Nodem Capital Privacy Policy

Nodem Ltd (“we”) are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect about you.

What is personal information?

Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and email address but it also includes other pieces of information which can be used to identify you.

Who we are

We are the controller of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact Alex Branton using the details set out below:

• Full name of legal entity: Nodem Limited

• Name of relevant contact: Alex Branton

• Email address: abranton@nodem.com

• Postal address: 1a Britannia Street, London, United Kingdom

• Contact telephone number: 020 7126 8178

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

How will we use your personal information?

We only obtain, use and keep personal information where we need it for a specific purpose. We set out below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. The regulations require that we have a legal basis so that your privacy is protected.

Please see below the relevant section that may apply to you.

Personal information of investors of the private funds that we manage

We collect and use personal information about you, including:

• Payment information (bank account details);

• Financial information (financial status and history);

• Business affiliation;

• Documentary data, including passport or drivers licence or other forms of identification; and

• Historical information i.e. previous names and addresses.

The purposes of collecting, using and maintaining your personal information are as follows:

• To manage and report the performance of your investments;

• To maintain a record of contacts and correspondence;

• To notify you about changes to our service; and

• To protect against, identify and prevent fraud and other unlawful activity.

In accordance with the UK’s General Data Protection Regulation, such processing is necessary to carry out obligations arising from contracts entered into between you and us. In addition, processing is necessary to comply with applicable legal requirements and relevant industry standards.

Personal information of investors of the private funds to which we act as Investment Advisor

We collect and use personal information about you, including:

• Name and contact information;

• The company you work for and your job title;

• Business affiliation.

The purposes of collecting, using and maintaining your personal information:

• To report the performance of your investments;

• To maintain a record of contacts and correspondence;

• To notify you about changes to our service;

• To respond to your inquiries.

In accordance with the UK’s General Data Protection Regulation, such processing is necessary to enable us to provide services under the advisory agreements entered into with the private funds in which you have invested.

Personal information of prospective investors of the private funds and other business contacts

We collect and use personal information about you, including:

• Name and contact information;

• The company you work for and your job title;

• Business affiliation.

The purposes of collecting, using and maintaining your personal information:

• To send you promotional materials, newsletters and other communications;

• To maintain a record of contacts and correspondence;

• To maintain a record of services received from professional advisors and consultants;

• To respond to your inquiries;

• To provide you with information, products or services that you request from us or which we feel may interest you.

In accordance with the UK’s General Data Protection Regulation, such processing is necessary for our legitimate interest in running and promoting our business, as well as ensuring effective external communication and engagement.

We are required to make an assessment with regards to the benefits for us weighed against how appropriate it is to contact you in this way and whether it would be unfair to you. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our services and we will only do so if we decide it would be of interest or beneficial for you.

Personal information of job candidates

The personal information we collect:

• Name and contact information;

• Current and previous employment details (job title, company name, address etc.);

• Educational history;

• Evidence of your right to work in the UK and immigration status;

• Information about your health, including any medical needs or conditions;

• If you contact us regarding your application, a record of that correspondence.

For successful candidates, as part of the background reference check prior to employment, we also collect:

• Diversity and equal opportunities monitoring information – this can include information about your race or ethnicity, disability and other ‘special category data’;

• Credit history;

• Criminal record;

• Passport information.

The purposes of collecting, using and maintaining your personal information is to process an employment application if you have applied for a position with us.

Such processing is necessary for our legitimate interest in hiring the right person for our business and to comply with applicable legal requirements and relevant industry standards.

We also have a legal obligation to check that candidates are entitled to work in the UK.

Sensitive or special category personal data

Our services are not intended for children and we will not knowingly collect any data related to children.

Personal data is defined as ‘special category’ when it reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. It includes: – genetic data – biometric data that uniquely identifies a person – data concerning health – data concerning someone’s sex life or sexual orientation.

We will use this type of data to inform our statistics on the representation of the categories of individual as shown above and may share your data for statistical analysis. In both instances your data will be anonymised first.

In accordance with the UK’s General Data Protection Regulation, such processing is necessary for our legitimate interest in promoting equality of opportunity and constitutes substantial public interest in order to identify and monitor equal opportunity and treatment for various groups. We process this type of data to ensure meaningful equal opportunity and reporting.

Consequences of not providing some types of information

Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the services you asked for. In this case we may have to cancel the services but we will tell you if this is the case.

How do we collect information about you?

Typically we collect information from you when you contact us directly or provide information in order for us to provide our services. We collect information from and about you in the following ways:

• Through third parties including credit reference agencies and fund administrators.

• Through direct interactions when you give us your personal information by filling in forms, submit your CV or during correspondence with us. This includes when you apply for our services or are seeking employment. In addition, limited amounts of personal information is collected when you enquire about our business, speak, meet or correspond with our employees, or otherwise interact with us. We keep a record of any correspondence that you have with us.

Who we share your information with

We need to provide information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security. The third parties we share your information with are as follows:

• Companies who process personal information on our behalf, including:

• Cloud hosting solutions;

• Credit reference agencies;

• Fund administrators;

• Professional advisors, including:

• Accountants;

• Tax advisors;

• Lawyers.

Sending your information outside the United Kingdom (UK)

The regulations which have been put in place to protect your privacy apply throughout the UK. As explained in the section above we may send your information to other third parties who are based outside of the UK, namely the EEA, the United States of America and the Bailiwick of Jersey, however we will only share your information with them because the country we send your information to is deemed to provide an adequate level of protection by the Information Commissioners Office. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

Storing your information

The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorised use or disclosure. We review our retention periods for personal information on a regular basis and will ensure all records are safely destroyed if we no longer need to retain them or you have contacted us to request so.

We take all reasonable steps to keep your personal information accurate and, where necessary, up to date.

Your rights

You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you:

• To access your information;

• To request we correct your information;

• To request that we erase your information;

• To object to the processing of your information;

• To request a restriction in the processing of your information;

• To request a transfer of your information;

• To withdraw your consent.

If you wish to exercise any of these rights please contact Alex Branton at abranton@nodem.com. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.

Security

We take reasonable steps to ensure we have in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.