DATA PRIVACY NOTICE

  1. This data privacy Notice (“Notice”) is issued and provided by each of the following entities (together “Andetta”, “we”, “us” or “our”):

Absolute Global Investment Fund B.V.

  1. The Notice is addressed to external individuals, professionals, and legal entities (collectively referred to as “you” or “your”) with whom we may interact, or may have interacted, in the course of our business, including any person with whom we or one of our investment companies (“Company”) has entered into a contractual relationship.

III. By means of this Notice, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process in accordance with the EU General Data Protection Regulation and/or other non-EU laws and regulations, as applicable (“Data Protection Legislation”). The Data Protection Legislation governs the meaning of the terms used in this Notice.

  1. When handling your data, we may act as data controller and/or data processor, as the case may be, in accordance with the Data Protection Legislation, depending on the circumstances in which personal information is collected, held or used. The data collection and processing may be in hard copy or through electronic instruments. The servers where your personal data are stored are located  in Cayman Islands.
  2. We may collect, store and process personal data received as part of the business relationship at any stage of the same relationship. Where your data are provided for investment purpose, we as data controller may directly (or through a third-party service provider) process your personal information. If you are an entity, we may process the personal information of your beneficial owner(s), employees, directors, officers and you shall make sure that these persons are properly informed of this Notice.
  3. Personal data may include: (i) personal identification information (e.g. name, date of birth, nationality, addresses, telephone number, ID details, signature samples, social security number); (ii) identification data provided by public authorities (e.g. tax and passport numbers); (iii) personal distinguishing marks (e.g. video or voice recordings); (iv) information surrounding life areas (e.g. professional activity, hobbies, family members); (v) financial information (e.g. investment profiles including preferences, creditworthiness data, origin of wealth and assets); (vi) communications (e.g. e-mail correspondence). You are responsible for ensuring that any personal data that you send to us are complete, updated, correct and sent securely. From time to time we may ask you to confirm the accuracy of personal data.

VII. The purposes of the processing include:

– the establishment of the business relationship (e.g. onboarding and disinvestments, compliance procedure, liaison with public authorities and service providers);

– the exercise of the rights and the fulfilment of both contract obligations (including implementation of pre-contractual measures) and legal obligations (e.g. reporting to tax authorities);

– maintaining and updating your data;

– marketing and promotional activities;

– notification regarding changes to our service offers or business;

– monitoring and improving the quality of our services;

– quality assurance and training purposes.

VIII. Personal data may be disclosed to: (i) any of our affiliated entities including their respective directors, officers, employees, agents, and service providers; (ii) any public or accredited authorities; any third parties processor and in general any relevant parties to the extent necessary for the establishment, exercise or defence of legal rights or contractual obligations; (iii) any relevant parties for the purpose of prevention and detection of crimes; (iv) any relevant parties in the event that we sell or transfer all or any relevant portion of our business or assets.

  1. In accordance with and to the extent permitted by the Data Protection Legislation, every data subject shall have the following rights:

– Request access to any personal data we hold about you, along with information regarding its nature, processing, and disclosure;

– Request rectification of your personal data if it is inaccurate or incomplete;

– Request erasure of your personal data (“right to be forgotten”), where applicable;

– Restrict further collection of personal data beyond what has already been gathered;

– Obtain and reuse your personal data, and transfer it to another controller (“data portability”);

– Restrict processing of your personal data under certain conditions;

– Withdraw your consent at any time, where processing is based on consent;

– Be informed without undue delay in the event of a personal data breach that may affect your rights and freedoms;

– Lodge a complaint with a supervisory authority regarding the processing of your personal data.

Notwithstanding the foregoing, we may exercise rights in connection with compelling legitimate grounds which override the data subject’s interest or where the data subject’s rights are not feasible, e.g. if data must be retained for the defense of legal claims or for compliance with applicable laws.

For any request, please contact us at Contact@AbsoluteGlobalFund.com

  1. By signing an agreement with us or approaching us or the Company for the establishment of the business relationship, you represent and warrant that: (i) you have provided all necessary Notices and obtained any required consents (including consents by any relevant data subject) for the lawful cross-border transfer of personal data to us, our affiliated companies, service providers and contractual partners for the whole duration and purpose of the business relationship; (ii) you will assist us with responding to data subject requests and with compliance obligations relating to security, breach notifications, data protection impact assessments, and consultations with supervisory authorities; (iii) you will notify us without delay on becoming aware of any personal data breach that may impact the business of the Company.
  2. We reserve the right to amend this policy at any time. The examples provided herein are illustrative and not exhaustive. You may have additional rights under applicable Data Protection Legislation. This notice is not intended to constitute legal advice and should not be relied upon as such. We recommend consulting a qualified professional to understand your rights under the relevant Data Protection Legislation.