Effective 28th of April 20211. ENTITY RESPONSIBLE FOR PROCESSING AND PRINCIPLESThe responsible entity for processing, D Global Ventures LLC, c/oCorporation Service Company, 251 Little Falls Drive, Wilmington, County of NewCastle, Delaware 19808 (hereinafter referred to as "DGV"), recognizes the importance of keeping the personal data of its customers confidential and protecting their privacy rights. Regarding its activities and the data collected by it, DGV intends to apply the most restrictive principles and standards that are identifiable with respect to the protection of personal data.Consequently, all personal data and information (hereinafter referred to as "Data") provided in connection with our services will be processed lawfully, fairly, transparently and confidentially by DGV.2. CONSENTBy contracting the services offered by DGV (hereinafter referred to as the "Services"), and in accordance with the legal provisions in force, you acknowledgeand agree that, in connection with our Services, Data is or will be collected by DGV. The Data will be collected and used solely for the purposes of the Services offered by DGV or any subsequent contractual relationship with DGV.Therefore, entering into an engagement with DGV means that you agree to the collection, processing of Data and agree to this Policy.3. LEGAL BASIS AND PURPOSES OF DATA COLLECTION AND PROCESSING3.1 Legal BasisThe Subject concerned acknowledges that the collection and processing of Data by DGV is necessary for the fulfilment of the mandate entrusted to DGV to which the Subject concerned is a party in connection with the Services, but also for the preservation of the legitimate interests of DGV and for the fulfilment oflegal obligations incumbent upon DGV.3.2 PurposesThe Data is collected and processed by DGV for the following purposes(hereinafter referred to as "Purposes"): The opening and maintaining of the contractual relationship with the Subject or the beginning of a business relationship with DGV (hereinafter referred to as "Business Relationship"), including all formalities relating to the identification of the Subject and of any person or entity over whom the Subject or a third party provides information and / or of which DGV has knowledge in any other way in connection with the Business Relationship (hereinafter referred to as "Related person"). Any other related services provided by DGV' service providers and subcontractors in a Business Relationship. The management, administration, placement and distribution of financial products, including all services related to these activities. Compliance with legal and regulatory obligations to which DGV is subject under regulations applicable to Swiss financial intermediaries (Money Laundering and Enforcement Act, International Financial Regulations (e.g. FATCA, Automatic exchange of information). Weighing interests, to protect the interests of DGV or third parties: prevention and elucidation of criminal offenses, risk management, exercise of rights and defense in litigation, consultation and exchange of information with information desks, computer security, safety of buildings and facilities. DGV Customer Management: DGV's customer administration, invoicing services, marketing (newsletters, event invitations, etc.) and others.4. WHAT DATA IS COLLECTED?4.1 Types of DataAs part of the Services, DGV collects the following data (contemplative, on-exhaustive list) from its counter-parties (customers, administrators of private equity vehicles, lawyers, banks, other financial intermediaries): Identification data: personal identification data (name, surname, title, tax identification number) and structural identification data (information relating to investment entities). Identification data issued by public authorities and other registers: identity cards, passports, certificate of incorporation, articles of association, share registers. Location data: personal and business addresses of investment entities. Communication and electronic identification data (personal and business): telephone number, e-mail address. Financial data: identification number and bank account numbers, financial means / assets, financial transactions.4.2 Information Collected Directly from SubjectsDGV collects and records all information provided to it in connection with the Services or by any other means in its Customer Relationship Management (CRM) system. The Subject may choose not to provide DGV with certain information, however this decision may have the effect of depriving the Subject of certain Services or features offered in connection with the Services.4.3 Information Collected from Third Parties - Subcontractors As part of its Services, DGV may also collect data from third parties (introducer, trustees, administrators of private equity vehicles, lawyers, banks, other financial intermediaries, list of international sanctions, information available to the public (e.g. Bloomberg, World-Check, FACTIVA or LexisNexis).Data collected from third parties is treated in the same way as Data collected directly from the Subjects (see paragraph 4.2 above).DGV may be considered as a processor of personal data in the context of information collected from third parties, according to the applicable regulations. Should this be the case and necessary, DGV will enter into subcontracting agreement with the third parties concerned to ensure compliance with the present Policy.
D Global Ventures LLC is a Delaware-based company.