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Privacy Policy

Vintra Capital LLP (the “Investment Manager”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by the Investment Manager is controlled by the Investment Manager and the Investment Manager is the data controller of your personal information. Vintra Capital LLP is incorporated in England & Wales, the company registration number is OC356767.

Where your details are provided to the Investment Manager as a consequence of your investment (or potential investment) in a Fund managed by the Investment Manager (the “ Fund”), then the Investment Manager, acting as a data controller, may itself (or through a third party, such as StateStreet (Ireland) Limited (the “ Administrator”) acting in its capacity as the Fund’s administrator) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (the foregoing collectively, “ Your Personal Information ”). When processing Your Personal Information, there may also be times when the Administrator will act as a data controller.

This policy (the “EU Privacy Policy”) explains the manner in which the Investment Manager collects, utilises and maintains non-public personal information about investors and potential investors (“Investors”) based in the European Union (“EU”) or the European Economic Area (“EEA”), as required under the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This EU Privacy Policy applies to your investment or potential investment in the Fund. Vintra Capital LLP is registered as the data controller with the UK Information Commissioner’s Office (“ICO”), registration number ZA386691.

Collection of Your Personal Information

The Investment Manager collects Your Personal Information from the following sources, as applicable:

1. Subscription documents and other information provided by the Investor in writing, in person, by telephone, electronically or by any other means (this information includes (i) name,

address, income, financial and investment qualifications, and tax-related information and (ii) in the case of individuals, birth date, nationality, passport or other identification number, and

employment information, or in the case of entities, date and jurisdiction of formation, entity type, tax identification number, and business information);

2. Transactions within the Fund, including account balances, investments, redemptions and management fees and performance allocations; and

3. Other interactions with the Investment Manager (for example, discussions with our staff).

Why We Use Your Personal Information

Your Personal Information may be processed by the Investment Manager and/or the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:

1. to facilitate your investment in the Fund and the management and administration of your investment in the Fund on an ongoing basis (the “ Services”) which are necessary to fulfil all

contractual and regulatory obligations related to your investment in the Fund, including without limitation the acceptance and processing of subscription documents and redemption

and transfer requests;

2. in order to carry out anti-money laundering checks and related actions which the Investment Manager and/or Administrator considers appropriate or necessary to fulfil any of their legal

obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to

prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with the Investment

Manager’s and the Administrator’s anti-money laundering policies and procedures;

3. to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;

4. to disclose information to other third parties such as service providers of the Investment Manager and/or Administrator (including, for example, attorneys, accountants, auditors, or

other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on the Investment Manager and/or Administrator or in order to

pursue the legitimate interests of the Investment Manager and/or Administrator;

5. to monitor and record electronic communications and if applicable, calls, for any of the purposes specified herein; and/or

6. to otherwise pursue the legitimate interests of the Investment Manager and/or Administrator

relating to your investment or your potential investment in the Fund.

Countries Having Access to Your Personal Information

The Investment Manager’s servers, which store and keep Your Personal Information, are located in the EEA. The Investment Manager also has service providers whose personnel will have access to Your Personal Information and that are located in other jurisdictions. Transfers to these service providers are necessary for the performance of the contract between the Investment Manager and the Investor. These jurisdictions either (i) afford an adequate level of protection for Your Personal Information (as declared by the European Commission) or, (ii) if they do not, then the Investment Manager has entered into an agreement with these service providers incorporating clauses the same or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and obligations no less onerous than those contained in this EU Privacy Policy.

Collecting Investor Information Legally

The Investment Manager and the Administrator are able to legally collect and use Your Personal Information either because:

1. You have consented to their doing so; and/or

2. Collecting and using Your Personal Information is necessary for the Investment Manager and/or the Administrator to fulfil their legitimate business interests, which may include (i) to

fulfil contractual obligations to Fund Investors or otherwise perform the Services; or (ii) to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of

law or other judicial or regulatory forum, or otherwise protect their legal rights; and/ or

3. It is necessary to comply with any applicable regulatory, judicial or other legal obligation.

Retention of Investor Information

The Investment Manager and the Administrator will retain Your Personal Information for the purposes described in (1), (2), and (3) in the immediately preceding paragraph as long as required for the purposes described above. In particular, and without limitation to the foregoing, the Investment Manager and the Administrator have legal obligations imposed on them under applicable legal systems which requires them to retain Your Personal Information for certain minimum time periods. We will retain personal information for as long as necessary to provide our services to you, to fulfil the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy but will not hold any personal data for any longer than necessary.

