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Submitted URL: http://www.collercapital.com/privacy-statement
Effective URL: https://www.collercapital.com/privacy-policy/
Submission: On August 28 via api from NL — Scanned from GB

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OUR COMMITMENT TO YOUR PRIVACY



Coller Capital Limited, Coller Capital Inc., Coller Capital Limited, Korea
Branch and Coller Capital (Hong Kong) Limited (collectively “we”, the “firm” or
“Coller Capital”) are committed to protecting the privacy of current and
prospective counterparties, investors, suppliers and other business contacts as
they interact with the firm in person, through the internet, or by other means.
Coller Capital is sensitive to the privacy concerns of individuals with whom the
firm interacts and has a long-standing practice with the goal of protecting the
confidentiality and security of personal information.

This Privacy Notice and Cookies Policy (this “Privacy Policy”) is designed to
tell you about Coller Capital’s practices regarding collection, use, storage,
and disclosure of personal data (as defined below). Examples of personal data
include your full name, email address, postal address, telephone number, job
title or the company you work for. We may collect your personal data via, as
relevant, the firm’s websites, mobile applications, products, software or
services that display a link to this Privacy Policy (collectively, the “Data
Sources”). Please be sure to carefully read this Privacy Policy in its entirety
before using or submitting personal data to a Data Source.

Additional supplementary information regarding privacy issues may be provided to
you in connection with a particular product or service provided or contracted by
us or any of our affiliates, whether provided through a website, by telephone,
in writing, or other medium. Such additional supplementary information may be
required by applicable law or as a result of the type or nature of the product
or service in question. You are encouraged to read all information provided to
you in connection with the use of your personal data.

If you are based in the United States (in particular, in California or Nevada),
please refer to the region-specific sections at the end of this Privacy Policy
which set out additional information relevant to the processing of your personal
data.


YOUR USE OF THIS SITE

Use of this website (or other Data Source) constitutes your agreement to the
terms of this Privacy Policy and applicable laws and regulations. Whenever you
submit personal data and any other information via this website (or other Data
Source), you acknowledge that such personal data will be collected, used and
disclosed in accordance with this Privacy Policy.


APPLICABLE DATA PROTECTION LEGISLATION

For the purposes of this Privacy Policy, “Applicable Data Protection
Legislation” means all applicable legislation relating to privacy or data
protection in force from time to time, including any statute or statutory
provision which amends, extends, implements, consolidates or replaces the same,
and in particular to the extent applicable and without limitation the Hong Kong
Personal Data (Privacy) Ordinance (“PDPO”), the Republic of Korea’s Personal
Information Protection Act (“PIPA”), the California Consumer Privacy Act, as
amended by the California Privacy Rights Act (“CPRA”), the EU General Data
Protection Regulation 2016/679 (“GDPR”), the GDPR as it forms part of the
domestic law of the United Kingdom by virtue of the European Union (Withdrawal)
Act 2018 (“UK GDPR”), and the Data Protection Act 2018. The terms “personal
data”, “controller”, and “process” (and its derivatives) shall have the meanings
given to them in the Applicable Data Protection Legislation. Where this Privacy
Policy uses terms which are defined in the Applicable Data Protection
Legislation, the definitions set out in the Applicable Data Protection
Legislation will apply.

We recognise that your personal data is valuable, and we process it in
accordance applicable law and, to the extent that it applies to your personal
data, Applicable Data Protection Legislation.


DATA CONTROLLER

Coller Capital is the data controller responsible for the processing of your
personal data collected from Data Sources under the Applicable Data Protection
Legislation (to the extent that it applies to personal data collected about you)
and other applicable law.


WHAT INFORMATION WE COLLECT, HOW WE USE THAT INFORMATION, AND LAWFUL BASIS

We collect personal data about you to provide you with products and services and
information about those products and services offered by us to you. We make sure
that the personal data we collect from you is necessary for and directly related
to this purpose. We will use and process your personal data lawfully, fairly and
in a transparent manner.

To the extent this information constitutes personal data, we use it to ensure
that content from the Data Sources is presented in the most effective manner for
you and your device because it is in our legitimate interest to improve our
customers’ online experience in relation to the Data Sources.

