Privacy and Cookie Policy

Effective Date: 01/06/2020

Franklin Templeton GSC Asset Management Sdn. Bhd. ("we" or "us") respect your privacy and value the trust you place in us when you share your personal information with us. The way we may collect and use your personal information, and the choices available to you in connection with our use of your personal information, is discussed in this Privacy & Cookies Policy ("the Policy").

The Policy describes our information practices relating to using this website ("our Website") and to investing in our Unit Trust funds.

Policy in this page will be subjected to change as and when there are changes to our policy or laws; and as and when required by the Securities Commission, Malaysia.

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  • Malaysia Personal Data Protection Act 2010 – Processing of Personal Data

    Franklin Templeton ( “FT Group”) is committed to safeguarding personal data provided to us by our investors, maintaining the confidentiality, security and integrity of personal data provided to us. Pursuant to the Malaysia Personal Data Protection Act 2010 (“PDPA”) , this Privacy Notice explains;

    1. Personal data which may be used, processed and disclosed
    2. To whom the personal data may be disclosed
    3. Purpose for which the personal data may be used, processed and disclosed
    4. Authority to use, process and disclose your personal data
    5. Access to and correction of your personal data

    “Personal Data” is defined under the PDPA to mean any information in respect of commercial transactions, which –

    1. is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
    2. is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
    3. is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system,


    that relates directly or indirectly to a Data Subject[1], who is identified or identifiable from that information or from that and other information in the possession of a Data User[2], including any sensitive personal data and expression of opinion about the Data Subject.

    This may include information relating to an individual, such as name and address, employment details; contact information such as phone numbers or email addresses; proof of identification and identification number; sample of signature; job title; banking and financial information; and results from third party searches.

    Under the PDPA, “processing”, in relation to personal data, means collecting, recording, holding or storing the personal data or carrying out any operation or set of operations on the Personal Data, including –

    1. the organization, adaptation or alteration of personal data;
    2. the retrieval, consultation or use of personal data;
    3. the disclosure of personal data by transmission, transfer, dissemination or otherwise making available; or
    4. the alignment, combination, correction, erasure or destruction of personal data.


    Personal data which may be used, processed and disclosed

    Any personal data related to you or individuals indirectly connected to you, such as:

    1. Proof of identification, beneficial owners, directors/control persons, account signatories, and related parties; business licenses; certificates; organizational documents (such as articles of incorporation, certificate of incorporation); and proof of beneficial owners or shareholder(s). This may include personal data provided to us from third parties authorized by you, or available publicly.
    2. Financial information and investment holdings, including but not limited to source of funds; account numbers; nature and purpose of investment and holdings; investment transactions; derivative transactions; deposits; securities or other financial assets; products used; product-related information; expected or anticipated activities including enquiries or transactions you request on our website; periodic or any regular reports; board resolutions; Know Your Client review results and searches; tax identification number; any information relating to the purpose as set out in our contractual or business relationship with you; and other general information that we may obtain about you as demographic information.


    To whom the personal data may be disclosed

    • Any company within the FT Group;
    • Employees, agents, subcontractors, advisers, and providers of outsourced services of FT Group;
    • Governmental, regulatory, supervisory, law enforcement or similar authority in any jurisdiction;
    • Any court of competent jurisdiction in defense of claims or enforcement of rights;
    • An assignee or a proposed assignee of any of FT Group’s rights or obligations;
    • Auditors of the FT Group or your auditors; and/or
    • Providers of services such as custodians, brokers, distributors and financial institutions; including any parties whom FT Group will deal with in relation to the performance of investment management for you.


    Your personal data may be disclosed regardless of whether the disclosure is made in the country in which you reside, in which the relationship is maintained, or in which the transaction is conducted, which could be within Malaysia or in a place outside Malaysia. We will only share personal data with outside parties in the limited circumstances permitted by law. This includes situations where we need to share personal data with companies who work on our behalf to service or maintain your account or process enquiries or transactions you've requested, when the disclosure is to a party representing you, or when required by law. Additionally, we may disclosure your personal data to external companies assisting us in the distribution or marketing of our products and services, or with whom we have joint marketing agreements, and will ensure that such companies are under contractual obligations to protect the confidentiality of your information, and to use it only to provide the services we've asked them to perform.

    Purpose for which the personal data may be used, processed and disclosed

    Your personal data may be used, processed and/or disclosed for the purpose of carrying out FT Group’s obligations to you or for any of the following purposes:

    • all future or existing verification procedures and ongoing account administration;
    • marketing a FT Group product or expertise to you, including a product managed by an external party that feeds or subscribes into a FT Group product;
    • to comply with any laws, regulations, court order or requirement of regulatory bodies, including periodic and ad-hoc reporting to relevant regulators;
    • for conducting anti-money laundering and terrorism financing checks, verification, related reporting and monitoring;
    • for delivery of reports and correspondence; and/or goods and services;
    • managing the Data Subject relationship and/or servicing you locally or globally; and
    • any other purposes relating to or in connection with the above, and the business of FT Group.


    The personal data collected will be retained by FT Group for the duration of our relationship, and as permitted by laws or regulations which may extend to periods after termination of your contractual or business relationship with us.

