Privacy Notice

This notice applies to you if:
• You are an individual who is our client or an investor that we manage or advise (a “Fund”).
• Your information was provided to us in connection with a client of ours or an investor in a Fund.
• You are an individual who is a potential client of ours or a potential investor in a Fund, or a Representative of a potential client or a potential investor in a Fund.
• You are an administrator, officer or manager of a listed company in which we or a Fund may invest.

This notice and any applicable agreement between you and us sets out the basis on which we use your personal information. This notice discloses information required by the privacy laws that apply to us, including the European Union General Data Protection Regulation and U.S. law. We are data controllers of your personal information.

We may use personal information that is:
• Provided by you via email, telephone, in meetings or as part of a request to participate in a Fund.
• Collected or generated in connection with an investment in a Fund by you or the person or entity you represent.
• Obtained from public sources, such as websites and regulatory records.

We may use the following personal information:
• Personal data such as name, title, addresses, telephone numbers, email addresses, date of birth, gender, citizenship, signature, photographs and details about your employment and education.
• Financial details, such as details of your investments, income and assets, bank accounts, tax residency and tax identification information.
• IP addresses and location data.
• Information related to procedures known to your client, results of background checks, which may include your information and political opinions.

We may use personal information to:
• Communicate with you and/or the person or entity you represent and maintain records of such communication.
• Carry out business development and marketing activities, such as providing information about Funds and our services, research and events.
• Assess suitability for the Funds and our services and carry out procedures to get to know your client.
• Process and manage investments in Funds and our appointment to provide services.
• Perform due diligence on Service Providers and manage Service Provider relationships.
• Enter into contracts and fulfill contractual obligations.
• Comply with legal, regulatory or self-regulatory requirements that apply to us.
• Administer our and ensure that they are effectively presented to you and to your computer or device.
• Respond to queries and complaints.

We will only use your personal information for the purposes for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis for such use.

Legal basis
We can only use your personal information where the law allows us to (i.e. where there is a “lawful basis for the processing”). The legal basis will be one or more of the following:
• When we need to perform a contract we have entered into with you.
• Where we need to comply with EU or member state legislation.

Depending on the type of personal information, these legitimate interests are: running daily business operations; mitigate operational, financial, legal, tax, reputational, strategic, economic and other risks; ensure that we continue to be a viable and competitive business; and comply with legislation.

Sharing personal information
As a global company, we may share your personal information with our affiliates for the purposes set out above.
Your personal information is stored on secure servers and access to it is limited in accordance with our information security policies and procedures.

Security
Your personal information is stored on secure servers and access to it is limited in accordance with our information security policies and procedures.

International transfers
Our affiliates and other third parties who receive your personal information may be based anywhere in the world. In such cases, we seek to ensure that your personal information receives an adequate level of protection, for example by seeking to ensure that such transfers are subject to standard data protection provisions or that the transfer is subject to appropriate measures. safeguards.

Retaining your personal information
The length of time we keep your personal information varies. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we use the information, and applicable legal requirements. In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use that information without notice.

Your rights
• Access – you can request details of your personal information that we hold.
• Rectification – you may request that we correct or complete any personal information.
• Erasure – you can request that we delete your personal information, although in some circumstances we may have a legal right to retain it.
• Restriction – you may object and request that we restrict the use of your personal information in some circumstances, although in some circumstances we may have the legal right to continue to use it or to refuse such a request.

If you exercise your rights to opt-out or restriction, or if you refuse to provide certain personal information, we may not be able to provide services to you or the person or entity you represent.
You will not have to pay any fees to exercise any of these rights.
Changes to this notice We may update this notice at any time and will post updates on the relevant websites.
If you have any questions about this Notice or how we use your personal information, or if you wish to exercise any of your rights, please contact us via communication channels.