DATA SUBJECTS

PERSONAL DATA

PURPOSE

LAWFUL BASIS

Website users Usage information including device and browser data (Including IP
address, traffic data, clickstream information, time stamp, location data, web
logs, other communication data such as your browser type and version, time zone
setting and location, plug-in types and versions, operating system and platform;
and the resources that you access). Monitor use of the website to ensure content
is presented in the most effective manner for your device and to help develop
the website by compiling aggregate statistics about users to analyse usage
Legitimate interests:
Understanding user behaviour to present information on the website (of most
interest to users) and ensure it is displayed correctly and in a user friendly
way;To improve customer online experience. Consent (Where applicable, where we
have obtained consent from you to use your personal data for these purposes) To
identify and verify your identity and/or eligibility for our services Legitimate
interests (To make sure enquiry is genuine and not being made for fraudulent
reasons or is spam) Compliance with legal obligations (To confirm the details
you provide to us before entering into a relationship with you) Customers
(Including prospective customers) Personal contact details (Such as name, title,
addresses, telephone numbers, and email addresses) To identify and verify your
identity and/or eligibility for our services Legitimate interests (To make sure
enquiry is genuine and not being made for fraudulent reasons or is spam)
Compliance with legal obligations (To confirm the details you provide to us
before entering into a relationship with you) To communicate with you and
respond to feedback about your needs and expectations of our offered services
and/or products Legitimate interests (To use your personal data to communicate
with you, respond to your requests about the services and facilities you require
and develop the relationship between us in the context of your use of our
services and facilities) Account creation when you register for our services and
account maintenance Legitimate interests:



Using your personal data to communicate with you, to respond to your requests
and to develop the relationship between us in the context of establishing and
operating your account;

Keeping you informed of your account activities or service changes.

Performance of a contract with you (Where we are unable to provide our services
without this information) Compliance with legal obligations (Relating to how we
manage our relationship with you) Conducting research and/or analysis on the use
of our services and to evaluate and improve our services Legitimate interests
(To understand the trends in the use and popularity of our services to adapt
existing and offer new services based on this research and analysis) To provide
information related to Coller Capital and its affiliates, including offered
products, services and other privileges, benefits and advantages from time to
time, and share information about our relevant services, news and events
Legitimate interests (To develop our relationship regarding our services,
facilities and other privileges, benefits and other advantages) Consent (To
sending you marketing communications) Providing, administering and managing
services performing our contractual obligations to you Performance of a contract
with you (Where we are unable to provide our services without this information)
Your business affiliation Conducting research and/or analysis on the use of our
services and to evaluate and improve our services Legitimate interests (To
understand the trends in the use and popularity of our services to adapt
existing and offer new services based on this research and analysis) Determining
eligibility and suitability for services and other privileges, benefits and
other advantages offered Legitimate interests (To develop our relationship
regarding our services, facilities and other privileges, benefits and other
advantages) To provide information related to Coller Capital and its affiliates,
including offered products, services and other privileges, benefits and
advantages from time to time, and share information about our relevant services,
news and events Legitimate interests (To develop our relationship regarding our
services, facilities and other privileges, benefits and other advantages)
Consent (To sending you marketing communications) Information gathered from
other sources To identify and verify your identity and/or eligibility for our
services Legitimate interests (To make sure enquiry is genuine and not being
made for fraudulent reasons or is spam) Compliance with legal obligations (To
confirm the details you provide to us before entering into a relationship with
you)

We may combine information, such as the above personal data, we obtain from
other sources with information you give to us and information we collect about
you. We will use this information and the combined information for the purposes
set out above (depending on the types of information we receive).

We will let you know, if it is not identified above, where you must provide us
with personal data in order for us to be able to enter into or perform an
agreement with you or to comply with a legal obligation. You do not have to
provide your personal data to us, but, if you do not provide us with the
personal data in these circumstances, we may be unable to respond to your
enquiry and/or engage in further communications with you and/or enter into or
perform the contract we have entered or propose to enter into with you.

