Data Privacy Statement

Version: 1.0 October 2023

Investcorp Capital PLC ("we", "us", and "our") has created this privacy statement to demonstrate our commitment to privacy. Your right to privacy and data security is a primary concern. This privacy statement sets out the basis on which any information we collect from you, or that is provided to us, will be processed by us.

Please find below further information regarding the ways in which we process your personal data and your rights in relation to such data processing such data.

• 1. INFORMATION GATHERING AND USAGE

  • 1.1 Why personal data is used

    • 1.1.1We intend to give you as much control as reasonably possible over your personal data (information that can be used to identify you, such as your name, email address, telephone numbers, postal address, credit card information, etc.). There are times when we may need to collect and process personal data from you to provide you with the services that you have requested from us. Set out below is a non-exhaustive list of the types of personal data we might collect from you and the purposes for which we would use it.

      1. (a) Client onboarding, account opening, and maintenance

         We collect information in relation to know your client ("KYC") compliance checks to enable us to identify and verify the identity of prospective clients in accordance with anti-money laundering regulations. We also conduct KYC checks from time to time to ensure the information we hold on you is up-to-date. This may include your name, title, date of birth, passport copy, national ID number, driving license (or other government identification documents), address, email, phone number, nationality, citizenship, marital status, tax details, board information (i.e., directorships), income, salary, source of funds, licenses, and professional memberships.

      2. (b) Providing services to you (including any subscription or redemption)

         We collect information to enable us to market and deliver existing and new services to you, provide you with investor reports about your portfolio of investments, etc. This may include bank details, account balance, transaction history, investing preferences, investment history, risk tolerance, and wire transfer instructions.

      3. (c) Personalise our products and services

         We collect online identifying information through the use of cookies (please refer to our cookie policy) and analytics tools to allow us to tailor our website in accordance with your preferences. This may include information on your location to show the version of the site most relevant to your location, your usage of our website (e.g., user movement including page scrolling, clicks, text entered, etc.) to help us identify usability issues and improve the service delivered to you, and information on your device to ensure we show you the best version of the site suited to your device.

      4. (d) Special events

         We may collect information from you when we organize special events to which you subscribe, to enable us to better service your needs during your attendance at such events. We may take photographs at our events and it is possible that such photographs will include your image. We take such photographs for use in promotional materials for future events and we may upload these photographs to our website or microsites that we create for such events and/or as part of press releases or social media posts.

      5. (e) Compliance with legal or regulatory obligations

         We collect information in relation to compliance with our legal and regulatory reporting obligations. This may include executed certifications related to FATCA/CRS or other tax reporting requirements, etc.

      6. (f) Visitors to our offices

         If you visit our offices, we will collect information about you (such as your name and contact details, details of your appointment and the relevant Investcorp team members you are meeting, and the time and date of your visit) to enable us to verify your identity and record the fact of your visit for security and health and safety purposes.

    • 1.1.2 We may receive the above personal information from sources other than you directly, e.g., from investor transactions with us and our affiliates, and from banks in connection with investor transactions or from investor representatives.

    • 1.1.3 We also note that telephone conversations and instructions may be recorded, as proof of a transaction or related communication. Such recordings will be processed in accordance with the applicable data protection laws and shall not be released to third parties, except in cases where we or any other relevant entities are compelled or entitled by laws or regulations or court order to do so.

    • 1.1.4 Failure to provide your personal data may mean that we are not able to communicate with you or have a business relationship with you. Where we process your personal information for direct marketing purposes, please be aware that you may object to our processing your personal data in this way at any time (as set out in section 3.17 below). If you do so, we will log your objection, stop processing your data for direct marketing purposes, and we will not contact you again.

    • 1.1.5 We do not perform any regular automated decision-making activities, including profiling activities, where your personal data is processed by automated means, except as described above in relation to the use of cookies.

    • 1.1.6 We will only process your personal data if and to the extent applicable law provides a lawful basis for us to do so and in particular:

      (a) if you have consented to us doing so;

      (b) if we need it to perform the contract we have entered into with you;

      (c) if we need it to comply with a legal obligation; or

      (d) if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the provision of services by us, requests, administrative or operational processes within Investcorp, promotion of our products and special events, and direct marketing.

  • 1.2 With whom your personal data may be shared

    • 1.2.1 Your personal data may be shared with:

      1. (a) Investcorp Group

         We may share the personal data that you provide to us to other entities in the Investcorp group to the extent necessary for the purpose of providing services to you.

      2. (b) Third parties

         We may share the personal data that you provide to us to our service providers for the purpose of providing services to you. This may include the provision of your personal data to IT service providers, fund and other administrators, investment advisors, marketing advisors, legal and other professional advisors and other service providers we may deal with from time to time. We may also provide your personal data to any successor, or potential successor, to all or part of our business (or otherwise as necessary in connection with an investment into or transaction related to our business).

         We are also regulated in various jurisdictions and have reporting obligations and other regulatory requirements that may require us to disclose your personal data to those regulators. Furthermore, in order to carry out our business activities, we are often required by our counterparties who perform their own KYC procedures to provide certain information to them relating to Investcorp's beneficial owners or the beneficial owners of the investments arranged by Investcorp.

      3. (c) Security

         Investcorp will also process your personal data for the purpose of ensuring office security and for health and safety purposes.

      4. (d) Photographs

         As noted above, we use photographs we take at events to promote future events. Such photographs may include your image where you attend an event and we may publish these photos on our website, microsite, or as part of a press release or in a social media post.

    • 1.2.2 We will not otherwise use, share, disseminate, publish or disclose your personal data (except as may be required in response to litigation, investigations or other legally required disclosures).

