Privacy Notice

This Notice Applies To You If

• You are an individual who is a client or investor in a fund or product we manage or advise.
• Your information was provided in connection with a client or investor (employee, director, officer, partner, trustee, or owner).
• You are a potential client, potential investor, or a representative of either.
• You contact us or our affiliates by email, telephone, or any other means.
• You are a visitor to any website operated by us or our affiliates.
• You are a representative of a supplier, service provider, professional adviser, or business partner.
• You are a director, officer, or senior manager of a listed company in which we may invest.

This notice and any applicable agreement sets out the basis on which we use your personal information. We are a data controller of your personal information.

Sources of Personal Information

We may use personal information that is:

• Provided by you via email, telephone, at meetings, or as part of an investment application.
• Collected or generated in relation to an investment or services involving you or the entity you represent.
• Received from third parties such as fund administrators, background check providers, public agencies, and directory providers.
• Collected using cookies and other technologies when visiting a The Qwik Group website.
• Obtained from public sources such as websites and regulatory filings.

Categories of Personal Information

We may use the following personal information:

• Personal details: name, title, addresses, telephone numbers, email addresses, date of birth, gender, citizenship, signature, photographs, and employment details.
• Financial details: investment information, income, assets, bank accounts, tax residency, and tax identification.
• Correspondence, call recordings, website usage data, IP addresses, and location data.
• Information related to know-your-client procedures, including background screening results.

How We Use Personal Information

The Qwik Group may use personal information to:

• Communicate with you and retain records of such communication.
• Conduct business development and marketing activities, including information about investment opportunities.
• Assess suitability for our services and carry out know-your-client procedures.
• Process and administer investments and service appointments.
• Carry out due diligence on service providers and administer those relationships.
• Meet any legal, regulatory, or self-regulatory requirement that applies to us.
• Administer The Qwik Group websites and ensure they are effectively presented.
• Respond to enquiries and complaints.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another compatible purpose.

Lawful Basis

We can only use your personal information when the law allows. The lawful basis will be one or more of the following:

• Where we need to perform a contract we have entered into with you.
• Where it is necessary for our legitimate interests — such as running day-to-day operations, managing risk, and complying with applicable law.
• Where use of sensitive personal information is necessary for reasons of substantial public interest.

Sharing Personal Information

As a global business, we may share your personal information with our affiliates and third parties including:

• Marketing providers that assist with delivering information to you.
• Service providers for the performance of contracts we have entered into.
• Analytics providers that assist in improving our websites.
• Fund administrators and other service providers in connection with investments.

We may also share your information if we sell or acquire any business or assets, if we are acquired by a third party, or if it is necessary to meet a legal or regulatory requirement.

Security

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

International Transfers

Our affiliates and third parties that receive your personal information may be based anywhere in the world. In such cases, we seek to ensure your personal information receives an adequate level of protection through standard contractual clauses or inter-governmental arrangements.

Retaining Your Personal Information

How long we hold your personal information will vary. We consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use, the purposes for which we use it, and applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you.

Your Rights

You have the following rights in respect of your personal information:

• Access — You may request details and a copy of your personal information.
• Rectification — You may request that we correct any inaccurate or incomplete information.
• Erasure — You may request that we delete your personal information, subject to legal entitlements to retain it.
• Restriction — You may object to and request restriction of our use of your information in certain circumstances.
• Direct Marketing — You may request that we do not use your information for direct marketing purposes.
• Portability — In certain circumstances, you may request your information in a structured, machine-readable format.

You will not have to pay a fee to exercise any of these rights, except where a request is clearly unfounded or excessive.

Changes to This Notice

We may update this notice at any time and will post updates on The Qwik Group websites. We may also notify you in other ways from time to time about our use of your personal information.

Third-Party Links

Our websites may include links to third-party websites, plug-ins, and applications. We do not control these and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

Contact & Complaints

If you have any questions about this notice or wish to exercise any of your rights, please email support@TheQwikGroup.com.You have the right to make a complaint at any time to the applicable supervisory authority for data protection issues in your jurisdiction.