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PRIVACY STATEMENT

1. INTRODUCTION AND SCOPE

This Privacy Statement sets out how TMF Group (“we”, “us”, and “our”) uses your
Personal Data in connection with:

* services provided to or by you ("Services”);
* other (pre) contractual relationship between you and TMF Group, except for
employment or
* similar relationship (“Relations”);
* Services provided to or by an entity that you represent or work for (“your
entity”) or Relations that your entity has with TMF Group.
* your data subject requests in accordance with applicable data protection laws
in order to provide you with requested information collected from us as
listed under Section 3. of this Statement

For purposes of this Privacy Statement, “Personal Data” means any information
through which we can identify you, as further described below under paragraph 3
(Personal Data we process).

This Privacy Statement only applies to the usage of Personal Data of
(prospective) clients, vendors or other business partners (individuals) and
investment funds for which TMF Group entity is responsible and qualifies as a
controller in the meaning of the General Data Protection Regulation
(2016/679/EU) ("GDPR") or similar qualification under other data protection
laws, whereby TMF Group entity determines the purpose and the means of the
processing of such Personal Data, including data collated and retained by or on
behalf of investment funds managed by TMF (“TMF managed funds”).

Your Personal Data can be collected through various channels, such as in a sales
process, via telephone calls, via forms you or your entity submit(s) to us,
via email or other communication channels or tools, as well as during business
events.

We can collect your Personal Data directly from you or indirectly from your
entity.

This Privacy Statement does not apply to corporate company information if no
Personal Data from individuals can be derived from such corporate information,
unless it is considered Personal Data in accordance with applicable local laws.

For our usage of Personal Data in our capacity as a processor under the relevant
data protection laws, Personal Data Protection Policy applies. We also have a
separate Website Privacy Statement which applies and sets out how we use your
Personal Data when you visit our website.

2. WHO WE ARE

When we refer to ourselves as “TMF Group” or “we”, we mean each TMF Group entity
that is responsible for using your Personal Data. This will depend on the TMF
Group entity(/ies) that you intend to or have entered into a contract with for
the provision of Services or with regard to Relations. An overview of the
locations where TMF Group entities operate in and TMF Group entities as such can
be found here.

3. PERSONAL DATA WE PROCESS

The Personal Data we process about you in connection with providing Services or
Relations include the following:

* Your contact details. Your name, address, telephone number, email address and
any other contact details you provide to us.
* Your personal characteristics. Including your gender, profession, job title,
name of your entity, marital status (if shown on national identification
cards) or other personal characteristics that are requested to identify you
as a client, a vendor or a business partner, or their representative or
employee, including information disclosed in commercial registers if it is
considered Personal Data in accordance with the applicable local laws.
* Recording of video footage. When you enter our buildings or premises, you are
recorded by our video surveillance systems (CCTV). You can also be recorded
on video footage during events, such as seminars, that we host. The specific
and customized information on this personal data processing (if recorded) is
available in the respective TMF Group affiliate premise. Where applicable-
the CCTV images may be also processed by the building owner or the authorized
third party of TMF Group affiliate.
* Your communication data. Your requests, any complaints you may have, or any
requests or complaints submitted for you or on your behalf, and any other
data that we receive if we communicate with you via email, telephone, in
person or otherwise.
* KYC information. TMF Group is required by law to conduct "know your client"
identification procedures. To comply with our legal obligation, we also
collect the following information from the Ultimate Beneficial Owners (UBOs)
or executives and representatives (e.g. managing directors or board members)
of our clients: first and family name, citizenship(s) (nationalities), your
Personal Data disclosed in a copy of ID or copy passport (including its
number, issuance and expiry dates, issuing authority, photo of individual),
CV (in certain cases when required by Group Compliance) tax residence,
private/residential address, phone number, email address, date of birth,
place of birth, marital status, profession and actual function, range of
annual income, range of estimated wealth, the source of wealth and (where
applicable) an U.S. or other Taxpayer Identification Number.

