Avolution Trust Limited (“we” or “us”) handles personal data obtained through our website (https://labuantrustco.com/, the “Site”) and in the course of providing our services in accordance with the Personal Data Protection Act 2010 of Malaysia (as amended, the “PDPA”), the Act on the Protection of Personal Information of Japan (the “APPI”) and other applicable laws, under the following policy.
1. Company Information and Contact Point
Name: Avolution Trust Limited (Company Registration No. LL22359)
Representative: Sei Yamamoto
Address: No. 1-23A, First Floor, Paragon, Jalan Tun Mustapha, 87008 Labuan F.T., Malaysia
Personal data enquiries and complaints: Japan Desk, enquiries in Japanese and English (email: enokuma@labuantrustco.com)
2. Personal Data We Collect
We collect the following personal data.
- Information you provide when making an enquiry or a partnership request: your name, company or firm name, email address, telephone number, website URL, location, industry, the content of your enquiry and other information provided through the contact forms on the Site, email, WhatsApp or LINE
- Information you provide when you engage or use our services: information such as identification documents (for example, passports), proof of address, your occupation and assets, the purpose of the transaction, and details of the shareholders, directors and beneficial owners of a company, and other information necessary for company incorporation, the establishment of trusts and foundations, bank account opening support and our other services, and for legally required customer due diligence (KYC)
- Information you provide in recruitment enquiries: information such as your name, contact details and career history
- Information about your use of the Site: cookies, IP address, browser type, pages viewed, date and time of access and similar access data (see Section 7)
Where you provide us with personal data relating to other individuals (for example, the shareholders, directors, beneficial owners or employees of a company, or members of your family), you confirm that you are entitled to provide that data to us and that you have informed those individuals of the matters set out in this policy, including the purposes for which their personal data will be processed and how they may contact us. On request, we will provide you with a copy of this policy in a form that you can pass on to them.
3. How We Collect Personal Data
We generally collect personal data directly from you. We may also obtain personal data from introducers and partner firms, from information published by public authorities, and from publicly available sources such as sanctions lists and media reports used for customer due diligence required by law.
If you do not provide the mandatory fields of a form or the documents we request for customer due diligence required by law, we may be unable to respond to your enquiry or provide our services. Providing optional information is at your discretion.
4. Purposes of Use
We use personal data only within the scope of the following purposes.
- To respond to and communicate about your enquiries and consultations
- To provide information on our services, prepare quotations, and enter into and perform contracts
- To carry out customer due diligence, anti-money laundering and counter-terrorism financing checks, and to create and retain records, as required of a company established in Labuan, Malaysia and subject to Malaysian anti-money laundering legislation
- To handle partnership enquiries and to communicate with partner firms
- To respond to recruitment enquiries and to manage recruitment and applicant information
- To analyse the use of the Site and to improve our content and services
- To comply with laws, requests from supervisory authorities and our internal rules
Where we need to use personal data for any other purpose, we will obtain your consent in advance.
In carrying out anti-money laundering and counter-terrorism financing checks, we may consult publicly available sources such as official sanctions lists and media reports. Where such checks require us to obtain sensitive personal data such as criminal records, we will obtain your consent in advance.
5. Disclosure to Third Parties
We do not disclose personal data to third parties except with your consent, in the cases set out below, or as described in Section 6 (Outsourcing and Joint Use).
- Where required by law, or upon a lawful request from a supervisory authority, court or similar body
- Where necessary to protect the life, body or property of a person and it is difficult to obtain your consent
Where we introduce you to partner professionals (lawyers, tax accountants, accounting firms, banks and others), we will obtain your consent in advance and provide only the information necessary.
6. Outsourcing and Joint Use
Outsourcing
We may outsource the handling of personal data to third parties to the extent necessary to achieve the purposes of use. Service providers are selected in accordance with criteria established by us and are contractually required to manage personal data appropriately. We currently use the following services.
- Website and email hosting (Xserver Inc., servers located in Japan)
- Receipt and storage of email (Gmail, provided by Google LLC)
- Access analytics (Google Analytics, provided by Google LLC)
- Messaging (WhatsApp, provided by WhatsApp LLC, a Meta company; LINE, provided by LY Corporation)
- Management of LINE official account messaging (UTAGE, a tool for managing LINE official account messaging)
Joint Use
Our Japanese-language services (Japan Desk) are provided by our partner, IYOU Accounting Office (Empression Co., Ltd.). Accordingly, we use personal data jointly with Empression Co., Ltd. as follows.
