Dravnox Capital Privacy Notice

Last revised: 01 March 2025

Introduction

Dravnox Capital is committed to safeguarding and processing personal information (“PI”), including sensitive personal information (“SPI”)¹, in line with all applicable privacy and data protection laws. Many of our offices are located in countries with laws governing the processing of PI. “Dravnox Capital”, “we”, “us” or “our” means Dravnox Capital, Inc., each of the direct or indirect subsidiaries of Dravnox Capital and Dravnox Capital managed products. Dravnox Capital functions and the entity you contract with are the controllers of your PI. Where we process your PI without a contract with you, the controller is the entity providing you with this Privacy Notice.

References to “you” or “your” refers to individuals whose PI is processed by Dravnox Capital, including individual investors, individuals in the alternative business industry, client employees, officers or agents (together “Representatives”) with direct or indirect relationships (such as those who invest through an intermediary); and beneficial owners of an organization or entity in connection with:

• the provision of services to potential and actual clients;
• transactions to which we are party (including those which we effect on behalf of clients); or
• services provided to us by a third-party vendor.

If your contract is with the Dravnox Capital entity you contract with will be the controller of your PI. If you are an investor in a Dravnox Capital managed
product, the associated Dravnox Capital management company and the managed product, if a separate legal entity, will be separate controllers. This privacy notice applies to your relationship with Dravnox Capital.

This Privacy Notice sets out the purposes for which we collect, use, and disclose (collectively “Processing”) PI and how it is protected. It also sets outs individuals’ rights in relation to the processing of their PI.

There may be additional terms, conditions and commitments that also govern how we collect, use and disclose your PI, which should be read in conjunction with this Privacy Notice.

PI we collect about you

PI is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include
information where the identity of the individual or the specific detail of the information has been removed and is therefore non-attributable. Depending on your jurisdiction, SPI is a sub-category of PI that may include PI relating to race or ethnicity, government identifiers, geolocation information, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data, among others.

The nature of the information that we collect will depend on the services provided, applicable laws and our relationship with you. We categorize the PI we may
process as follows (the PI listed for each category are non-exhaustive examples):

• Identification data
  Full name, title, gender, marital status, date of birth, passport number, driving license number, national identification number, signature.
• Contact data
  Personal address, telephone number, email address.
• Electronic Monitoring data
  To the extent permitted by law, we may record and monitor your electronic communications with us, including telephone conversations, email, instant messaging and any other electronic communications.
• Financial data
  Account number, client reference number; account statements, investment history.
• Marketing, Behavioral and Communications data
  Marketing and communication preferences; information about your use of our websites, our portals and platforms as explained in our Cookie Notice.
• Professional Information data
  Firm name, position/job title, work and education history, business address, business telephone number, business email address, B2B social media ID (e.g., LinkedIn profile URL, WeChat ID).
• Profile and Interaction data
  Username and password for our online services that you have access to, investments made by you, services requested, as well as participation information and marketing communications in connection with survey responses, e-mail campaigns, chat bot interactions and social media advertisement.
• Services data
  Payment details to and from you, details of services you have provided to us, or we have provided to you.
• Dravnox Capital Building and Assets Security data
  Records of visits to our premises, CCTV recordings.
• Technical data
  Your use of and interaction with our online services, your IP address browser type and version, browser plug in types, geographic location, language, access time, referring website and versions operating system.
• SPI
  In limited circumstances we may collect information about criminal convictions and offences, when legally required; dietary requirements, if we are arranging catering; disability, to make reasonable accommodations for you in our buildings; political affiliations, for us to determine whether you are a politically exposed person. Additionally, some of the other information described above may be considered “sensitive” under certain laws. We do not use or disclose SPI for purposes other than those permitted by relevant laws.

We collect PI in relation to you in several ways, including:

• Directly from you when provided to us, for example in connection with a Dravnox Capital product or service; such as a completed investment application form.
• If you are Representative of an organization or entity that is a client or vendor of Dravnox Capital, and that organization or entity provides us with your PI.
• Throughout the course of our relationship with you or your employer, including where you change your details, provide additional PI, or where the services we are providing to you change.
• From documentation we receive in the course of our relationship with from a General Partner or Limited Partner of the company you are engaged with.
• From public sources such as company corporate websites or social media (in particular LinkedIn), regulatory filings and news, including where you have been interacting
  with us via social media or where you have been notified that your PI is considered for talent acquisition purposes, including via public profiles on social media.
• From e-mail or advertising campaigns and surveys.
• From other Dravnox Capital entities or third parties such as credit reference agencies and data brokers.
• From visits to our websites, use of our chat bots or through logging into any of our online services (including by cookies or other tracking tools).
• From attending in-person or virtual events or trainings organized or co-sponsored by Dravnox Capital..