If you are acting as a party to contract with us, then providing required
Personal Data which allow us to identify you as a contracting party is a
pre-condition for concluding such contract. The contract cannot be concluded
without Personal Data based on which we can identify you as a party to the
contract.

Providing Personal Data concerning the KYC process is necessary for us to be
able to comply with the applicable legal, regulatory or professional
requirements on anti-money laundering legislation. If the Personal Data is not
provided then conducting required verification can be significantly hindered,
and as a consequence we may not be able to conclude a contract with you or your
company, or already concluded contract may be terminated due to non-compliance
with the legal obligation imposed by Anti-money laundering legislation.

Providing Personal Data for the purpose of contact or communication is
voluntary. However, lack of such Personal Data may significantly delay providing
Services, maintaining Relations or answering your requests or
complaints. Providing Personal Data only for marketing purposes is voluntary.
Failure to provide the Personal
Data for such purposes has no consequences.

4. PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

TMF Group collects, uses or otherwise processes your Personal Data for the
purposes below and on a lawful basis. Insofar we already hold information about
you, we may use that information for the same purposes.

* For the performance of our agreement with you/your entity: We use your
Personal Data in order to carry out our obligations arising from any
agreements entered into between you/your entity and us or a TMF managed fund,
and to provide you/your entity with the information or Services that you
require or request, including managing and handling you/your entity’s
investment in a TMF managed fund, your requests, inquiries or complaints.
* For marketing purposes, based on your consent: If you are a prospective
client: we use your Personal Data to send you marketing communications (such
as newsletters, promotions, news or service updates) via email or other
electronic means or via telephone, but we will only do so after we have
received your explicit consent to do so, unless otherwise allowed by
applicable laws. You can withdraw your consent, if any, as well as exercise
any of your rights at any time; see paragraph 9 (Your rights) below.
* To comply with our legal obligations: Any information referred to above under
paragraph 3 (Personal Data we process) may be used to comply with a legal
obligation to which TMF is subject, such as maintaining appropriate business
records, conducting Know Your Client identification procedures, commencing
risk assessment, complying with lawful requests by governmental agencies and
public authorities and to comply with applicable laws and regulations or as
otherwise required by law.
* For our legitimate commercial interests:
* If you are an existing client, vendor or business partner, their
representative or employee: we use your Personal Data (both on aggregated
and on individual basis), such as your contact details and your electronic
identification data for the purpose of advertising our Services that may be
of interest to you (based on the Services you or your entity previously
used), making contact with you for marketing or other commercial purposes.
We use your Personal Data for client, vendor and business partner
administration purposes, such as administration of Services agreements or
other agreements, as relevant, internal administration of work done under
such agreements.
* We use your Personal Data for analysing and improving the quality of our
Services and to understand you or your entity as a customer (customer
optimization). This enables us to assess what may interest you, to measure
or understand the effectiveness of advertising we serve to you and others
and to deliver relevant advertising. In addition, based on your historical
use of our Services we may target you with advertisement or other marketing
materials that are customized to your personal preferences and experiences.
* In addition, we use your Personal Data for our other legitimate commercial
interests such as, to operate and expand our business activities, to
develop and improve or modify our Services, to generate aggregated
statistics about the users of our Services; to assist in security and fraud
prevention; to administer our website and for internal operations,
including troubleshooting, data analysis, testing, research, and
statistical purposes.
* We also use your Personal Data for system integrity purposes (for example
the prevention of hacking, spamming etc.); to facilitate our business
operations, to operate company policies and procedures; to enable us to
make corporate transactions, such as any merger, sale, reorganization,
transfer of TMF Group’ assets or businesses, acquisition, bankruptcy, or
similar event; or for other legitimate business purposes permitted by
applicable law.

