Your Privacy Matters

Introduction

Your privacy is important to us at BFG Investments. This Privacy Policy outlines how BFG Investments Ltd ("we", "us", or "our") collects, uses, protects, and discloses personal information. We are committed to handling your personal data in a secure and transparent manner. This policy applies to information collected through our website and in the course of our business interactions related to BFG Investments Private Fund.

Personal Data We Collect

We may collect personal information from you when you interact with us, such as when you contact us via email or web form, subscribe to updates, or inquire about an investment. The information we collect can include:

• Contact details: your name, email address, phone number, mailing address, and company or organization (if you provide these).
• Identification and financial information: if you progress in discussions as a potential investor, we may request information like your nationality, residency, investment preferences, and documents to verify your identity or accredited investor status (e.g. copies of ID, proof of funds) as required by law (such as Anti-Money Laundering regulations).
• Website usage data: through the use of cookies or analytics tools, we might collect information about your visits to our website – for example, your IP address, browser type, pages viewed, and time spent – to understand how our site is used and to improve user experience. (See Cookies & Tracking below.)

We limit our collection to information that is relevant and necessary for the purposes described below. We do not knowingly collect personal data from individuals who are not of legal age or who are not our intended audience of professional investors.

How We Use Your Information

Personal information we collect will be used for the following purposes:

• Responding to Inquiries: If you contact us (for example, via the provided email address), we will use your contact information to respond to your questions and provide the information or assistance you requested.
• Providing Fund Information: For individuals who have expressed interest in our fund and who are verified as eligible investors, we use personal data to provide additional documentation, such as our Information Memorandum, performance reports, or account access to the investor portal. We may also use your details to facilitate the subscription process if you decide to invest (including sending you necessary forms and agreements).
• Investor Relations: If you become an investor, we will use your information to manage our ongoing relationship with you. This includes sending you periodic updates, capital account statements, distribution notices, or other investor communications. It also includes handling any requests or inquiries you may have as an investor.
• Regulatory Compliance: We may process your personal data to comply with legal and regulatory obligations. For instance, we might use identification information to fulfill Know-Your-Customer (KYC) and Anti-Money Laundering (AML) requirements mandated by Labuan FSA or other relevant regulators. We also maintain records as required by financial regulations and laws.
• Website Improvement and Analytics: Information on how you use our site (if collected) helps us troubleshoot technical issues, secure our online services, and design a better user experience. For example, we might analyze traffic patterns to see which sections of our website are most visited, allowing us to refine our content.
• Marketing and Updates (Limited): We do not engage in mass marketing to the general public, but if you are an existing contact or investor, we may from time to time send updates about our fund's strategy, new opportunities, or industry insights. This would typically be done in a selective and personalized manner. You will always have the option to opt-out of receiving such communications.

We will not use your personal information for purposes unrelated to the above without your consent. Importantly, we do not sell or rent your personal data to third-party marketers.

Cookies & Tracking

Our website may use cookies and similar tracking technologies (like Google Analytics) to enhance user experience and gather information about site usage. Cookies are small text files placed on your device that help the website remember your preferences or understand how you interact with our content. For example, a cookie might store your language preference or keep you logged in (for any secure areas for investors). We may also use cookies to aggregate non-personal data about how many users visited a page, how long they stayed, and what actions they took.

Your choices: Most web browsers allow you to adjust settings to refuse cookies or alert you when cookies are being sent. If you choose to disable cookies, please note that some parts of our site might not function properly.

We currently do not use cookies to deliver targeted advertising, and any analytics data collected is used solely to improve our site and service delivery. By continuing to use our website, you consent to our use of cookies as described (unless you have disabled them via your browser).

Information Sharing and Disclosure

We treat your personal information with confidentiality. We may share your information only in the following circumstances:

• Service Providers: We may disclose necessary personal data to trusted third-party service providers who assist us in operating our business. Examples include fund administrators, banks, auditors, legal counsel, or information technology providers. These parties are contractually obliged to keep your information confidential and use it only for the services they perform for us.
• Regulatory and Legal Requirements: If required by law or regulation, we may need to disclose information to regulatory authorities, government agencies, or courts. For example, we might provide information to Labuan FSA during a compliance audit, or respond to a subpoena or legal process.
• Business Transfers: In the unlikely event that our business (or a portion of it) undergoes a major transaction such as a merger, acquisition, or restructuring, your personal data might be transferred to the new entity or third party as part of that process.
• Your Consent: We may share your personal information with other parties if you have given us explicit consent to do so.

