Privacy Policy

1. Who we are

Snowball Capital Sdn Bhd (Business Registration No. 201001042254, Tax Identification No. C21971367070) is an investment holding company based in Penang, Malaysia, acting as the “data user” under the PDPA for the personal data described in this Policy.

Registered office: Cangkat Sungai Ara 20, 11900 Bayan Lepas, Penang, Malaysia.
Contact for privacy matters: hello@snowball.capital.

2. Personal data we collect

We may collect and process the following categories of personal data:

• Contact data — name, email address, phone number, company, and any details you include when you email us or use a contact form.
• Enquiry & relationship data — correspondence regarding partnership, co-investment, founder introductions, or limited-partner (LP) matters.
• Account data — credentials and related information if you access the LP portal.
• Technical data — IP address, browser type, device information, and pages visited, collected automatically when you use the Site.

We collect personal data directly from you, automatically through your use of the Site, and occasionally from third parties such as referrers or publicly available sources, where lawful.

3. Purposes & legal basis

We process personal data to:

• respond to enquiries and communicate with you;
• evaluate and manage investment, partnership, and co-investment opportunities;
• administer LP relationships and the LP portal;
• operate, secure, and improve the Site;
• comply with legal, regulatory, tax, and anti-money-laundering obligations.

We process your data on the basis of your consent, the performance of a contract or steps taken at your request, our legitimate interests as an investment holding company, and compliance with applicable law.

4. Disclosure of personal data

We may disclose personal data to:

• companies within our portfolio and group, where relevant to your enquiry or relationship;
• professional advisers (legal, accounting, audit, tax);
• service providers who host the Site, manage the LP portal, or support our operations;
• regulators, authorities, or courts where required by law.

We do not sell your personal data. Where data is shared with a service provider, we require appropriate safeguards consistent with the PDPA.

5. Cross-border transfer

Some of our service providers may store or process data outside Malaysia. Where personal data is transferred abroad, we take reasonable steps to ensure it receives a level of protection comparable to that required under the PDPA.

6. Cookies & analytics

The Site stores a small theme preference in your browser’s local storage and may use cookies or similar technologies for essential functionality and to understand how the Site is used. You can control cookies through your browser settings; disabling them may affect some features.

7. Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required to meet legal, regulatory, tax, and accounting obligations, after which it is securely deleted or anonymised.

8. Security

We apply reasonable technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your rights under the PDPA

Subject to the PDPA, you have the right to:

• request access to the personal data we hold about you;
• request correction of inaccurate, incomplete, or outdated data;
• withdraw consent to processing;
• limit the processing of your data;
• prevent processing likely to cause damage or distress, and processing for direct marketing.

To exercise any of these rights, contact us at hello@snowball.capital. We may need to verify your identity before acting on a request. We may charge a prescribed fee for data access requests where permitted.

10. Third-party & portfolio websites

The companies we hold, own, back, and build — and any other sites we link to — operate their own websites and collect personal data under their own privacy policies. Please refer to the respective privacy policy of each website you visit. This Policy applies only to data we collect through snowball.capital and our direct dealings with you.

11. Children

The Site is not directed at children, and we do not knowingly collect personal data from minors without appropriate consent.

12. Changes to this Policy

We may update this Policy from time to time. The “Last updated” date above reflects the latest revision. Continued use of the Site after changes constitutes acceptance of the revised Policy.

13. Language

This Policy is provided in English. In the event of any inconsistency with a translated version, the English version prevails.

14. Contact us

Questions about this Policy or your personal data? Write to us:

Snowball Capital Sdn Bhd
Cangkat Sungai Ara 20, 11900 Bayan Lepas, Penang, Malaysia
hello@snowball.capital