We may also create or derive PI such as creating records of your interactions with us, subject to applicable law.

Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with
the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.

Purpose and legal basis for processing your PI

The below table sets out the purposes and basis for which we process PI.

In relation to vendor services:

To whom we disclose your PI

In connection with one or more of the purposes outlined in the section ‘Purpose and Legal basis for processing your PI’ above, we may disclose PI in any jurisdiction to:

• other members of the Dravnox Capital Group;
• professional advisors, third parties, agents or independent contractors that provide services to any member of the Dravnox Capital Group (such as IT systems providers, data analysis providers, platform providers, financial advisors, brokers, consultants (including lawyers and accountants));
• goods and services providers (such as providers of marketing, payment and billing services or debt collection agencies where we are permitted to disclose your personal
  information to them), intermediaries, brokers, and other individuals and entities that partner with us;
• customers and partners (including investors, fund managers, service providers, and advisors in the alternative assets industry) that have subscribed to specific services
  offered by any member of the Dravnox Capital Group (e.g. data base services);
• competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their
  agents where Dravnox Capital is required or allowed to do so under applicable law or regulation;
• a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of Dravnox Capital’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
• credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorist financing checks and to detect fraud and other potential criminal activity; and
• any person to whom disclosure is allowed or required by local or foreign law, regulation, or any other applicable instrument.

International transfers and transfers to service providers

To provide global services and in the course of running our business, we may transfer PI to a location outside of the country where you reside or where services are provided to you or the organization or entity you work for, including Dravnox Capital processing and/or research centers in Europe, USA, and Singapore. Although the country to which PI may be transferred may not have the same level of privacy and data protection laws, we apply the same level of
security and organizational controls to the processing of PI wherever it is processed. We require by contract that our third-party service providers processing PI on our behalf to comply with Dravnox Capital’s criteria for PI processing.

If we transfer PI out of the EEA, we ensure a similar level of protection for your PI by ensuring the country to which the PI is transferred is considered by the EU Commission to provide an adequate level of protection or putting in place contractual clauses the EU Commission consider provide the same level of protection.

Marketing and exercising your right to opt-out of marketing emails and Personalization In certain jurisdictions, you will need to expressly consent to receive marketing

emails. If you are an authenticated user on our websites and platform, we may provide you with a personalized experience based on your user behaviour.

In all jurisdictions, you can choose not to receive such communications at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making a request to your usual Dravnox Capital contact, by using the contact details set out in the “Contacting Us” section of this Privacy Notice, or, in relation to certain third party advertisements, by exercising your rights related to cookies as explained in our Cookie Notice.

Third-party marketing/sale of PI

Some entities in the Dravnox Capital Group may sell certain PI. For example, Preqin sells Identification data; Contact data; and Professional Information data to
its customers who subscribe to certain of our databases for their own purposes, including marketing. We also share for targeted advertising or cross-context behavioral advertising purposes the following categories of PI to advertising networks and social media networks: Profile and Interaction data; Technical
data; and Marketing, Behavioral and Communications data. We do not knowingly sell or share personal information of individuals under 16 years of age.

Because of certain of these activities, Preqin, a Dravnox Capital Group member, is a data broker under Texas law. To conduct business in Texas, a data broker must register with the Texas Secretary of State (Texas SOS). Information about data broker registrants is available on the Texas SOS website at https://www.sos.state.tx.us/index.shtml.

You will find information on your right to opt-out from such processing in the section “Your rights”.

PI retention

We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.

PI security

We use a range of physical, electronic, and managerial measures designed to ensure a level of security appropriate to the risk of PI processing. These measures may include:

• education and training of relevant staff to ensure they are aware of our privacy obligations when processing PI as well as training around social engineering, phishing, spear phishing, and password risks;

• the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• the ability to restore the availability and access to PI in a timely manner in the event of a physical or technical incident;
• administrative and technical controls to restrict access to PI;
• technological security measures, including fire walls, encryption (industry standard SSL encryption with 128-bit key lengths), and anti-virus software;
• physical security measures, such building access controls;
• external technical assessments, security audits and vendor due diligence;
• perimeter security;
• segregation of networks;
• application security;
• endpoint security;
• real-time monitoring of data leakage controls;
• layered and comprehensive cybersecurity defences; and
• security incident reporting and management.