Importantly, we do not share personal information with any third parties for their own marketing purposes.

Data Security

We take the security of your personal data seriously. BFG Investments Ltd implements industry-standard security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Physical security: Our offices and file storage (both physical and electronic) are secured; access to personal data is limited to authorized personnel only.
• Technical safeguards: We use secure computer systems, up-to-date encryption protocols, firewalls, and access controls to prevent unauthorized cyber access. For instance, any sensitive information (like identification documents or account details) transmitted electronically is done through encrypted channels. Our website employs HTTPS/SSL encryption to secure data entered through web forms.
• Organizational policies: We train our staff on data privacy requirements and ensure that only staff who need to process your information (for the purposes described) have access to it. We also have protocols for handling any suspected data breach, including notifying affected individuals and regulators as required by law.

Despite our precautions, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. You can also play a part in security by using strong passwords for any investor portal access we provide and keeping your credentials confidential.

Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for satisfying any legal, accounting, or reporting requirements. For example:

• If you contact us but do not become an investor, we may keep your contact details and correspondence for a certain period in case you have follow-up questions or if an opportunity to invest arises, but we will not keep it indefinitely without purpose.
• For investors, we retain personal and transactional data throughout the duration of your investment and thereafter for the period required under law (for instance, we might keep records for a number of years after the fund closes or after you redeem, to comply with anti-money laundering record-keeping or tax audit requirements).
• Web analytics data is generally kept only for analytical purposes and is often aggregated; personal identifiers (like IP addresses in logs) are typically deleted or anonymized in accordance with our data retention policies.

When personal data is no longer necessary, we will securely delete or anonymize it. We also regularly review the data we hold and erase or anonymize personal data that is not needed.

Your Rights

Depending on the jurisdiction in which you reside, you may have certain legal rights with respect to your personal data. These may include:

• Access: The right to request a copy of the personal data we hold about you, and to obtain information about how we process it.
• Correction: The right to ask us to correct or update any inaccurate or incomplete personal information.
• Deletion: The right to request erasure of your personal data, where applicable.
• Objection/Restriction: The right to object to or request restriction of processing of your data in certain circumstances.
• Data Portability: In some cases, the right to receive the personal data you provided to us in a structured, commonly used format, or to request that we transmit it to another party at your direction.
• Withdraw Consent: If we rely on your consent to process any personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the contact information provided below. We will respond to legitimate requests in accordance with applicable law. Please note that some rights may be subject to exceptions or limitations; for example, we cannot delete information that we are required to maintain by law, or we may need to verify your identity before fulfilling an access request.

International Data Transfers

BFG Investments operates in Labuan, Malaysia. If you are located outside of Malaysia, be aware that any information you provide to us will likely be transferred to and stored in Malaysia, and possibly in other countries if we use cloud storage or service providers with international servers. Malaysia is an internationally recognized financial center, and we ensure that any cross-border data transfers are done with appropriate safeguards. By communicating with us or using our site, you consent to the transfer of your personal data to Malaysia and other jurisdictions as appropriate. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and applicable data protection laws.

Changes to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices or relevant laws. If we make material changes, we will update the "last updated" date at the bottom of this policy and, if appropriate, provide a notice on our website. We encourage you to review this policy periodically to stay informed about how we are protecting your information. Your continued relationship with us or use of our website after any changes to this policy constitutes your acceptance of the updated terms.

Contact Us (Privacy Inquiries)

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us at:

Please include your name and contact information along with your specific request or question. We will do our best to address your inquiry promptly and resolve any issues to your satisfaction. If you are not satisfied with our response and you are entitled to further recourse under applicable law, we will provide you with information on how you can lodge a complaint with a data protection authority.