We will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose. In the circumstance that we use
your personal data for a different purpose than the purpose for which we
collected it, we will notify you, explain the legal basis which allows us to do
and ask for your consent for the additional purpose(s) (such consent only to be
requested if required by law).

We do not carry out automated decision-making or profiling in relation to your
personal data.


DISCLOSURE OF YOUR PERSONAL DATA

We may disclose any of your personal data to our affiliated companies, where
required by law or as set out in this Privacy Policy. We will not sell, trade or
rent your personal data to others.

However, we may make certain disclosures in answering any query from you or
providing you with services. We may disclose such disclosures:

TYPE OF PERSONAL DATA

RECIPIENT OF PERSONAL DATA

PURPOSE OF TRANSFER

LAWFUL BASIS FOR TRANSFER

Financial Information Service providers which may include the general partners’
investment manager, investment adviser, administrator, custodian and registrar,
as well as the Coller website’s host and IT and technical providers To ensure
any enquiries or applications are processed by the appropriate party in
accordance with your reasonable expectations Legitimate interest (For our
legitimate business interests, being the opening of investor accounts and
administering and managing your investments and interests in our investment
funds) Performance of a contract with you (To fulfil our obligations under our
subscription or other supplemental agreement with you) Lawyers and accountants
and other similar external advisors Where we need to take steps to defend
ourselves in respect of a legal claim or to comply with our legal obligations
Compliance with legal obligations (To comply with applicable laws, regulations,
legal processes or governmental requests – these may include anti-money
laundering and other financial crimes laws) Regulators, authorities and
governmental bodies Personal Contact Details Regulators, authorities and
governmental bodies Where we are required to do so to comply with our legal
obligations Compliance with legal obligations (To comply with applicable laws,
regulations, legal processes or governmental requests – these may include
anti-money laundering and other financial crimes laws) Service providers which
may include the general partners’ investment manager, investment adviser,
administrator, custodian and registrar, as well as the Coller Capital website’s
host, IT and technical providers. To ensure your request is processed by the
appropriate party in accordance with your reasonable expectations. Legitimate
interest (For our legitimate business interests, being the improvement of our
service delivery) Additional Data (including Details of outside directorships
and other outside interests and Information about criminal convictions and
offences) Service providers which may include the General Partner’s investment
manager, investment adviser, administrator, custodian and registrar, as well as
the Coller Capital website’s host, IT and technical providers To ensure any
enquiries or applications are processed by the appropriate party in accordance
with your reasonable expectations Legitimate interest (For our legitimate
business interests, being the opening of investor accounts and administering and
managing your investments and interests in our investment funds) Performance of
a contract with you (To fulfil our obligations under our subscription or other
supplemental agreement with you) Regulators, authorities and governmental bodies
Where we are required to do so to comply with our legal obligations Compliance
with legal obligations (To comply with applicable laws, regulations, legal
processes or governmental requests – these may include anti-money laundering and
other financial crimes laws) Device and Web Data Third party analytics providers
To administer our website and for internal operations, including
troubleshooting, data analysis, testing, research, statistical and survey
purposes. Consent (Where applicable, where we have obtained consent from you to
use your personal data for these purposes) Legitimate interest (For our
legitimate business interests, being the improvement of our service delivery)
Law enforcement agencies or other governmental bodies or authorities involved in
the prevention of crime To protect your Personal Data stored on, or accessible
through, our website from unauthorised access or theft Public interest (To
monitor and prevent unauthorised attempts to access to your account data or
other personal data stored on, or accessible through, our website, including
your financial data) Information about your use of our information and
communications systems, including internet or other electronic network activity
information Service providers which may include the general partners’ investment
manager, investment adviser, administrator, custodian and registrar, as well as
the Coller Capital website’s host, IT and technical providers. To ensure your
request is processed by the appropriate party in accordance with your reasonable
expectations and to analyse customer deliverability statistics, opens and
clicks. Legitimate interest (For our legitimate business interests, being the
improvement of our service delivery) Website Marketing Data Third party service
providers. Where you have indicated that you wish for us to receive
communications from third party service providers. Consent (Where applicable,
where we have obtained consent from you to use your personal data for these
purposes)

We do not share your personal data with third parties for those third parties’
direct marketing purposes.