The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavour to protect PI but cannot guarantee the security of data transmitted to us or by us.

Your rights

In certain circumstances you may have the following rights in relation to the processing of your PI:

• Know or Access
  To request a copy of the PI we process in relation to you and to be informed about how we collect, use and share your PI.
• Object
  To object to the processing of your PI if (i) we are processing your PI on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your PI for direct marketing purposes.
• Opt Out
  Depending on the laws of your jurisdiction, to opt out of sales or sharing of your PI including for cross-context behavioral advertising or targeted advertising.
  
  
  • To opt out of sharing for such advertising purposes through the Dravnox Capita website, you may do so by selecting “Manage Cookies” below and toggling off Marketing/Tracking/Profiling Cookies.
  • To opt out of all other sales, please email us at support@dravnox.com.
• Withdrawal
  To withdraw your consent you have provided at any time. The withdrawal of consent does not affect the lawfulness of processing of your PI based on consent before the withdrawal.
• Correction
  To request that we update the PI we process in relation to you, or to correct PI that you think is incorrect or incomplete.
• Erasure
  To ask that we delete PI that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
• Restriction
  To request that we restrict the way in which we process your PI, for example, if you dispute the accuracy of your PI or have raised an objection which is under consideration.
• Portability
  To request a copy of your PI that you have provided to us in a commonly used electronic format such as through the completion of an application form.
• Automated decision making
  To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar effect to you.

You may exercise your rights at any time by emailing support@dravnox.com or using the details set out in the Contacting us section.

To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the PI processed in relation to you, including, for example, the nature and location of your relationship with us.

We will respond to all legitimate requests in line with the timescales set out in applicable law.

Depending on the laws of your jurisdiction, you may designate an authorized agent to submit a request on your behalf either in writing or through a power of attorney. Before processing your request, we will require the authorized agent
to provide written proof of authorization and may require you to verify your own identity and confirm your authorization directly with us.

You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.

Under certain U.S. laws, certain members of the Dravnox Capital Group are required to disclose metrics related to how they have responded to rights requests under applicable privacy laws. These metrics are as follows:

Contacting us

The Global Head of Privacy and Data Protection oversees compliance with privacy and data protection at Dravnox Capital. If you wish to exercise any of your rights, or have questions concerning this notice, please contact:

The Global Head of Privacy and Data Protection
Dravnox Capital

Email: support@dravnox.com

Or submitting a request through our Contact Us page.

Complaints

If you have any concerns or complaints about the way your PI is processed, please contact the Global Head of Privacy and Data Protection at support@dravnox.com. 

You may also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen.

Depending on the laws of your jurisdiction, you may also appeal our decision related to your rights request where you believe we have not reasonably fulfilled your request. To submit an appeal, please email support@dravnox.com with the subject “Appeal.”

Cookie Notice

Please see our separate Cookie Notice.

Linked websites

This Privacy Notice is not applicable to third party websites that we do not own or control, or to any third-party website where Dravnox Capital advertisements are displayed.

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

¹ Please note not all privacy laws define SPI, for example Hong Kong, Singapore and Canada.

Dravnox Capital Cookie Notice

Last revised: 10 April 2025

Introduction

 This Cookie Notice applies to the use by Dravnox Capital of cookies and similar technologies (collectively “cookies”) on the Dravnox Capital Websites (“our Websites”). The purpose of this Cookie Notice is to explain what cookies are, how they work, the cookies we use and how you can control which ones we use when you visit our Websites. It also describes the purposes for which we process Personal Information (“PI”) collected through our use of cookies and your rights. It also sets outs individuals’ rights in relation to the processing of their PI by cookies.

“Our Websites” mean any publicly available, Dravnox Capital-domain, operated by Dravnox Capital or by a third party on behalf of Dravnox Capital.

 “Dravnox Capital”, “we”, “us” or “our” means Dravnox Capital and each of the direct or indirect subsidiaries of Dravnox Capital, (the “Dravnox Capital Group”).

References to “you” or “your” relate to individuals who visit our Websites.

