Anchor Investment Management Ltd
42 Reid Street
7th Floor
Hamilton HM 12
Bermuda

Tel: (441) 296 3515

PRIVACY NOTICE Continued

The types of personal data we may collect and use

The types of personal data we may collect will depend on the nature of our relationship with you and the purpose of which information is being collected. Such personal data might include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, signature, copies of identity documents, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information.

How long do we retain your personal information?

We will generally keep personal information about you for as long as necessary in relation to the purpose for which it was collected, or for such longer period if required under applicable law or necessary for the purposes of our other legitimate interests.

The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of seven years after the termination of any such relationship.

We will, from time to time, review the purpose for which we have collected information about you and decide whether to retain it, update it, or securely delete it, if the information is no longer required.

Do we share your personal information with third partiees?

To the extent it is relevant to the purpose for which we collect your information, we may share your personal data with third parties, such as:

• any person to whom we have a right or obligation to disclose personal data, or where we determine that disclosure is necessary to protect or defend our rights or property, including with regulators, courts of law, governmental, regulatory or law enforcement agencies;
• service providers and trading counterparties to our clients, including placement agents or distributors, brokers, banks, trading venues, clearing houses, custodians, corporate services providers, and providers of customer relationship management tools;
• reference agencies and other third parties conducting background checks in the context of employment or client, counterparty, or investment due diligence;
• any person, as directed by you; or
• any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

What are your rights?

You have certain rights under Data Protection Law and Personal Information Protection Act 2016 in respect of the personal data we hold about you and which you may exercise. These rights generally include:

• to request access to your information;
• to request rectification of inaccurate or incomplete information;
• to request erasure of your information (a “right to be forgotten”);
• to restrict the processing of your information in certain circumstances;
• to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
• where relevant, to request the portability of your information;
• where you have given consent to the processing of your data, to withdraw your consent; and
• to lodge a complaint with the competent supervisory authority.

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