Mensch Investment Management Privacy Policy and Data Protection Notice

Mensch Investment Management Limited., its affiliates and the funds that they manage (collectively, “Mensch”)  are required by various laws to make individuals aware of our  established practices concerning the protection of their privacy and  non-public personal information. Mensch collects non-public personal  information about investors and employees in the regular course of doing  business. The information includes but is not limited to information  provided to use by investors in conjunction with their investments as  well as information about their investments. Mensch discloses such  information as permitted or required by law. Mensch does not sell  personal data.

Access to personal information concerning our investors and employees is  restricted to our employees, affiliates and required service providers  (as described in more detail below). Mensch maintains and routinely  reviews physical, electronic and procedural safeguards to protect the  privacy of its investors and individual data. 

Where your details are provided to any fund managed by Mensch (each, a  “Fund”) as a consequence of your investment in the Fund, then Mensch,  acting as a data controller may itself (or through a third party acting  in its capacity as the applicable Fund’s administrator or its  affiliates (collectively, the “Administrator”) process  your personal data or that of your directors, officers, employees  and/or beneficial owners. The Administrator may also act as a data  controller of your personal data in connection with the performance of  its legal and contractual obligations as Administrator of the Fund. 

Please ensure that you provide a copy of this Privacy Policy and Data  Protection Notice to any third parties, including individuals, whose  personal data you provide to the Fund, Mensch or the Administrator.  Should this Privacy Policy and Data Protection Notice be materially  updated at any time, you will specifically be notified of such changes.

1. Personal Data Collected

Mensch, as a “data controller”, and the Administrator, as a data  processor, processes and discloses your personal data. The types of  personal data collected, processed and disclosed varies. This  information can include:

• Name
• Address
• E-mail address
• Social Security number
• Tax identification number
• Account balance

2. Method of Collecting Personal Data

Mensch may obtain your data from multiple sources including but not limited to: 

• The Administrator;
• Applications for employment;
• Through transactions with any Fund;
• Third parties conducting background checks to satisfy anti-money laundering and sanctions compliance obligations; or
• Publicly available sources such as social media.

Cookies and Tracking Technologies

This website may use “cookies,” which from time to time automatically  collect certain information and data. “Cookies” are small pieces of  data sent to your computer browser from our web server and stored on  your computer’s hard drive. The data identifies you as a unique user and  facilitates your ongoing access to and use of this website. Cookies  also help us diagnose problems with our server.

3. Purposes of Processing and Legal Basis for Processing

Your personal data may be processed by Mensch or the Administrator  (or any of their affiliates, agents, employees, delegates or  sub-contractors) for the following purposes:

• Managing and administering your holdings in a Fund, including  assessing and processing applications, communicating with you about your  holdings and account related activities on an on-going basis;
• To update and maintain records and provide NAV and other calculations;
• To manage and maintain Mensch’s relationships with you and for ongoing customer service;
• To enforce or defend a Fund’s rights, itself or through third parties to whom it delegates such responsibilities;
• To comply with any applicable legal, tax or regulatory obligations  on Mensch or the Administrator, which derive from anti-money  laundering and counter-terrorism legislatio;

This use of your personal data is necessary for performance of your contract with Maverick.

• In order to carry out anti-money laundering checks and related  actions including sharing data with police, law enforcement, tax  authorities or other government and fraud prevention agencies where  Mensch has a legal obligation, including screening transactions,  reporting suspicious activity and complying with production and court  orders;
• To report tax related information to tax authorities;
• To investigate and resolve complaints and manage contentious regulatory matters, investigations and litigation;
• To monitor electronic communications for investigation and fraud  prevention purposes, crime detection, prevention and investigation;

This use of your personal data is necessary in order to comply with any legal or regulatory obligations.

The day to day running and management of a Fund including to:

• monitor, maintain and improve the processes, information and data,  technology and communications solutions and services used by the Fund;
• perform general, financial and regulatory accounting and reporting;
• monitor and record calls for quality, business analysis, training  and related purposes in order to pursue the legitimate interests of the  Fund to improve its service delivery; and
• protect Mensch’s legal rights and interests including screening  transactions for fraud prevention and anti-money laundering purposes.

 This use of your personal data is necessary for Mensch’s  legitimate business interest in managing our business including legal,  personnel, administrative and management purposes and for the prevention  and detection of crime provided Mensch’s interests are not overridden  by your interests.

4. Recipients of Data and International Transfer of Data

Maverick and the Administrator may disclose your personal data as follows:

• to their affiliates and third-party service providers engaged in  connection with the oversight, safekeeping, administration, distribution  or operation of a Fund, in order to process the data for the  above-mentioned purposes (including Mensch and non-Mensch entities);
• to competent authorities (including tax authorities), courts and  bodies as required by applicable law or requested by such entities or to  affiliates for internal investigations and reporting; or
• to third party service providers engaged in background checks

If you are located within the European Economic Area (“EEA”),  please be aware that the disclosure of personal data to the third  parties set out above likely involves the transfer of data to the BVI  and other jurisdictions outside the EEA. Such countries may not have the  same data protection laws as your jurisdiction and the Funds have,  inter alia, authorised the Administrator as its agent to ensure the  transfer of data by the Administrator outside the EEA is subject to a  contract incorporating standard contractual clauses in the form adopted  by the European Commission under Decision 2010/87/EU, Decision  2004/915/EC or an equivalent or replacement decision (the “Model Clauses”).

5. Retention period

Mensch and the Administrator will retain your personal data for a  minimum period of 5 years from the date on which you redeem all your  investment in the Funds or for as long as required for Mensch or the  Administrator to perform the services or comply with applicable  legal/regulatory obligations.

6. Consequences of not Providing Required Data

Where Mensch or the Administrator requires your personal data to  comply with anti-money laundering or other legal requirements, failure  to provide this information means a Fund may not be able to accept you  as an investor and/or may be unable to process or release your  investment. This may result in the Fund terminating its relationship  with you. When you are asked for your information you will be informed  whether it is a statutory or contractual requirement to provide the  information and the consequences of not providing the information.

7. Data Subject Rights

You have various rights in relation to your personal data, including  the right to request access to your personal data, correct any mistakes  on Mensch’s records, request the deletion of your personal data,  restrict the processing of personal data where you contest its accuracy  or the lawfulness of its processing, or where your personal data are no  longer required, object to use of personal data based on legitimate  business interests, and ask not to be subject to automated decision  making if the decision produces legal or other significant effects on  you.

In addition, you are entitled to the portability of the personal data  that you provided on the basis of consent or for the performance of the  contract of which you are party and only to the extent that the  processing is carried out by automated means.  Mensch will acknowledge  receipt of your request within 10 days and respond to your request in  writing, or orally if requested, as soon as practicable and in any event  not more than within one month after receipt of your request. In  exceptional cases, Mensch may extend this period by two months and  will tell you why. Mensch may request proof of identification to  verify your request. 

You have the right to lodge a complaint to Mensch’s Chief Compliance  Officer or with a supervisory authority if you consider that the  processing of your personal data infringes applicable data protection  laws. 

 If you have any questions about Mensch’s use or the Administrator’s  use of your personal data, please contact Mensch at  compliance@menschinvtmgmt.com. To  make a request under  the Virgin Islands Consumer Protection Act, in addition to the contact  information previously provided, Consumer Affairs Unit in the British Virgin Islands  phone number is (284) 468-3701. You can also contact them by WhatsApp at (284) 468-9760 or email at customerservice@gov.vg. The Consumer Affairs Unit is located at 33 Admin Drive, Wickhams Cay 1, Road Town, Tortola, Virgin Islands (British).