This Cookie Notice should be read in conjunction with Dravnox Capital’s Privacy Notice.

This Cookie Notice does not apply to any domains that we do not own or control, or to any third-party domains where Dravnox Capital advertisements are displayed.

What is a cookie?

A cookie is a small text file which is downloaded to your device or browser when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie, in order to develop a record of the user’s online activity. Cookies may be delivered by the website a user visits, or by third parties. First party Cookies are set by Dravnox Capital and belong to the website domain that appears in the browser address bar.

Types of cookies:

1. Necessary cookies

Necessary cookies help keep our websites secure while enabling network management, site functionality and accessibility. You may disable necessary cookies in your browser settings, but that may affect how the website functions for you.

2. Preference cookies

Preference cookies enable us to store certain user selections or preferences and allows for a more tailored website experience.

3. Statistical Analytics

Measure the performance of our website and collect aggregate level information on how you use our site, for us to provide you with the best possible digital experience. No user level based behavioural data will be collected as part of this method. If you are visiting a European site, these are only active if you click “Accept all”. On Non-European sites, you may opt out of these separately under “Manage cookies”.

4. Marketing/Tracking/Profiling cookies

Marketing/Tracking/Profiling cookies are usually placed by advertising networks and are used to deliver relevant content or measure campaign performance. Information about website usage and visits may be shared with other organizations such as advertisers.

5. Conversational cookies

Conversational cookies help tie conversations and interactions to a specific visitor on our site, when you are interacting with our chatbot. These cookies must be accepted in order to interact with the chatbot on our websites.

Consent and updating your cookie preferences

On our European Websites, we will not set any cookies other than those that are Strictly Necessary without your consent.

On our Websites outside Europe, by clicking “Required only”, Statistical Analytics and Strictly Necessary cookies will be set as they do not collect any Personal Information. You may opt out of Statistical Analytics separately under “Manage cookies”.

If you are navigating between our European Websites and our Websites outside Europe, your first choice will determine the setting of Statistical Analytics; you can always change your preference under “Manage cookies”.

When you first visit our Website and on subsequent visits you will have the option to choose and then amend your other cookie preferences by clicking the Manage Cookies button which will appear on each page.

Across all sites, you will only be prompted again if we update the list of cookies we utilize or if this affects your browsing.

Cookies used on our Websites

If you’d like more information on the specific cookies currently used, their purpose and how long they last, please use Contact Us form.

“Session” Cookies are temporary and will expire at the end of a browser session; that is, when you leave a website. These allow our website to recognize you and carry information as you navigate between pages during a single browser session and allow you to use the website efficiently.

Other cookies have a defined expiry period as set out in the link above. Cookies will not be listed if they have expired, however some expired cookies may still be listed in your browser cookies settings even though they are not current on our website.

Non-cookie tracking technologies

We may also use web beacons including conversion pixels, which are small codes located on a particular web page which are triggered when someone visits a page resulting in an increase in the conversion count, or other technologies for similar purposes. We may include these on our sites, in our marketing e-mail messages or newsletters, or on affiliated websites, including client platforms and products, to determine whether messages have been opened and links clicked on.

How to block all cookies and what this will mean

If you want to block all cookies, you may be able to do this through the settings in your browser for each browser you use and each device you use. If you block all cookies, you may find certain features on our website will not function properly and we may not be able to respond to your request or provide you with the best service.

Please remember, if you turn off cookies using the settings in your browser, this will apply to all websites, not just Dravnox Capital.

Further information

You can find more information about cookies on the following websites:
www.allaboutcookies.org
www.youronlinechoices.eu

Contacting us

The Global Head of Privacy and Data Protection oversees compliance with privacy and data protection law and regulation at Dravnox Capital. If you wish to exercise any of your rights, or have questions concerning this Cookie Notice, please contact:

The Global Head of Privacy and Data Protection
Dravnox Capital

Email: support@dravnox.com

Complaints

If you have any concerns or complaints about the way your PI is processed, please contact the Global Head of Privacy and Data Protection at support@dravnox.com. You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your Personal Information has arisen. Please contact support@dravnox.com for further details.

Dravnox Capital Privacy Notice

Please see our separate Dravnox Capital Privacy Notice.

Recruitment Privacy Notice

Please see our separate Recruitment Privacy Notice.

Changes to this Cookie Notice

We may modify or amend this Cookie Notice from time to time. You are advised to visit our website regularly to check for any amendments.