• 2. WHERE WE STORE YOUR PERSONAL DATA

  • 2.1 We may transfer your personal data to, or store it in, a destination outside of the jurisdiction of the entity to which you provided it or the jurisdiction in which you are located. This is because Investcorp is a global business, with operations located in various jurisdictions, which uses service providers based in a number of locations worldwide.

  • 2.2 In some cases, your personal data will be stored in or transferred to jurisdictions outside of the Abu Dhabi Global Market ("ADGM") (a "third country"), where data protection laws are not as stringent as the applicable laws in the ADGM. Where the ADGM Commissioner of Data Protection has not issued an adequacy decision in relation to the third country where your personal data is processed, we will ensure that there are adequate safeguards in place to protect your personal information in accordance with applicable data protection and privacy law. We will do this through use of data transfer agreements implementing standard data protection clauses.

    • 2.2.1 Period for which we store your personal data

      We will store your personal data for only so long as is necessary to fulfil the purposes described above and in accordance with data retention periods prescribed by applicable laws and regulations. We regularly assess our need to retain personal data by reference to the purposes for which it was collected. Once our relationship with you has come to an end, we will retain the personal information for a period of time that enables us to maintain business records for analysis or audit purposes, comply with record retention requirements under applicable laws, defend or bring existing legal claims, and/or deal with any complaints about our services. Where it is no longer necessary to retain the data (and where legal obligations do not mandate further retention) we will securely delete your personal data.

    • 2.2.2 Links to third-party websites

      Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

    • 2.2.3 Electronic newsletters

      We may from time to time offer various free electronic newsletters. We do not spam, sell or rent email addresses and we will only send you our newsletter where we are complying with applicable laws regulating direct marketing. You may remove your address from our mailing lists by sending us an email.

• 3. YOUR RIGHTS

  • 3.1 You have a number of rights under data protection laws which may be exercised in certain circumstances. These are:

    • 3.1.1 Right to be informed

      You have a right to receive clear and easy to understand information on what personal data we hold, why we hold it and with whom we share it – these details are contained in our Privacy Notice.

    • 3.1.2 Right of access

      You have the right of access to your personal data. If you wish to receive a copy of the personal data we hold on you, you may make a data subject rights request.

    • 3.1.3 Right to rectification

      If your personal data is inaccurate or incomplete, you can request that it is corrected.

    • 3.1.4 Right to erasure

      You can ask for your personal data to be deleted or removed if there is not a compelling reason for us to continue to have it.

    • 3.1.5 Right to restriction

      You can ask that we block or suppress the processing of your personal data in certain circumstances. This means that we are still permitted to keep your data – but only to ensure we do not use it in the future for those reasons you have restricted.

    • 3.1.6 Right to data portability

      You can ask for a copy of your personal data for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal data you have provided us to another company in a safe and secure way.

    • 3.1.7 Right to object

      Where we are processing your personal information without your consent to pursue our legitimate interests, you may object to us processing your personal data (subject to any legal obligations). In particular, where we are using your personal data to contact you for marketing purposes, you may object to such processing at any time.

    • 3.1.8 Rights relating to automated individual decision making including profiling

      You have the right to ask us to:

      • . give you information about its processing of your personal data;
      • . request human intervention or challenge a decision where processing is done solely by automated processes; and
      • . carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.

    • 3.1.9 Right to complain

      You may contact us at any time where you believe that we are in breach of data protection law or where you wish to make a complaint about or data processing. While we hope that we can resolve any complaints for you, you do have the option complain to your local data protection authority (i.e., the Office of Data Protection in the ADGM). You may contact the Office of Data Protection by emailing: [email protected]

  • 3.2 For any of the requests listed above, please contact us. We will make reasonable efforts to respond promptly and at the latest within two months. Our response to such requests may be limited to information under our direct control. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, if your request for access is excessive or unjustified, we may charge a reasonable fee considering the administrative costs of providing the information or communication or taking the action requested.

  • 3.3 More information can be found on your rights here.

• 4. SECURITY

  • 4.1 Security measures

    • 4.1.1 We limit access to personal data that we collect about you to our employees and third party agents, who we reasonably believe need to have access to your information to provide you with the information or services you request from us. We have security measures in place to help protect against the loss, misuse and alteration of the information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standard so as to help safeguard against such occurrences. Where information is provided to us via our website, in certain areas the information passed between your browser and our system is encrypted with secure sockets layer ("SSL") technology to create a protected connection between you and our Site to ensure confidentiality. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We will use commercially acceptable means to protect your personal data, but we cannot guarantee its absolute security.
    • 4.1.2 If you have any questions about our security, you can email us.

  • 4.2 Children's privacy protection

    • 4.2.1 Investcorp does not target and its websites are not intended for children under the age of 16. Investcorp will not knowingly collect personal data from children, and will delete such data upon discovery. Where Investcorp requires personal data pertaining to children for the purpose of providing a service, the consent of an adult with parental responsibility for that child will be required.

• 5. OPTING OUT

  If you do not wish to receive certain communications from us you may opt out by: (i) declining the service offered, or (ii) informing us that you no longer wish to receive such communications. We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.

• 6. CONTACT DETAILS

  • 6.1 If you would like to get in touch with us with regards to your personal data, please contact us at:

    • 6.1.1 Address: Investcorp Capital PLC
      Al Maqam Tower
      Abu Dhabi Global Market Square
      Al Maryah Island
      Abu Dhabi, United Arab Emirates
    • 6.1.2 Email:
      [email protected]

• 7. CHANGES IN THIS PRIVACY STATEMENT

  Any changes we make to this privacy statement in the future will be posted on this page. We reserve the right to modify this privacy statement at any time, so please check back periodically to see any updates or changes to our privacy statement. If we make material changes to this policy, we will notify you by email, or by means of a notice on our website home page.