INFORMATION FOR THE PROCESSING OF PERSONAL DATA MADE IN ACCORDANCE WITH ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679-GDPR (GENERAL DATA PROTECTION REGULATION)

Dear User,

Fundracer B.V., with registered office in Amsterdam, RSIN number 92951422, the management company of Fundracer investment fund(s), pursuant to EU Regulation No. 2016/679 (hereinafter “Regulation”) is required to provide you with certain information regarding the use of personal data.

This information is intended to be provided for the website https://fundracer.capital (hereinafter the “Site”), and not also for other websites that may be consulted by the user through links and is an integral part of the Site and the services we offer; the Information is provided in accordance with art. 13 of the Regulation to those who interact with the web services of the Site.

Your personal data will be processed in accordance with the legal provisions of the Regulations and the confidentiality obligations provided therein. The processing of your personal data, therefore, will be based on the principles of fairness, lawfulness, transparency, purpose limitation and storage, minimization and accuracy, integrity and confidentiality, as well as on the principle of accountability referred to in Article 5 of the Regulations.

DATA CONTROLLER AND DATA PROCESSORS

The Data Controller is the company Fundracer B.V. as identified above. The updated list of Responsible parties may be requested from the following e-mail address: rene.wiertz@fundracer.capital.

TYPE OF DATA PROCESSED

Navigation data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment. At present, data on web contacts do not persist for more than seven days.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of personal data in specific sections of the site (e.g. in the “Contact Us” section) as well as any other personal data included in the message, will be processed exclusively for purposes strictly related to the request (e.g.: responding to requests for information sent). Except for any processing required by law, any other purpose is excluded.

Cookies

Details about the cookies used on the Site are available in the “cookie policy” available at the following link, where you can customize your experience of using the Site.

PURPOSE AND LEGAL BASIS FOR PROCESSING

Personal data will be processed for the following purposes:

• Operational management and closely related purposes for accessing the website.

Legal basis for processing: consent and execution of a contract.

• Processing for statistical purposes in anonymous and aggregate form on the use of the site and control about the proper functioning of the same.

Legal basis for processing: consent and legitimate interest of the Data Controller.

• Fulfillment of any obligations under applicable laws, regulations or EU legislation, fulfillment of requests from authorities.

Legal basis of the processing: fulfillment of a legal obligation.

• Functional purposes of responding to your requests sent through the contact section on the site.

Legal basis of the processing: consent of the data subject.

NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL

The provision of personal data, while not mandatory, may be essential to enable the performance of our services.

In particular, for the purposes referred to in point d. the conferment is always optional, you may therefore decide not to confer any data or to subsequently deny the possibility of processing data already provided, revoking at any time the consent already given by sending a specific request to the Data Controller in the manner described in this information notice. However, denying consent may make it impossible to acquire your data and thus to respond to your requests.

METHODS OF PROCESSING

Your personal data will be processed with the aid of automated paper and/or computer tools, by Data Processors appointed pursuant to Art. 28 of Reg. (EU) 2016/679 or by persons authorized to process them for the time necessary to achieve the purposes for which they are collected or for any other legitimate related purpose (subject to your withdrawal of consent). At the end of this period, the data will be retained to comply with specific regulatory or contractual obligations, as well as for administrative purposes and/or to assert or defend a right, in case of litigation and pre-litigation.

In any case, the Data Controller undertakes to take appropriate technical and organizational security measures to prevent the destruction or loss of data, any unauthorized use and unauthorized access, pursuant to Article 32 of Reg. (EU) 2016/679.

Your data will not be disseminated in any way, but may be communicated to third parties whose activities are necessary and related to the achievement of the above-mentioned purposes (such as, by way of example: professionals, competent administrative and judicial authorities, professional legal advisory firms, national and/or international public authorities who are entitled to do so).

No automated decision-making processes, including profiling as referred to in Article 22(1) and (4) EU Reg. 2016/679, are involved in the processing.

TRANSFER OF PERSONAL DATA

Personal data processed by this Site are not transferred outside the European Economic Area. In any case, it is understood that the Data Controller, should it become necessary, will have the right to move the location of the servers to countries outside the EU. In this case, the Data Controller assures as of now that the transfer of data will take place in accordance with applicable legal provisions by entering into agreements, if necessary, that guarantee an adequate level of protection.

RIGHTS OF THE DATA SUBJECT

As a data subject, you may apply to the Data Controller to assert your rights, as provided for in Articles 15 to 22 of EU Reg. 2016/679, which we quote below:

• right to ask the Data Controller for access to personal data (Art. 15);
• right to ask the data controller for rectification (Art. 16);
• right to ask the data controller to erase them (Art. 17);
• right to ask the data controller to restrict processing concerning you (art. 18);
• right to data portability (art. 20);
• right to object to the processing (art. 21);
• right in relation to automated decision-making processes (Art. 22).

Where processing is based on Article 6(1)(a), you have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal.

You also have the right to lodge a complaint with the Data Protection Authority.

To exercise your rights, you may send an e-mail to rene.wiertz@fundracer.capital.