NTREE INTERNATIONAL LTD. NOTICE OF EU PRIVACY POLICY

NTree International Ltd. (the “NTREE”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by NTREE is controlled by NTREE and NTREE is the data controller of your personal information.

Where your details are provided to NTREE as a consequence of your investment (or potential investment) in investment fund (the “Fund”), then NTREE, acting as a data controller, may itself (or through a third party such as a 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”).

NTREE’s data protection officer, located at 12 Hay Hill, London W1J 8NR, UK and can be contacted at Ashwin.Tirodkar@ntree.co.uk.

This policy (the “EU Privacy Policy”) explains the manner in which NTREE collects, utilizes 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 a Fund.

Collection of Your Personal Information

NTREE 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. Publicly available data sources; and
  3. Other interactions with NTREE (for example, discussions with our staff).

Why We Use Your Personal Information

Your Personal Information may be processed by NTREE (or any of affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:

  1. to facilitate your investment in a Fund and the management and administration of your investment in a Fund on an ongoing basis (the “Services”) which are necessary to fulfil all contractual and regulatory obligations related to your investment in a 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 NTREE 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 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 NTREE (including, for example, attorneys, accountants, auditors, or other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on NTREE or in order to pursue the legitimate interests of NTREE;
  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 NTREE relating to your investment or your potential investment in a Fund, and/or where the processing of Your Personal Information would be in the public interest.

Countries Having Access to Your Personal Information

NTREE’s servers, which store and keep Your Personal Information, are located in the EU and the United States.

NTREE also has service providers whose personnel will have access to Your Personal Information and that are located in other countries which have an adequate level of protection of Your Personal Information. The disclosure of Your Personal Information to the third parties set out above may involve the transfer of data to the United States and other jurisdictions outside the EEA. Such countries may not have the same data protection laws as your jurisdiction. NTREE is evaluating the contractual arrangements that it has with its third party service providers to determine if additional contractual protections are needed.

Collecting Investor Information Legally

NTREE is able to legally collect and use Your Personal Information either because:

  1. You have consented to us doing so; and/ or
  2. Collecting and using Your Personal Information is necessary for NTREE to fulfil our legitimate business interests, which may include (i) to fulfil contractual obligations to 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

NTREE 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.

Your Rights

You have the right to:

  1. be informed about Your Personal Information that NTREE collects from you, uses, and retains, which this EU Privacy Policy seeks to do;
  2. obtain confirmation from NTREE that Your Personal Information is being collected, used, and retained as described above and to access Your Personal Information held by NTREE;
  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 NTREE holds about you at any time, subject to NTREE’s rights to retain Your Personal Information for legitimate business purposes;
  5. block or suppress NTREE collecting and using Your Personal Information, which means NTREE 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 NTREE holds about you for your own purposes across different services, which allows you to move, copy or transfer Your Personal Information easily from NTREE to another place identified by you to NTREE in a safe and secure way without hindrance to the usability of Your Personal Information;
  7. object to NTREE 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 NTREE at Ashwin.Tirodkar@ntree.co.uk.

NTREE will confirm 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 NTREE to stop collecting, using and retaining Your Personal Information at any time by emailing NTREE at Ashwin.Tirodkar@ntree.co.uk.

You should note that notwithstanding your withdrawal of consent, NTREE may be legally required to retain some or all of Your Personal Information.

Where NTREE 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 a Fund and/or may be mandatorily redeemed from a Fund if you are already an Investor.

Protection of Investor Information

NTREE maintains appropriate technical and organizational 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 pseudonymization and encryption of Your Personal Information where appropriate;
  2. ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services;
  3. ensuring NTREE 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 organizational measures to attempt to ensure Your Personal Information is secure.

NTREE 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. NTREE will destroy, erase or make unreadable data, computer files and documents containing Your Personal Information that is non-public prior to disposal.

Further Information

This EU Privacy Policy is in addition to NTREE’s existing Privacy Policy adopted under US law, a copy of which is attached. NTREE reserves the right to change this EU Privacy Policy at any time. 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 contact us at Ashwin.Tirodkar@ntree.co.uk.

Making a Complaint

If you would like to make a complaint about the way NTREE has collected, used or retained Your Personal Information, please contact us at Ashwin.Tirodkar@ntree.co.uk.

You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement if you consider that the processing of personal data relating to you carried out by NTREE or its service providers infringes the GDPR.

Former Customers and Investors

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