Privacy Notice

02

Scope of This Privacy Notice

This Privacy Notice may apply to personal information relating to:

• Prospective and existing investors
• Representatives of family offices
• Wealth managers
• Investment managers and advisers
• Business owners and entrepreneurs
• Directors and shareholders
• Portfolio company representatives
• Investment partners
• Professional advisers
• Suppliers and service providers
• Counterparties
• Prospective counterparties
• Website visitors
• Individuals submitting enquiries
• Individuals receiving authorised communications from us
• Job applicants and prospective employees
• Representatives of governmental, regulatory or professional organisations
• Other individuals with whom Asasika Group has a legitimate business relationship

The manner in which this Privacy Notice applies will depend upon the nature of your relationship with Asasika Group.

03

Data Controller

The relevant Asasika Group entity determining the purposes and means by which personal information is processed will generally act as the data controller in respect of that information.

In certain circumstances, another Asasika Group entity or third party may act as an independent controller, joint controller or processor.

Where required by applicable law, additional information identifying the relevant controller, representative or data protection contact will be provided at the point at which personal information is collected.

04

Personal Information We May Collect

Depending upon the nature of your relationship with Asasika Group, we may collect and process different categories of personal information.

05

Sensitive Personal Information

Asasika Group does not seek to collect sensitive or special category personal information unless it is reasonably necessary and permitted by applicable law.

In limited circumstances, information obtained through legal, regulatory, compliance or due diligence procedures may reveal information that receives additional protection under applicable privacy legislation.

Where such information is processed, Asasika Group will seek to ensure that an appropriate legal basis and additional safeguards apply.

06

How We Obtain Personal Information

We may obtain personal information directly from you when you:

• Visit or interact with our website
• Submit an enquiry
• Communicate with Asasika Group
• Provide information concerning a prospective investment
• Enter into a business or investment relationship with us
• Attend a meeting or event
• Subscribe to communications
• Provide documentation for due diligence or compliance purposes
• Apply for employment
• Otherwise provide information directly to us

We may also lawfully obtain information from other sources, including:

• Corporate entities with which you are associated
• Business partners
• Professional advisers
• Banks and financial institutions
• Investment intermediaries
• Portfolio companies
• Public registers
• Governmental and regulatory authorities
• Publicly available sources
• Professional databases
• Compliance and screening providers
• Fraud prevention services
• Due diligence providers
• Data and research providers
• Other persons or organisations where permitted by applicable law

Where personal information has not been obtained directly from you, we will provide information concerning our processing where required by applicable law.

07

Purposes for Which We Process Personal Information

Asasika Group may process personal information for purposes including:

• Managing investor and prospective investor relationships
• Evaluating investment opportunities
• Administering investments and transactions
• Conducting due diligence
• Verifying identity and beneficial ownership
• Assessing investor eligibility and classification
• Conducting anti money laundering checks
• Conducting counter terrorist financing checks
• Conducting sanctions screening
• Preventing and detecting fraud or other unlawful activity
• Managing relationships with family offices, wealth managers, professional advisers and counterparties
• Managing portfolio company relationships
• Processing transactions and payments
• Maintaining accounting and financial records
• Responding to enquiries
• Providing requested information
• Managing contractual relationships
• Operating and securing our website and technology infrastructure
• Maintaining CRM and business administration systems
• Protecting Asasika Group, its investors and counterparties
• Managing legal claims and disputes
• Complying with applicable legal and regulatory obligations
• Responding to lawful requests from governmental, judicial or regulatory authorities
• Managing recruitment and employment processes
• Maintaining appropriate business records
• Undertaking internal reporting, auditing and risk management
• Conducting appropriate business development and marketing activities
• Protecting and enforcing our legal rights
• Supporting corporate transactions, restructuring, financing or other legitimate business activities

08

Legal Bases for Processing

The legal basis upon which Asasika Group processes personal information will depend upon the relevant processing activity and applicable law.

Where legislation such as the UK GDPR or EU GDPR applies, we may rely upon one or more of the following legal bases:

09

Anti Money Laundering, Sanctions and Compliance

As part of investment, transaction and counterparty due diligence, Asasika Group may undertake identity verification and compliance screening where appropriate or required.

Information may be checked against relevant sanctions lists, politically exposed person databases, corporate registers, public records and appropriate compliance databases.

