Privacy Notice

Introduction

Your privacy is very important to us. This notice (“Privacy Notice”) is provided by Caius Capital LLP, Caius Capital US LP, Caius Capital Services Limited, and Caius Capital Limited (the “Management Group”), Caius Capital International Fund (the “Offshore Fund”), Caius Capital Domestic Fund LP (the “Onshore Fund”), and Caius Capital Master Fund (the “Master Fund”, and together with the Offshore Fund and the Onshore Fund, the “Funds” and each a “Fund”, and together with the Management Group, “we” or “us”), and sets out our policies with respect to the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former investors in the Funds, other clients of the Management Group, our business partners and service providers, and other relevant third parties.

References to “you” or an “investor” in this Privacy Notice mean any investor who is an individual, or any individual connected with an investor who is a legal person, as applicable.

Use of Cookies

We may send text files (e.g., “cookies” or other cached files) or images to your web browser to store information on your computer. Such text files and images are used for technical convenience to store information on your computer. For instance, we may use a session cookie to store form information that you have entered so that you do not have to enter such information again. We may use information stored in such text files and images to customise your experience on this website and to monitor use of this website. You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of this website. You can disable cookies from your computer system by following the instructions on your browser or at www.allaboutcookies.org.

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). The Funds and Management Group are considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that each would determine the purposes and the means of the processing of your personal information.

Please contact our Compliance Officer on +44 2071907940 and by email on william.douglas@caiuscapital.com or by writing to the following address 2 Park Street, London, W1K 2XA, United Kingdom with any questions or complaints about this Privacy Notice or requests with regards to the personal data we hold.

The Types of Personal Data We May Hold

The categories of personal data we may collect depends on the product or service you have with us. This information can include social security number, names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, income, assets, risk tolerance, wire transfer instructions, transaction history, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.

How We Protect Personal Data

To protect your personal information from unauthorised access and use, we apply organisational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings. Given the nature of information security, there is no guarantee that such safeguards will always be successful.

How We Collect Personal Data

We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) recording and monitoring of telephone conversations with you.

We also may receive your personal information from third parties or other sources, such as our affiliates, Fund Administrator, Fund Sub-Administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, third party service providers (including in relation to background searches) or other publicly accessible sources, such as the Internet.

How We May Use Personal Information

We may process your personal data for the purposes of administering the relationship between you and us (including subscription acceptance, communications and reporting), marketing of our products and services, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements (including anti-money laundering, fraud prevention, tax reporting, sanctions compliance, or responding to requests for information from supervisory authorities, or law enforcement agencies).

We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:

(i) processing is necessary to perform our obligations under the relevant Fund Documents;

(ii) we are required to comply with a legal or regulatory obligation applicable to us; or

(iii) we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose (including for example for internal operations such as detecting security incidents, troubleshooting, data analysis, testing, research, statistical and survey purposes, and administering and improving our website).

What Are The Consequences Of Failing To Provide Personal Information

Where personal data is required to satisfy a statutory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in us being unable to provide a service to you.

Where there is suspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

How We May Share Personal Data

We may disclose information about you to our affiliates, service providers or other third parties to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations. We may also need to share your personal information with regulatory, tax or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.

It may also be necessary, depending on the service you receive from us, under anti-money laundering and similar laws, to disclose information about you to facilitate the establishment of trading relationships with trading counterparties.

We may also disclose information about you, or your transactions and experiences with us, to our affiliates or service providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.

Retention Periods

We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of your investment in the applicable Fund and for a minimum of five years after a redemption or withdrawal, as applicable, of your investment, or liquidation of the applicable Fund. We may retain personal data for a longer period for the purpose of marketing our products and services or compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.

We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

Monitoring of Communications

We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

For purposes of U.S. federal law, this Privacy Notice applies to current and former investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.

We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about the Fund’s investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so.

We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at +44 2071907940. If you are a new investor, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date you receive our Privacy Notice. When you are no longer our investor, we may continue to share your information with our affiliates for such purposes.

You may contact us at any time to limit our sharing of your personal information. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by the Funds.

Additional Information under the Cayman Islands Data Protection Law 2017 (“DPL”)

If you are an investor in a Fund that we manage, the applicable Fund may share your personal information with its services providers, including the Investment Manager, the Administrator, the Sub-Administrator, the Prime Brokers, or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPL.

You have certain rights under the DPL, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. A complaint in respect of the Offshore Fund or the Master Fund may be lodged with the Office of the Ombudsman in the Cayman Islands. Please use the contact details under Who to Contact About This Privacy Notice if you wish to exercise these rights.

Additional Information under the UK General Data Protection Regulation

You may have certain rights in relation to our processing of your personal data and any processing carried out on your behalf under the EU General Data Protection Regulation (Regulation (EU) 2016/679, “EU GDPR”) and/or under the EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR”, and together with the EU GDPR, “GDPR”), each as amended and supplemented from time to time. These rights include: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint, including with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under the GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above.

If you have any questions or complaints in relation to how we handle your personal data under the GDPR or otherwise, please use the contact details under Who to Contact About This Privacy Notice to raise such questions or complaints.

In addition, a complaint in respect of the Investment Manager may be made to the Information Commissioner’s Office in the United Kingdom.

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection to personal data as under the UK GDPR (“Third Countries”). In such cases, we will transfer personal data (or procure that it be transferred) to the Third Countries in accordance with the requirements of the GDPR, which may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf in such Third Countries, including in the form of the standard contractual clauses for the transfer of personal data to third countries from time to time approved by the European Commission (“EU SCCs”), or in the form of the international data transfer agreement adopted by the Information Commissioner’s Office and the UK Parliament (“IDTA”) or the EU SCCs as amended by the International Data Transfer Addendum to the EU SCCs issued by the Information Commissioner’s Office under S119A(1) Data Protection Act 2018, in force 21 March 2022 (“UK Addendum”), or an equivalent or replacement agreement, as applicable. We may also be required to transfer your personal information to our regulators or government agencies or to other relevant parties in Third Countries in cases where such transfers are permitted under the GDPR, for example where necessary for the purposes of establishing, bringing, or defending legal claims, including in the context of administrative proceedings, such as requests for information, examinations or investigations.