framework, partner-bank requirements, and applicable AML/CTF legislation across our operating jurisdictions;
  • Responding to enquiries — to evaluate and respond to prospective client requests and general correspondence;
  • Investor relations — to communicate with existing and prospective investors regarding mandates, structures, and firm developments;
  • Sending insights and updates — where you have opted in, to distribute market commentary, publications, and firm announcements;
  • Legal and regulatory reporting — to comply with lawful requests from courts, regulators, and law enforcement authorities; and
  • Website security and administration — to maintain the security and functionality of this website.

4. Legal Bases for Processing

CTV processes personal data on the following legal bases:

  • Contract performance — processing is necessary for the performance of an engagement or pre-contractual steps taken at your request;
  • Legal obligation — processing is required to comply with AML, KYC, CTF, regulatory reporting, and record-keeping obligations imposed by applicable law;
  • Legitimate interests — processing is necessary for CTV's legitimate business interests, including business development, website security, and fraud prevention, where those interests are not overridden by your rights; and
  • Consent — where you have provided express consent, in particular for receipt of marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Disclosure of Personal Data

CTV does not sell personal data. We disclose personal data only in the following circumstances:

  • Partner banks and financial counterparties — to facilitate transaction execution, credit facilities, collateral transfer arrangements, and other financial structures where your data is required by the counterparty for onboarding or KYC purposes;
  • Professional advisors — including lawyers, auditors, and compliance consultants engaged by CTV, subject to professional confidentiality obligations;
  • Regulators and law enforcement — where disclosure is required by law, court order, or a lawful request from a competent authority; and
  • Service providers — third-party vendors providing IT, hosting, communications, or administrative services, each engaged under written agreements containing appropriate confidentiality and data protection obligations.

6. International Data Transfers

CTV operates across multiple jurisdictions including Labuan, Hong Kong, Singapore, Kuala Lumpur, London, Chennai, and Muscat. Personal data may be transferred between these locations in the ordinary course of our business operations.

Where personal data is transferred to jurisdictions that do not provide an equivalent level of protection to the jurisdiction in which it was collected, CTV implements appropriate safeguards, including Standard Contractual Clauses, intra-group data transfer agreements, or other mechanisms recognised under applicable law. Transfers to partner institutions are subject to contractual protections consistent with applicable data protection requirements.

7. Data Retention

CTV retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum periods:

  • Client records — retained for the duration of the client relationship plus a minimum of seven (7) years following termination, to satisfy AML record-keeping obligations under Labuan requirements, LFSA guidelines, and equivalent obligations in partner jurisdictions;
  • Enquiry and prospect data — retained for 24 months from the date of last contact, unless the enquiry converts to a client relationship, in which case client retention periods apply;
  • Technical and website data — retained for no longer than 12 months unless required for ongoing security or fraud investigations.

Retention periods may be extended where required by law, regulatory direction, or ongoing legal proceedings.

8. Your Rights

Subject to the applicable data protection law in your jurisdiction, you may have the following rights in respect of your personal data:

  • Right of access — to obtain a copy of the personal data we hold about you;
  • Right of rectification — to correct inaccurate or incomplete data;
  • Right of erasure — to request deletion of your personal data in certain circumstances;
  • Right to restrict processing — to limit how we use your data pending resolution of a dispute;
  • Right to object — to processing based on legitimate interests or for direct marketing;
  • Right to data portability — to receive your data in a structured, machine-readable format (where processing is automated and based on consent or contract); and
  • Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time.

Please note that AML and regulatory record-keeping obligations may override erasure requests. We will notify you where this is the case. To exercise any of these rights, contact us at ops@captechventures.net.

9. Security

CTV maintains industry-standard administrative, technical, and physical controls to protect personal data against unauthorised access, disclosure, alteration, and destruction. These controls include:

  • Encryption of data in transit using TLS protocols;
  • Role-based access controls limiting data access to personnel with a legitimate need;
  • Regular review of vendor and counterparty security standards; and
  • Incident response procedures for suspected data breaches, including notification to affected individuals and regulators where required by law.

No transmission over the internet is unconditionally secure. CTV cannot guarantee the security of information submitted to this website through public networks.

10. Cookies

This website uses essential cookies only. We do not deploy third-party tracking cookies, behavioural advertising cookies, or retargeting technologies.

Font resources served via Google Fonts may result in requests to Google's servers, which may set cookies in your browser. Such cookies are governed by Google's Privacy Policy. CTV has no control over Google's data practices in this regard.

11. Children

CTV's services are directed exclusively at professional and institutional clients. This website is not intended for, and does not knowingly collect data from, persons under the age of 18.

12. Updates to This Policy

CTV may amend this Privacy Policy from time to time to reflect changes in law, regulatory requirements, or business practice. The effective date at the top of this page indicates when the current version was adopted. Material changes will be notified to clients in writing prior to or upon becoming effective. Visitors to this website are encouraged to review this policy periodically.

13. Contact

Privacy enquiries, data subject rights requests, and complaints should be directed to:

  • Email: ops@captechventures.net
  • Post: Capital Technology and Ventures Limited, Office Suite 1677, Level 16(A), Main Office Tower, Financial Park Labuan, Federal Territory of Labuan, Malaysia

We will acknowledge your request within 5 business days and respond substantively within the period prescribed by applicable law (or within 30 days where no specific period is prescribed).