Such processing may be undertaken to comply with applicable legal obligations, protect the legitimate interests of Asasika Group and its investors, manage financial crime risk and protect the integrity of our business activities.

Where legally required or appropriate, information may be disclosed to competent governmental, judicial, regulatory or law enforcement authorities.

10

Marketing and Business Communications

Asasika Group may communicate with existing and prospective investors, professional contacts, family offices, wealth managers, advisers, counterparties and other business contacts regarding investment activities, corporate developments, events and services where permitted by applicable law.

We will use consent where consent is legally required.

Where applicable law permits communications on another lawful basis, we may rely upon that basis subject to applicable rights and safeguards.

You may request that we stop sending direct marketing communications at any time by using an unsubscribe facility provided in the relevant communication or by contacting us.

A request to stop marketing communications will not necessarily prevent us from contacting you regarding an existing investment, contractual relationship, legal obligation, security matter or other non marketing purpose.

11

Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Certain cookies may be necessary for the operation, security and functionality of the website.

Other cookies may be used, subject to applicable law and consent requirements, for analytics, preferences, performance, advertising or similar purposes.

Where consent is legally required for non essential cookies or similar technologies, such technologies should not be activated until the required consent has been obtained.

Users should be provided with an appropriate mechanism to accept, reject or manage applicable cookie preferences.

Further information should be provided within the Asasika Group Cookie Policy.

12

Sharing Personal Information

Asasika Group does not sell personal information.

Personal information may, where appropriate and lawful, be disclosed to:

• Asasika Group subsidiaries and affiliated entities
• Banks and financial institutions
• Investment partners
• Portfolio companies
• Fund administrators and investment administrators
• Custodians
• Payment service providers
• Professional advisers
• Lawyers
• Accountants and auditors
• Tax advisers
• Consultants
• Technology and infrastructure providers
• Cloud service providers
• CRM providers
• Cybersecurity providers
• Data storage providers
• Compliance and screening providers
• Due diligence providers
• Insurance providers
• Regulators and governmental authorities
• Courts and judicial authorities
• Law enforcement agencies
• Prospective purchasers, investors, financiers or counterparties in connection with a corporate transaction
• Other parties where disclosure is authorised by you or permitted or required by applicable law

Where third parties process personal information on our behalf, we seek to implement appropriate contractual and organisational protections where required by applicable law.

13

International Transfers

Asasika Group operates and maintains business relationships internationally.

Personal information may therefore be processed, accessed or stored in jurisdictions outside the country in which it was originally collected.

Data protection standards may differ between jurisdictions.

Where applicable privacy legislation requires safeguards for an international transfer, Asasika Group will seek to implement an appropriate transfer mechanism.

Depending upon the applicable legislation and circumstances, this may include an adequacy determination, approved contractual provisions, standard contractual clauses, the United Kingdom International Data Transfer Agreement or Addendum, binding arrangements within a corporate group or another legally recognised transfer mechanism.

Additional technical and organisational safeguards may be implemented where appropriate.

14

Data Security

Asasika Group seeks to maintain appropriate technical and organisational measures designed to protect personal information against unauthorised or unlawful processing and against accidental loss, destruction, alteration, disclosure or access.

Depending upon the nature and sensitivity of the information, such measures may include:

• Access controls
• Authentication controls
• Encryption where appropriate
• Network and infrastructure security
• Secure storage
• Role based access restrictions
• Monitoring and logging
• Data backup procedures
• Incident management procedures
• Confidentiality obligations
• Vendor due diligence
• Employee and contractor controls
• Business continuity procedures
• Regular review of security arrangements

No electronic transmission or information storage system can be guaranteed to be completely secure.

Accordingly, while Asasika Group takes reasonable measures to protect personal information, absolute security cannot be guaranteed.

15

Personal Data Breaches

Asasika Group seeks to maintain procedures for identifying, assessing, managing and responding to personal data breaches.

Where a breach triggers a legal obligation to notify a competent data protection or regulatory authority, Asasika Group will seek to make the required notification within the period prescribed by applicable law.

Where applicable law requires affected individuals to be informed, appropriate notification will also be provided.

16

Data Retention

Asasika Group retains personal information only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, regulatory, accounting, reporting, contractual and legitimate business requirements.