5. HOW WE SHARE YOUR PERSONAL DATA

We share your Personal Data with the following parties:

* Data controllers within TMF Group. Your Personal Data will be shared between
the TMF Group entities that may use your Personal Data as described in this
Privacy Statement for internal administrative purposes, management purposes,
analytical purposes and other business-related purposes. Each of the
recipient(s) shall be responsible for ensuring the appropriate protection of
your personal data, providing information on your data processing and
obtaining additional consents if required. Your Personal Data will only be
used by TMF Group companies for marketing purposes if you have given your
explicit consent thereto and/or where we have legitimate interest to do so.
An overview of the locations TMF Group entities operate in and TMF Group
entities as such can be found here.*
* Service Providers and Processors. We engage third party vendors to provide
Services for us or on our behalf, which may have access to your Personal
Data, including:
* * Business partners (such as law, tax and audit firms or finance providers),
including subcontractors which are engaged to perform (part of) the
Services under Services agreements;
* Suppliers (such as IT service providers);
* Marketing and advertising companies that carry out marketing activities on
our behalf;
* Analytics and search engine providers that assist us in the improvement
and optimisation of our website, such as Google Analytics.
* In providing their services, they will access, receive, maintain or otherwise
process Personal Data on our behalf. Any such services provider, prior to the
provision of their services, concludes a data processing agreement in line
with requirement of the relevant data protection legislation. Our agreements
with these service providers do not permit use of your Personal Data for
their own (marketing) purposes. Consistent with applicable legal
requirements, we take commercially reasonable steps to require third parties
to adequately safeguard your Personal Data and only process it in accordance
with our instructions. Third parties in case of legal requirement. We will
disclose your Personal Data if disclosure is required by law or in the
context of an investigation, regulatory requirement, judicial proceeding,
court order or legal process served on us, or to protect the rights or safety
of the website, us or our affiliated companies.
* Corporate transaction. In addition, information about our clients, including
Personal Data, may be disclosed as part of any merger, sale, transfer of TMF
Group’s assets, acquisition, bankruptcy, or similar event.
* Other third parties, based on your consent. We also disclose information
about you, including Personal Data to any other third party, where you have
consented or requested that we do so.

6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Due to the global presence of our business operations, TMF Group transfers
Personal Data you provide to us to countries other than your country of
residence. The laws of these countries may not provide the same level of
protection to your Personal Data. TMF Group or third parties we use will
therefore seek to ensure that all adequate safeguards are in place and that all
applicable laws and regulations are complied with in connection with such
transfer, in particular for Personal Data transferred to countries outside the
European Economic Area (“EEA”).

Intra-group data transfers within TMF Group take place on the basis of our
Binding Corporate Rules, which can be found on the TMF Group website
(https://www.tmfgroup.com/en/legal/dataprotection/binding-corporate-rules/).

For Personal Data that is transferred to third parties outside the EEA, we enter
into legally required agreements with these third parties, including the most
recent version of the standard contractual clauses as approved by the European
Commission or other supervisory authority where required. You are entitled to
receive a copy of any documentation showing the suitable safeguards that have
been taken by making a request via the local TMF Group entity which collected
your Personal Data or via email address dataprotection@tmf-group.com.

7. SECURITY

TMF Group will take reasonable steps to ensure that your Personal Data are
properly secured using appropriate technical, physical, and organizational
measures, so that they are protected against unauthorised or unlawful use,
alteration, unauthorised access or disclosure, accidental or wrongful
destruction, and loss., Encryption is applied to ensure data confidentiality
where deemed required; we deploy access control mechanisms to ensure only
authorized personnel can access personal data; and we raise awareness among
employees about the importance of protecting personal data through information
security and privacy protection trainings. Access to Personal Data is granted
using principle of ‘Least Privilege’. Furthermore, we contractually ensure that
any third party processing your Personal Data on behalf of TMF Group affiliate
adheres to CIA principles (Confidentiality, Integrity, Availability) in a secure
way.

8. DATA RETENTION

We retain your Personal Data for as long as required to satisfy the purpose for
which they were collected and used (for example, for the time necessary for us
to provide you with client Services) unless a longer period is necessary for our
legal obligations or to defend a legal claim.