Your Rights

You have the right to:

1. be informed about Your Personal Information that the Investment Manager and/or the Administrator collects from you, uses, and retains, which this EU Privacy Policy seeks to do;

2. obtain confirmation from the Investment Manager that Your Personal Information is being collected, used, and retained as described above and to access Your Personal Information held

by the Investment Manager;

3. have Your Personal Information corrected if it is inaccurate or incomplete at any time;

4. erasure, or the right to be forgotten, which means you can request deletion or removal of any of Your Personal Information the Investment Manager holds about you at any time, subject to

the Investment Manager’s or the Administrator’s rights to retain Your Personal Information as provided for under the GDPR;

5. block or suppress the Investment Manager collecting and using Your Personal Information, which means the Investment Manager can continue to store Your Personal Information but

cannot further collect or use it in any way;

6. obtain and reuse any of Your Personal Information that the Investment Manager holds about you for your own purposes across different services, which allows you to move, copy or

transfer Your Personal Information easily from the Investment Manager to another place identified by you to the Investment Manager in a safe and secure way without hindrance to

the usability of Your Personal Information;

7. object to the Investment Manager collecting, using or retaining Your Personal Information where this is based on:

a. your legitimate interest or the performance of a task in the public interest; or

b. direct marketing even if otherwise legally permitted; and

8. withdraw your consent to the use of Your Personal Information at any time, as described below.

To make any requests as listed above, please contact the Investment Manager at compliance@vintracapital.com. The Investment Manager will respond to any requests relating to your rights above within one month of receipt of your request, or within two months of receipt of your request where this request is more complex.

Withdrawal of Your Consent

You can tell the Investment Manager to stop collecting, using and retaining Your Personal Information at any time by emailing the Investment Manager at compliance@vintracapital.com. You should note that notwithstanding your withdrawal of consent, the Investment Manager may be legally required to retain some or all of Your Personal Information. Where the Investment Manager or the Administrator requires Your Personal Information to comply with AML or other legal requirements, failure to provide this information will mean that you will be unable to be accepted as an investor in the Fund and/or may be mandatorily redeemed from the Fund if you are already an Investor.

Protection of Investor Information

The Investment Manager maintains appropriate technical and organisational measures to ensure a level of security appropriate to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect customer information, including:

1. the pseudonymisation and encryption of Your Personal Information where appropriate;

2. ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;

3. ensuring the Investment Manager can restore access to Your Personal Information in a timely manner if a physical or technical incident occurs; and

4. regular testing, assessment and evaluation of the effectiveness of its technical and organisational measures to attempt to ensure Your Personal Information is secure.

The Investment Manager restricts access to the personal and account information of Investors to those employees who need to know that information in the course of their job responsibilities. The Investment Manager will destroy, erase or make unreadable data, computer files and documents containing Your Personal Information that is non-public prior to disposal. Despite these precautions, however, Vintra Capital LLP cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal data. In the event of a data breach, VintraCapital have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.

Making a Complaint

If you have any questions, comments or complaints about this Policy, or the general use of your information, please contact compliance@vintracapital.com. You also have the right to make a complaint to the relevant Supervisory Authority about our use of your information. In most cases under this Policy the relevant Supervisory Authority will be the Information Commissioner’s Office (“ICO”). The ICO can be contacted at https://ico.org.uk or telephone on 0303 123 1113.

Former Customers and Investors

This EU Privacy Policy also applies to former Investors in the EU and the EEA.

Further Information

The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive. This EU Privacy Policy complies with the GDPR regarding privacy. You may have additional rights under other foreign or domestic privacy laws in addition to those that are described above. If you have any questions about this EU Privacy Policy, please email us at compliance@vintracapital.com.

Changes to the Privacy Policy

Vintra Capital LLP reserves the right to modify or amend the Privacy Policy at any time and for any reason, as permitted by applicable law. If there are material changes to the Privacy Policy, we will post those changes here.

Last updated on 4 March 2021.