Retention periods may vary according to:

• The nature of the information
• The purpose for which it is processed
• The nature of the investment or business relationship
• Applicable limitation periods
• Legal and regulatory requirements
• Anti money laundering and financial crime obligations
• Tax and accounting requirements
• Potential or actual disputes
• Security considerations
• The need to establish, exercise or defend legal claims

Information that is no longer required will be deleted, anonymised or otherwise securely disposed of where appropriate and subject to applicable legal requirements.

17

Your Privacy Rights

Depending upon the jurisdiction and applicable privacy legislation, you may have some or all of the following rights:

• The right to be informed about how your personal information is processed
• The right to request access to personal information held about you
• The right to request correction of inaccurate or incomplete information
• The right to request deletion of personal information in certain circumstances
• The right to request restriction of processing in certain circumstances
• The right to object to certain processing
• The right to object to direct marketing
• The right to request portability of certain personal information
• The right to withdraw consent where processing is based upon consent
• The right to raise concerns with an applicable data protection authority
• The right to request information concerning certain international transfer safeguards
• Rights relating to certain automated decisions and profiling where applicable

These rights are not absolute and may be subject to legal exemptions, restrictions and conditions.

18

Right to Object to Direct Marketing

You have the right to object at any time to the processing of your personal information for direct marketing purposes where applicable law provides that right.

Where a valid objection is received, Asasika Group will cease processing the relevant personal information for direct marketing purposes as required by applicable law.

19

Exercising Your Rights

Requests concerning personal information should be submitted through the official contact details published by Asasika Group.

We may request information reasonably necessary to verify your identity before responding to a request.

This is intended to protect personal information from unauthorised disclosure.

We will seek to respond within the period prescribed by applicable law.

In certain circumstances, applicable law may permit an extension or allow us to decline or restrict a request. Where legally required, we will explain the relevant reason.

20

Automated Decision Making and Profiling

Asasika Group may use technology to support business administration, investment analysis, compliance, marketing, CRM management, risk assessment and operational processes.

We do not intend to make decisions based solely upon automated processing that produce legal effects or similarly significant effects upon an individual unless such processing is permitted under applicable law and appropriate safeguards are implemented.

Where applicable law requires specific information concerning automated decision making or profiling, such information will be provided to affected individuals.

21

Artificial Intelligence

Asasika Group may use artificial intelligence and automated technologies within appropriate business, investment, analytical, administrative, marketing and operational processes.

Where personal information is processed using artificial intelligence, we seek to ensure that such processing has an appropriate purpose and legal basis and is subject to applicable privacy, confidentiality and security requirements.

Personal information should not be submitted to third party artificial intelligence systems unless such use is authorised and appropriate safeguards have been considered.

Where artificial intelligence is used to make or materially support decisions affecting individuals, additional assessment, transparency or human oversight may be implemented where required by applicable law.

22

Confidentiality of Investor Information

Information relating to investors, prospective investors, investment structures, financial arrangements and transactions may be confidential.

Asasika Group seeks to limit access to such information to persons who reasonably require access for legitimate business, investment, legal, regulatory or administrative purposes.

Confidential information may nevertheless be disclosed where required by law, regulation, court order or a competent authority, or where disclosure is otherwise permitted under an applicable agreement or legal obligation.

23

Corporate Transactions

If Asasika Group or any part of its business undergoes a merger, acquisition, restructuring, financing, joint venture, sale, transfer or other corporate transaction, personal information may be disclosed to appropriate advisers, financiers, prospective counterparties and other relevant parties.

Where such disclosure occurs, Asasika Group will seek to ensure that appropriate confidentiality and data protection requirements are applied where required by law.

24

Third Party Websites

Our website may contain links to websites operated by third parties.

Asasika Group does not control the privacy or security practices of independent third party websites.

This Privacy Notice does not apply to the processing activities of independent third parties.

Users should review the privacy notices of external websites before providing personal information.

25

Social Media

Asasika Group may maintain accounts on social and professional networking platforms.

Where you interact with Asasika Group through a third party platform, information may be processed both by Asasika Group and the relevant platform operator.

The privacy practices of the platform operator are governed by its own privacy policies and terms.

26

Children

The Asasika Group website, investment activities and services are not directed towards children.