“Joint use” is a framework under the APPI: the parties listed below use the personal data jointly within the scope stated, while Avolution Trust Limited remains responsible for its management. By making an enquiry through our Japan Desk, or through the LINE or WhatsApp channels shown on the Site, you consent to the disclosure of your personal data to Empression Co., Ltd. for the purposes set out below. If you do not wish your personal data to be disclosed to Empression Co., Ltd., please contact us using the details in Section 1.
- Personal data used jointly: name, company or firm name, email address, telephone number, location, industry, website URL, the content of enquiries, and records of communications with us
- Parties using the data jointly: Avolution Trust Limited and Empression Co., Ltd. (IYOU Accounting Office)
- Purposes of joint use: the purposes set out in Section 4 (for Empression Co., Ltd.: handling enquiries in Japanese, confirming the content of consultations, providing information on our services, and handling consultations on accounting and tax matters in Japan)
- Party responsible for the management of the personal data: Avolution Trust Limited (address and representative as set out in Section 1)
The LINE contact channel shown on the Site is a LINE official account operated by Empression Co., Ltd. (IYOU Accounting Office). Information you provide via LINE is obtained by Empression Co., Ltd. and used jointly with us within the scope set out above. You may receive notices from Empression Co., Ltd. through that account. To stop receiving messages, you may block the account or follow the instructions provided within it. The WhatsApp contact number is shared by us and Empression Co., Ltd.
7. Cookies and Access Analytics
The Site uses Google Analytics to understand how the Site is used and to improve our services. Google Analytics uses cookies to collect access data. It does not collect information that directly identifies you, such as your name, but identifiers such as your IP address are obtained. For details on how Google handles this data, please see the Google Privacy Policy. If you do not wish to have data collected through cookies, you may disable cookies in your browser settings or use the Google Analytics Opt-out Browser Add-on. The main functions of the Site remain available with cookies disabled.
8. Cross-Border Transfers of Personal Data
We are a company located in Labuan, Malaysia, and personal data obtained from residents of Japan is handled outside Japan (in Malaysia). Of the service providers and joint users listed in Section 6, Empression Co., Ltd. (Malaysia), Google LLC (United States) and WhatsApp LLC (United States) are located outside Japan. Transfers to them are made under Article 28 of the APPI, after confirming that the recipient has in place a system for continuously taking measures equivalent to those required of a business operator handling personal information in Japan. Information on the personal data protection regime of the country in which each recipient is located, and on the measures taken by the recipient, is available on request through the contact point in Section 1. Xserver Inc.’s servers are located in Japan. LY Corporation stores data in accordance with its own privacy policy.
Where we transfer personal data out of Malaysia, we do so in accordance with section 129 of the PDPA, on the basis that the recipient is subject to a law, or is bound by a binding scheme or contract, that provides protection substantially similar to the PDPA, or that the transfer is necessary to perform a contract with you.
9. Security Measures
To prevent the leakage, loss or damage of personal data, we take measures including encryption of communications (SSL/TLS), management of access rights, restricting the staff who handle personal data, and appropriate selection of external services.
10. Retention Period
We retain personal data for the period necessary to achieve the purposes of use. Records that we are required to retain under anti-money laundering laws and other laws are retained for the period prescribed by law (for example, at least six years from the completion of the transaction).
11. Requests for Access, Correction, Suspension of Use and Other Requests
If you request notification of the purposes of use, access, correction, addition, deletion, suspension of use or cessation of provision to third parties of your personal data held by us, we will respond within the period required by law after verifying your identity. Please send requests to the contact point in Section 1. When you make a request, we will inform you of the identity verification procedure and of whether and how a request may be made through an agent. We may charge a fee, limited to actual costs, for access requests. Please note that we may be unable to comply with requests for deletion or similar in respect of information that we are required by law to retain.
You may also withdraw your consent to our processing of your personal data at any time, and you may at any time require us to stop processing your personal data for direct marketing purposes, by contacting us using the details in Section 1. Withdrawal of consent may mean that we are unable to continue providing our services.
12. Response to Data Breaches
If a leakage, loss, damage or similar incident involving personal data occurs and is likely to harm your rights and interests, we will report it to the Personal Information Protection Commission of Japan and the Personal Data Protection Commissioner of Malaysia (Department of Personal Data Protection) as required by law, and will notify you promptly.
13. Changes to This Policy
We may revise this policy in response to changes in law or in our services. A revised policy takes effect when it is posted on the Site. Any change to the purposes of use will be made within a scope reasonably considered to be related to the purposes before the change, and will be announced on the Site. Where a change goes beyond that scope, we will obtain your consent in advance.
Established: 24 September 2026
Last updated: 24 September 2026
Avolution Trust Limited