RETENTION AND DATA INTEGRITY

We will keep a record of the personal data that we receive from you in order to
answer any queries from you, respond to any requests for more information about
the services and facilities we provide, and/or in order to provide those
services and facilities.

We will only retain the personal data collected from you for as long as is
necessary, including your account remaining active and not having been
cancelled, and reasonable to fulfil the purposes for which we have initially
collected such personal data (and any other purpose as described above) and/or
to comply with our legal or regulatory obligations.

We will make reasonable efforts to keep your personal data accurate, complete
and current.

We will delete our copy of your personal data within an appropriate time period
after our last contact with you although we may retain a record of the existence
of the relationship, to the extent and for so long as we are required to do so
by law or regulation. For example, if you have contacted us to ask us for the
processing of your personal data to be erased, we will retain a record of your
request in order to ensure we comply with your wishes.

Where we provide personal data to third parties who provide services on our
behalf, as detailed in the “Disclosure of your personal data” section above, we
do so subject to strict contractual terms that protect the personal data in
accordance with Applicable Data Protection Legislation.


INFORMATION SECURITY

We use appropriate technical, organisational, administrative and physical
security measures to reduce the risks of loss of, unauthorised access to, or
inadvertent destruction of, your personal data. We train our employees to handle
personal and business information in accordance with approved policies and
procedures that we have established to ensure compliance with applicable laws,
regulations and internal policies for protecting personal data, including
Applicable Data Protection Legislation. Only those employees with proper
authority and training are allowed access to your personal data.

You acknowledge that the transmission of information via the internet is not
secure. We cannot guarantee the security of your data transmitted to our public
website, any other site used by us and accessible by you or through electronic
communications, and any transmission is at your own risk.


INTERNATIONAL TRANSFERS OF PERSONAL DATA

If you provide personal data to us, it may be transferred to, processed in,
stored at or accessible from one or more destinations internationally to
jurisdictions outside the jurisdiction of the Coller Capital entity to which you
provided such data and outside the European Economic Area (“EEA”), and United
Kingdom (“UK”) as relevant, including territories that have not been deemed to
offer adequate protection to personal data by the European Commission or, as
relevant, are not subject to an adequacy regulation enacted by the UK
Government. It may also be processed by staff operating outside the EEA or, as
relevant, UK who work for Coller Capital or are a third party service provider.
Such staff may be engaged in, among other things, the provision of support
services.

Where we make such a transfer of personal data outside the EEA, or UK as
appropriate, we shall ensure appropriate safeguards are used and make such
transfer on the condition that enforceable data subject rights and effective
legal remedies are available. This may include an approved data protection
framework, or standard data protection clauses within agreements that we will
enter into which enable you to exercise your rights in accordance with the
Applicable Data Protection Legislation.


YOUR RIGHTS

With respect to the personal data that we collect about you as detailed in this
Privacy Policy, and to which the GDPR, UK GDPR, PIPA or HK PDPO applies, you
(and in some instances your legal representative(s)) may have the right
(depending on the Applicable Data Protection Legislation) to:

 * request access to that personal data;
 * receive a copy of the personal data that you have provided in a structured,
   commonly used and machine readable format so that you can share it with
   others;
 * request the transfer of your personal data to another party;
 * not be subject to a decision based solely on automated processing, including
   profiling;
 * withdraw your consent at any time (to the extent we are processing your
   personal data based on your consent);
 * ask that personal data be erased (please note that we may be required to
   retain certain personal data, but we will not retain such information for
   longer than is necessary for the relevant purposes. We require certain key
   personal data from you in order to provide you with information or services
   and if you ask us to remove all or part of such information, you may no
   longer be able to use or access such information or services, including our
   public website or parts of it);
 * request the rectification of your personal data, if you consider that it is
   inaccurate;
 * object to us possessing your personal data by asking for the processing of
   that personal data to be restricted or stopped; and/or
 * make a complaint to the appropriate data protection authority, which in the
   UK is the Information Commissioner’s Office, about the manner in which Coller
   Capital processes your personal data.