    Authority to use, process and disclose your personal data

    Insofar as personal data provided by you includes the personal data of individuals connected to you represents and warrants that it has obtained sufficient informed consent from the relevant individuals, as required by applicable law for the purpose of enabling FT Group to disclose such personal data in the circumstances described above, and will provide us with such consent as and when requested by us.

    Insofar as personal data provided by you includes the personal data of individuals connected to you which include sensitive data or any information specified by applicable law to be sensitive in nature, you represents and warrants that it has obtained and will provide to us, sufficient informed written/explicit consent from the relevant individuals, as required by the PDPA for the purpose of enabling us to use, process or disclose such personal data as described above.

    Access to and correction of your personal data

    If you wish to access and, as the case may be, request the correction of any of your personal data, or have any objections to the use, processing, transfer or disclosure of any of your personal data for any specific purpose or to any specified person; or if you have any complaints or enquiries, please contact the following:

    Mailing address: Franklin Templeton Asset Management (Malaysia) Sdn. Bhd.
    Suite 31-02, 31st Floor, Menara Keck Seng
    No. 203, Jalan Bukit Bintang, Kuala Lumpur

    Telephone No.: +603 2264 6688
    Fax No.: +603 2145 9071
    E-mail address: salesMY@franklintempleton.com

    Mailing address: Franklin Templeton GSC Asset Management Sdn. Bhd.
    Suite 31-02, 31st Floor, Menara Keck Seng
    No. 203, Jalan Bukit Bintang, 55100 Kuala Lumpur

    Telephone No.: (603) 2264 6699
    Fax No.: (603) 2145 9071
    E-mail address: salesMY@franklintempleton.com

    We may be required under applicable laws to obtain certain of your personal data (including personal data relating to individuals connected to you ) and perform ‘know your client’ assessment on you. If you fail to provide such information to us , this may lead to adverse consequences, including, and may not be limited to, we sourcing the relevant information from any third parties for the purposes described within these terms; or termination of the relationship.

    Retention of Your Personal Data

    Your personal data will be retained in compliance with this Privacy Notice and/or the terms and conditions of your agreement(s) with us for the duration of your relationship with us, for such period as may be necessary to protect the interests of FT Group and/or its investors as may be deemed necessary. Such retention is deemed necessary as required by the law and/or where required by internal policies.

    Confidentiality and Security

    Our employees are required to follow procedures with respect to maintaining the confidentiality of our investors' non-public personal information. Additionally, we maintain physical, electronic, and procedural safeguards to protect the information. This includes performing ongoing evaluations of our systems containing investor information and making changes when appropriate.

    Revisions to Privacy Notice

    This Privacy Notice may be revised from time to time. Any such revision will be posted on this website and/or by such other means of communication deemed suitable by us. If you continue to use our services/products, you shall be deemed to have agreed to accept such changes.

    [1] “Data Subject” means an individual who is the subject of the personal data

    [2] “Data User” means a person who either alone or jointly or in common with other persons processes any personal data or has control over or authorizes the processing of any personal data, but does not include a data processor

  • A cookie is a small text file which includes a unique identifier that is sent by a web server to your computer, mobile phone or any other internet enabled device when you visit a website. Cookies are widely used to make websites work efficiently and to collect information about your online preferences.

    How do we use cookies?
    We use cookies and other tracking technologies to customise content and advertising, provide social media features and to see how our visitors move through our website. We use this information to make decisions about ways to improve the services we offer you.

    We use all or some of the following categories of cookies on our website:

    Essential cookies. These cookies are essential for parts of our website to operate. They enable you to move around our website and allow us to recognise you within our website so that we can provide you with service that you have asked for such as remembering your sign-in details.

    Functionality cookies. These cookies help us customise our site content based on your preferences. They remember choices you make such as identifying yourself as a particular investor type (Retail, Professional or Institutional), your language, the country you visit our website from and any changes you make to text size or other parts of our web pages. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

    Performance cookies. These cookies collect information on how you use our website in order to help us improve areas such as navigation and to help us fix technical issues or errors. For example, we use these cookies to help us understand how you arrive at our website, browse or use our website and highlight areas where we can improve. The information stored by these cookies never shows personal details from which your identity can be established.

    Targeting cookies. These cookies collect information about your browsing habits in order to make advertising, and the content we deliver, more relevant to you and your interests. They are also used to limit the number of times you see an advert or particular content, as well as help measure the effectiveness of an advertising or marketing campaign.  These cookies are usually placed by third party advertising networks.  They remember the websites you visit and that information is shared with other parties such as advertisers.

    Social Media cookies. These cookies allow you to share our website on social media such as Facebook and Twitter. These cookies are not within our control.  Please refer to the respective privacy policies for how their cookies work.

    Web beacons.  Some of our web pages may contain electronic images known as web beacons (also known as clear gifs or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

    You can find more information about cookies, behavioural advertising and online privacy at www.allaboutcookies.org or www.youronlinechoices.eu.

    Enabling and Disabling Cookies

    You can choose whether to switch on or off cookies by visiting the Cookie Preference centre. You can select which cookie categories you wish to allow.