We do not knowingly seek to collect personal information from children except where legally necessary in connection with a legitimate investment, trust, family, employment or other lawful matter and appropriate safeguards are applied.

If we become aware that information relating to a child has been collected improperly, we will take reasonable steps to address the matter in accordance with applicable law.

27

Recruitment

Personal information supplied by applicants may be used to assess suitability for employment, communicate regarding applications, undertake appropriate background or reference checks and manage the recruitment process.

Applicant information may be shared with relevant personnel, professional advisers, recruitment providers and screening providers where appropriate.

Information concerning unsuccessful candidates will be retained only for an appropriate period having regard to applicable legal and legitimate business requirements.

28

Legal and Regulatory Disclosure

Asasika Group may process, retain or disclose personal information where reasonably necessary to:

• Comply with applicable law
• Comply with regulatory obligations
• Respond to court orders
• Respond to lawful governmental requests
• Assist competent law enforcement authorities
• Establish, exercise or defend legal claims
• Investigate suspected fraud or misconduct
• Protect the rights, property or security of Asasika Group, its investors, employees, counterparties or others
• Comply with anti money laundering, sanctions or financial crime requirements

Nothing in this Privacy Notice is intended to prevent Asasika Group from complying with a lawful obligation imposed upon it.

29

Data Protection Authorities and Complaints

If you have concerns regarding how Asasika Group processes your personal information, we encourage you to contact us so that the matter can be reviewed.

Depending upon where you reside and the legislation applicable to the relevant processing, you may also have the right to lodge a complaint with the competent data protection or privacy authority.

Where the United Kingdom data protection regime applies, individuals may have the right to complain to the UK Information Commissioner.

Where European Union data protection legislation applies, individuals may have the right to complain to the competent supervisory authority in the relevant Member State.

Where another jurisdiction's privacy legislation applies, rights of complaint will be determined by the applicable legislation and competent authority.

30

United Kingdom and European Economic Area Individuals

Where the UK GDPR, EU GDPR or related legislation applies to our processing, Asasika Group will seek to process personal information in accordance with the applicable requirements of that legislation.

This may include requirements concerning transparency, lawful processing, purpose limitation, data minimisation, accuracy, retention, security, accountability, individual rights and international transfers.

Where legally required because an Asasika Group entity is established outside the relevant jurisdiction but falls within the territorial scope of applicable legislation, an appropriate representative will be appointed and identified as required by law.

31

British Virgin Islands

Asasika Group is incorporated in the British Virgin Islands.

Where British Virgin Islands data protection legislation applies to a particular processing activity, Asasika Group will seek to process personal information in accordance with the applicable requirements of that legislation.

Nothing in this Privacy Notice should be interpreted as limiting any rights or obligations imposed by mandatory British Virgin Islands law.

32

Other Jurisdictions

Asasika Group may conduct business, maintain relationships or interact with individuals in multiple jurisdictions.

Additional privacy requirements may therefore apply depending upon the location of the relevant individual, Asasika Group entity or processing activity.

Where mandatory local privacy legislation provides individuals with additional rights or protections, those requirements will apply to the extent required by law.

33

Changes to This Privacy Notice

Asasika Group may amend this Privacy Notice periodically to reflect changes in law, regulation, technology, business activities or our processing practices.

The current version will be published on our website together with the date on which it was last updated.

Where a change materially affects the manner in which personal information is processed and applicable law requires additional notification, we will take reasonable steps to provide such notification.

34

Contact Us

Questions, requests or concerns relating to this Privacy Notice or the processing of personal information should be directed to Asasika Group using the official contact information published on our website.

Where a dedicated privacy or data protection email address is established, that address should be displayed within this section.

Requests concerning the exercise of privacy rights should clearly state the nature of the request and provide sufficient information to enable Asasika Group to identify the relevant information and verify the identity of the requester.

35

General Privacy Statement

Asasika Group regards the confidentiality, integrity and responsible handling of information as an important component of its corporate governance framework.

We seek to collect only information that is appropriate for legitimate business, investment, legal, regulatory or operational purposes and to maintain that information subject to proportionate security, confidentiality and governance measures.

This Privacy Notice should be read together with the Asasika Group Terms and Conditions of Use, Cookie Policy and any specific privacy, investment or regulatory notices applicable to a particular service, transaction or relationship.