Please contact us using the details in the “Contact information” section below
if you wish to exercise any of these rights.

If you wish to exercise your right to make a complaint to the Information
Commissioner’s Office, which regulates and supervises the use of personal data
in the UK: they may be contacted at: Water Lane, Wycliffe House Wilmslow,
Cheshire SK9 5AF, e-mail: casework@ico.org.uk, website: https://ico.org.uk/,
helpline 0303 123 1113;

You also have the right to lodge a complaint with the Guernsey Data Protection
Authority, the Cayman Islands Data Protection Ombudsman, the Korean Personal
Information Protection Commission, the Hong Kong Office of the Privacy
Commissioner for Personal Data or another relevant authority or a supervisory
authority (as applicable) in the jurisdiction of your usual residence or place
of work or of the place of the alleged breach, if you consider that the
processing of your personal data carried out by us or any of our affiliates or
third-party service providers has breached data laws. You may also appeal to
certain courts against (i) any failure of the Guernsey Data Protection Authority
or another relevant authority (as applicable) to give written notice of whether
the complaint is either being investigated or not being investigated and where
applicable, the progress and the outcome of the investigation or (ii) a
determination of the Guernsey Data Protection Authority or another relevant
authority (as applicable) not to investigate the complaint or a determination
that a controller or processor has not breached or is not likely to breach an
operative provision in connection with the complaint.

In addition to the above, you can review, update, and correct your account
information and preferences at any time.

You also have the right to opt out of marketing communications at any time. You
may do so by clicking “unsubscribe” links provided in promotional email
messages, by amending your communication preferences, or by contacting us using
the details in the “Contact information” section below.


COOKIES

We may obtain and use information about your general internet usage by using
cookies and similar technology (referred to as “Cookies”). Cookies are small
text files that are downloaded on your browser or the hard drive of your
computer, mobile or other handheld device. Cookies contain information that is
transferred to your computer’s hard drive and your web browser then sends these
cookies back to us in order to help us improve your use of this website, to
monitor your activity during your visit(s) to the website, to distinguish you
from other users and to deliver a better and more personalised service. You can
find more detailed information about cookies and how they work at
http://www.aboutcookies.org.

By clicking the “Accept” icon in the cookie bar that appears on your first visit
to the website, you consent to our use of cookies as explained in this Privacy
Policy. You can withdraw your consent at any time by clicking “Decline” in the
cookie bar or generally by turning off the use of cookies, such as by the
methods described in the “Change your Cookie Preferences” section below, or you
can select the appropriate options on your web browser to delete individual
types of cookies. Please note, however, that if you block some or all cookies
(including necessary cookies), you may not be able to use or access all or parts
of the website, such as being able to log on to member specific areas.
Withdrawing your consent will not affect our use of the personal data processed
using cookies prior to you withdrawing that consent. For information on the
deletion of your personal data generally, including that processed through
cookies, please review the section “Your rights” above.

The following table sets out the types of cookies used on the website and
provides detail about what they are used for. When you use the website for the
first time, cookies which are essential to make the website operate (see those
identified as “necessary cookies” below) will have been set. Other cookies will
not have been set unless you consented to those cookies being set upon your
first visit to the website. If you have consented to accept cookies, then the
website will remember this and continue to set cookies each time you visit.

COOKIE TYPE

EXPLANATION

COOKIE NAME

SPECIFIC PURPOSE

Necessary cookies These cookies help make the website usable by enabling basic
functions like page navigation. The website cannot function properly without
these cookies. has_js
incap_ses_#
visid_incap_# This cookie registers whether or not you have activated JavaScript
in your browser.



These cookies preserve your user state across page requests.

Statistics cookies These cookies help us to understand how you and other users
interact with the website, by collecting and reporting information anonymously.
_ga
_gid
_gat These cookies register a unique ID that is used to generate statistical
data on how you use the website.



This cookie is used by Google Analytics to throttle the request rate.