We apply data retention terms as required under the applicable laws of the
country(/ies) where your data is being processed and further in accordance with
TMF Group Data Retention Policy. Where this policy or the applicable laws do not
determine otherwise, data retention term of ten (10) years is applied.

9. YOUR RIGHTS

Subject to the conditions set forth in the applicable law, you have the right to
request access to or rectification or erasure of your Personal Data and to
restrict or object processing of your personal data, as well as the right to
data portability. If you would like to exercise any of those rights, please send
an email to the local TMF Group entity which collected your Personal Data or
dataprotection@tmf-group.com specifying your request. You can also contact us
via the contact form available here: the TMF Group Data Subject Request Form. We
will respond to your request consistent with applicable law. In your request,
please tell us which right you would like to exercise, including what Personal
Data you would like to have changed, whether you would like to have it erased
from our database, or otherwise let us know what limitations you would like to
put on our use of it. We will try to comply with your request as soon as
reasonably practicable. Please note that we may need to retain certain Personal
Data for recordkeeping purposes and/or to complete any transactions that began
prior to your request on exercising your rights mentioned above.

In the event your Personal Data is processed on the basis of your consent, you
can withdraw your consent at any time by sending an email to the local TMF Group
entity which collected your Personal Data or dataprotection@tmf-group.com
specifying your request, without affecting the lawfulness of processing based on
consent before its withdrawal. Withdrawing your consent will not affect the
lawfulness of any processing we conducted prior to your withdrawal, nor will it
affect processing of your personal information conducted in reliance on lawful
processing grounds other than consent.

You may lodge a complaint with a supervisory authority, in particular in your
Member State of residence, if you consider that the collection and use of your
Personal Data infringes this Privacy Statement or applicable law.

CHANGES TO THIS PRIVACY STATEMENT

We reserve the right to update or amend the Privacy Statement as required under
the applicable laws, changes in organizational and technical measures, or other
further insights. If a fundamental change to the nature of the use of your
Personal Data is involved or if the change is in any other manner relevant to
you, we will ensure that information is provided to you well in advance of the
change actually taking effect.

If you have any queries about this Privacy Statement or our handling of your
Personal Data in general, or if you want to exercise your rights, please email
us at dataprotection@tmf-group.com and be sure to indicate the nature of your
query. You can also exercise your rights via the contact form included here.

DOWNLOAD

Privacy Statement – TMF Group | April 2024 | Version 2.2

Privacy Statement – TMF Group | September 2023 | Version 2.1

Privacy Statement – TMF Group | 1 April 2023 | Version 2.1

Privacy Statement – TMF Group | September 2022 | Version 2.0

Privacy Statement – TMF Group | June 2018 | Version 1.0

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WE MAKE A COMPLEX WORLD SIMPLE

TMF Group is a leading provider of critical administrative services, helping
clients invest and operate safely around the world. with over 11,000 colleagues
in more than 125 offices across 87 jurisdictions provide local expertise. Our
locations cover 92% of world GDP and 95% of FDI inflow.

We are a key part of our clients’ governance, providing the accounting, tax,
payroll, fund administration and legal entity management services essential to
their success. We make sure rules are followed, reputations protected and
operational compliance maintained. We work with the majority of the Fortune
Global 500, FTSE 100 and top 300 private equity firms.

Learn more about us Learn more about us
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Get in touch to find out how we can help your organisation grow in a complex
world.

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When you visit any website, it may store or retrieve information on your
browser, mostly in the form of cookies. This information might be about you,
your preferences or your device and is mostly used to make the site work as you
expect it to. The information does not usually directly identify you, but it can
give you a more personalized web experience. Because we respect your right to
privacy, you can choose not to allow some types of cookies. Click on the
different category headings to find out more and change our default settings.
However, blocking some types of cookies may impact your experience of the site
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These cookies enable the website to provide enhanced functionality and
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These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser to
block or alert you about these cookies, but some parts of the site will not then
work. These cookies do not store any personally identifiable information.

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These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

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These cookies may be set through our site by our advertising partners. They may
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