Dravnox Capital Alumni Privacy Notice

Last revised: 1 June 2024

Welcome to the Dravnox Capital Alumni Website (“Alumni Website”). Dravnox Capital is committed to processing personal information (“PI”) in line with all applicable privacy and data protection laws. “Dravnox Capital”, “we”, “us” or “our” means Dravnox Capital, and each of the direct or indirect subsidiaries of Dravnox Capital.

PI we collect about you

PI is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual has been removed and is therefore non-attributable.

To join Dravnox Capital’s alumni network, you will be asked to submit an application on our Alumni Website. Your participation in our network is entirely your choice. As part of your application, we may collect the following PI that can be categorized as follows (the PI listed for each category are non-exhaustive examples):

• Identification data
  Full name, gender, photograph.

• Personal Contact data
  Email address, current residential location.

• Professional Information data
  Current employment status, management title, line of business, employment experience, education, board memberships, Dravnox Capital email address, information relating to your time at Dravnox Capital, including management level, city last worked, line of business, title, and time of joining and leaving Dravnox Capital.

Unless we otherwise indicate that the provision of specific PI is optional, any PI we request from you is necessary to progress your application to become a member of the Dravnox Capital alumni network.

The purposes and legal basis for processing your PI

The below table sets out the purposes and bases for which we process PI.

To whom we may disclose your PI

In connection with one or more of the purposes outlined in the section ‘Purpose and Legal basis for processing your PI’ above, we may disclose PI in any jurisdiction to:

• Other members of Dravnox Capital;
• Any service providers who provide services to us in relation to the alumni network;
• Any person in connection with litigation or other legal proceedings, to obtain legal advice or for establishing, exercising or defending legal rights;
• Any person to whom disclosure is allowed or required by law and/or regulation;
• Any court, tribunal, regulatory authority or Government entity, and;
• Third parties to whom Dravnox Capital may transfer its rights and/or obligations under any agreement, including but not limited to a potential merger or acquisition of all or part of Dravnox Capital’s business or assets.

Your rights

In some countries, subject to certain exemptions, you may have the following rights:

• Access
  The PI processed in relation to you is accessible to you in your profile on the Alumni Website.

• Correction
  You may amend your PI directly in your profile on the Alumni Website.

• Erasure
  If you wish to delete your Dravnox Capital Alumni Website account, you may email us at support@dravnox.com to request deletion.

Additionally, in some countries, subject to certain exemptions, you have rights including, but not limited to the right to object to processing, restriction, and portability. If you wish to exercise any of these rights, please contact support@dravnox.com.

You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.

How long your PI is retained for

We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defence of legal claims.

How your PI is protected

Dravnox Capital implements technical and organizational measures to appropriately protect PI against unauthorized, accidental, or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to PI transmitted, stored, or otherwise processed.

Transfers of PI

We are a global organization and in the course of running our business, we may transfer PI to a location outside of the country where you reside, including Dravnox Capital processing centers in the USA, Hungary, India and Singapore. Although the country to which PI may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of PI wherever it is processed. We require by contract that our service providers processing PI on our behalf comply with Dravnox Capital’s criteria for PI processing.

If we transfer PI out of the EEA, we ensure a similar level of protection for your PI by ensuring the country is considered by the EU Commission to provide an adequate level of protection or by putting in place contractual clauses the EU Commission considers to provide the same level of protection.

Alumni communications and exercising your right to opt-out

We will not send you communications about Dravnox Capital news, thought leadership, career opportunities, alumni stories, and invitations to alumni events if you have informed us that you do not wish to receive communications. All electronic communications we send to you will have an unsubscribe option.

Third-party marketing/sale of PI

We do not share or sell your PI to third parties for the third party to use for their own marketing or other purposes.

Cookies

Please see our separate Cookie Notice.

Contacting us

The Global Head of Privacy and Data Protection oversees compliance with privacy and data protection at Dravnox Capital. If you wish to exercise any of your rights, or have questions concerning this notice, please contact: The Global Head of Privacy and Data Protection Dravnox Capital Email: support@dravnox.com .

Complaints

If you have any concerns or complaints about the way your PI is processed, please contact the Global Head of Privacy and Data Protection at support@dravnox.com . You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen. Please contact support@dravnox.com for further details.

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time and you are advised to visit our Alumni Website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.