Marketing cookies These cookies are used to track users across websites, with
the intention to display ads that are relevant and engaging for each user and
thereby more valuable for publishers and third party advertisers lpv401212
pardot
r/collect
visitor_id#
visitor_id#-hash Unclassified Unclassified cookies These are cookies that we are
in the process of classifying, together with their providers _utmvaplusyBKB
_utmvbplusyBKB
_utmvmplusyBKB Unclassified




CHANGING YOUR COOKIE PREFERENCES

If you would like to disable cookies, you can set your web browser to reject
cookies. However, if you disable the cookie function, you may not be able to
access or receive all the information contained on the website. How to alter
your cookie setting will depend on the type of browser or device you use. The
“Help” or “Internet Settings” functions within your browser should tell you how.
For information on how to manage cookies on popular browsers please see the
following links:

 * Google Chrome
 * Microsoft Edge
 * Mozilla Firefox
 * Microsoft Internet Explorer
 * Opera
 * Apple Safari

Alternatively, you may wish to visit http://www.allaboutcookies.org/ which
contains detailed information on cookies and how to delete, restrict or block
them on a wide variety of browsers. For information on how to do this on the
browser of your mobile phone you will need to refer to your handset manual.

To opt out of being tracked by Google Analytics across all websites, you may be
able to use the tool provided by Google available at:
http://tools.google.com/dlpage/gaoptout.

Please note that Google and other third parties (including, for example,
advertising networks, social media platforms and providers of external services
like web traffic analysis services) may also use cookies as a result of you
visiting other websites, over which we have no control.

We have a presence on the following social media platforms:

LinkedIn – https://www.linkedin.com/company/coller-capital/

YouTube – https://www.youtube.com/channel/UCuxowG9Q9rOJdYBqxdwSKHA/featured

Twitter- https://twitter.com/Coller_Capital/

The website includes links to these social media platforms and social sharing
icons. Whenever you leave our website following the above links, cookies might
be set by these social media platforms. Cookies might also be set by these
social media platforms if you are logged in to any of these social media
platforms or if you decide to share.

The cookie policies for those social media platforms are available through the
following links and contain information on how to control the setting of
cookies:

LinkedIn – https://www.linkedin.com/legal/cookie-policy

YouTube –
https://support.google.com/youtube/answer/32050?co=GENIE.Platform%3DDesktop&hl=en

Twitter – https://help.twitter.com/en/rules-and-policies/twitter-cookies


CHILDREN

We do not knowingly collect or maintain personal data from any person under the
age of sixteen. No parts of our website (or other Data Source) are directed to
or designed to attract anyone under the age of sixteen.


CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy and any other relevant
policies or procedures at any time. Any changes we may make to this Privacy
Policy will be posted on this page. You should regularly check and review this
page to ensure you understand how we may be processing personal data. Any
changes we may make to this Privacy Policy (which will, unless otherwise
indicated, apply to personal data already obtained before the changes were made)
will be effective from the date on which those changes have been posted on this
page. Where we decide it is appropriate to do so, we may also notify you of any
changes we have made by e-mail.


CONTACT INFORMATION

If you have any questions concerning this Privacy Policy or the policies or
procedures referred to above, please contact us by emailing
CCcompliance@collercapital.com and/or by post at Coller Capital Limited of Park
House, 116 Park Street, London, W1K 6AF marked for the attention of:

 * Legal & Compliance department; or
 * only in relation to marketing communications, the Marketing department.


NOTE FOR INDIVIDUALS BASED IN CALIFORNIA

California Consumers have certain rights afforded them under the CPRA. For
additional information on such rights and how to exercise such rights, please
visit Addendum for California Residents.


NOTE FOR INDIVIDUALS BASED IN NEVADA

Under Nevada law, we do not sell your personal information. However, if you are
a Nevada resident, you may submit a request that we not sell any personal data
we have collected about you by contacting us as set forth in the “Contact
Information” section.


DO NOT TRACK

Our website (or other Data Source) does not currently take any action when it
receives a Do Not Track request. Do Not Track is a privacy preference that you
can set in your web browser to indicate that you do not want certain information
about your webpage visits collected across websites when you have not interacted
with that service on the page. For details, including how to turn on Do Not
Track, visit www.donottrack.us.

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