Privacy Policy - BRAHM Capital Partners

Last Updated: May 2026

YOUR PRIVACY IS IMPORTANT TO US

It is BRAHM Capital Partners Sdn Bhd’s (“BRAHM,” “we,” “us,” or “our”) policy to respect your privacy regarding any information we may collect while operating our website at https://brahm.capital (the “Website”). As a Malaysia-based private equity investment manager regulated by the Securities Commission Malaysia (SC Malaysia), we are committed to protecting your personal data in accordance with the Personal Data Protection Act 2010 (PDPA) and this Privacy Policy.

This Privacy Policy explains how we collect, use, disclose, protect, and otherwise process your personal information. Please read this policy carefully. By accessing and using our Website, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

1. DATA CONTROLLER AND CONTACT INFORMATION

Data Controller: BRAHM Capital Partners Sdn Bhd SSM No. 202250100220 / 1603614-K Level 6, Menara Darussalam, 12 Jalan Pinang KLCC 50450 Kuala Lumpur, Malaysia Contact Information: Email: corporate@brahm.capital Phone: +60 11 5405 9228 For privacy-related inquiries, please contact us at the above address with the subject line “Privacy Inquiry.”

2. WHAT PERSONAL INFORMATION WE COLLECTED

We collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned, in accordance with the PDPA.

2.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us, including:

Full name, email address, and phone number
Company name, title, and business information
Messages, inquiries, and communications sent via contact forms, email, or other channels
Investment interest information, professional background, and qualifications
Confidential information related to potential investment opportunities
Employment application materials (resume, cover letter, certifications)

2.2 Information Collected Automatically

When you visit the Website, we automatically collect certain technical information:

Device information (device type, operating system, browser type and version)
IP address and location information
Browsing activity and pages visited
Duration of visits and clickstream data
Referrer source and search terms used
Cookie and tracking technology data

2.3 Information Not Collected

We do not intentionally collect information from children under the age of 18. If we become aware that we have collected personal information from a child, we will promptly delete such information. By using the Website, you represent that you are at least 18 years of age.

3. LEGAL BASIS FOR PROCESSING

We process your personal information based on the following legal grounds under the PDPA and applicable data protection laws:

Your consent – You have provided explicit consent for processing
Contractual necessity – Processing is necessary to fulfill our obligations to you
Legal obligation – We are required to process data to comply with applicable law or regulatory requirements
Legitimate interests – Processing is necessary for our legitimate business interests, including investment management, business operations, and fraud prevention

4. HOW WE USE YOUR INFORMATION

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. We use your personal information for the following purposes:

Responding to your inquiries, requests, and communications
Providing information about investment opportunities, funds, or partnerships (where you have expressed interest)
Processing and evaluating employment applications and recruitment
Conducting due diligence and know-your-customer (KYC) verification for regulatory compliance
Managing investor relations and fund administration
Improving and optimizing our Website, services, and user experience
Website analytics, performance monitoring, and fraud detection
Complying with legal, regulatory, and contractual obligations
Protecting our legal rights and the security of our Website and systems

We will not use your information for any purpose other than those specified unless we obtain your consent or as required by law. We do not sell, trade, or rent your personal information to third parties for marketing purposes.

5. DATA SECURITY

We implement appropriate technical and organizational security measures to protect personal information against loss, theft, misuse, unauthorized access, disclosure, copying, use, or modification. These measures include:

Encryption of sensitive data in transit and at rest
Secure authentication protocols and access controls
Regular security audits and vulnerability assessments
Employee data protection training
Secure disposal of confidential information

Important Notice: No method of transmission over the internet is completely secure. While we strive to protect your personal information using commercially reasonable security measures, we cannot guarantee absolute security. Use of the Website is at your own risk. You are responsible for maintaining the confidentiality of any passwords or authentication credentials.

6. COOKIES AND TRACKING TECHNOLOGIES

Our Website uses cookies and similar tracking technologies to enhance your browsing experience and analyze website usage.

6.1 What are Cookies?

Cookies are small text files stored on your device that allow us to recognize you and remember your preferences. There are different types of cookies:

Essential cookies – Necessary for basic Website functionality (e.g., security, load balancing)
Performance/Analytics cookies – Help us understand how you use the Website and improve its functionality
Preference cookies – Remember your preferences and settings
Marketing cookies – Used to deliver targeted content (if you have consented)

6.2 Managing Cookies

You can control cookie settings through your browser. Most browsers allow you to refuse cookies or alert you when cookies are being sent. However, disabling cookies may affect certain features of the Website. Please note that essential cookies cannot be disabled as they are required for Website functionality.

6.3 Third-Party Tracking

We may use third-party analytics services (e.g., Google Analytics) to track website usage and performance. These third parties may also use cookies and tracking technologies. We recommend reviewing their privacy policies for their data collection practices. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

7. SHARING YOUR INFORMATION

We do not share your personal information with third parties except in the following circumstances:

When necessary to fulfill your requests or provide services you have requested
With service providers and contractors who assist us in operating our Website and conducting business (under confidentiality and data protection agreements)
With legal advisors, auditors, and compliance consultants as needed for regulatory compliance
When required by law, court order, or legitimate government request
To protect our legal rights, privacy, safety, or property
With your explicit prior consent for a specific purpose
In connection with a merger, acquisition, or sale of substantially all of our assets

We do not sell, trade, or rent personal information to third parties for marketing purposes. Any service providers or contractors who access your information are contractually obligated to maintain confidentiality and use the information only for specified purposes.

8. THIRD-PARTY LINKS

Our Website may contain links to third-party websites and services. We are not responsible for the privacy practices, content, or security of those websites. We encourage you to review the privacy policies of any third-party sites before providing your personal information. Your use of third-party websites is governed by their terms and policies, not ours.

9. YOUR RIGHTS UNDER PDPA AND DATA PROTECTION LAWS

Under the Personal Data Protection Act 2010 (PDPA) and other applicable data protection laws, you have the following rights:

Right to Access – You can request access to the personal information we hold about you
Right to Correction – You can request correction of inaccurate, incomplete, or misleading information
Right to Deletion – You can request deletion of your information (subject to legal requirements and retention obligations)
Right to Opt-Out – You can opt-out of marketing communications and certain types of processing
Right to Data Portability – You can request a copy of your personal data in a structured, commonly used format
Right to Lodge a Complaint – You can lodge a complaint with the Personal Data Protection Commissioner if you believe we have violated your data protection rights

To exercise any of these rights, please submit a written request to the contact information provided in Section 1. We will respond to your request within 30 days or as required by law. Some requests may be subject to limitations or exceptions under applicable law.

10. DATA BREACH NOTIFICATION

In the event of a data breach or unauthorized access to personal information that poses a risk to the rights and freedoms of individuals, we will notify affected individuals and relevant regulatory authorities as required by the PDPA and applicable laws without undue delay. Notification will include information about the nature of the breach, the data affected, and recommended precautions.

11. INTERNATIONAL DATA TRANSFERS

Your personal information is primarily stored and processed in Malaysia. However, we may transfer your information to countries outside Malaysia where we or our service providers operate, subject to appropriate safeguards and in compliance with PDPA requirements. Any such transfers will be subject to contractual arrangements that ensure an adequate level of data protection equivalent to the protections provided by Malaysian law.

12. AUTOMATED DECISION-MAKING

We do not use automated decision-making or profiling for purposes that have legal or similarly significant effects on you. However, we may use analytics and automated tools for general Website optimization, security monitoring, and fraud detection. You are not subject to a decision based solely on automated processing that would have legal or similar significant effect.

13. SENSITIVE INFORMATION

We do not intentionally collect sensitive personal information (such as race, ethnicity, religion, health data, or biometric data) unless explicitly required for a specific purpose with your explicit consent. If we do collect such information, it will be handled with heightened confidentiality and security measures in accordance with PDPA requirements.

14. CHANGES TO THIS POLICY

BRAHM Capital Partners may update this Privacy Policy from time to time at our sole discretion to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by updating the “Last Updated” date at the top of this policy and, where required by law, by posting a notice on our Website or sending you an email notification.

Your continued use of the Website following the posting of modifications constitutes your acceptance of such modifications. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

15. CONTACT US

If you have any questions, concerns, or complaints about our Privacy Policy, our handling of your personal information, or wish to exercise your data protection rights, please contact us:

BRAHM Capital Partners Sdn Bhd Level 6, Menara Darussalam 12 Jalan Pinang KLCC 50450 Kuala Lumpur, Malaysia

Email: corporate@brahm.capital

Phone: +60 11 5405 9228