Privacy Policy - Data Protection, and Privacy Policy

1.Introduction

(1.1.) Redwheel is a global asset manager which offers a range of products that enable our institutional clients to invest in a range of strategies to help them meet their long term financial needs.

(1.2.) Redwheel is committed to protecting the non-public personal information of its clients and has instituted a formal program that details how the firm will safeguard client non-public personal information, and comply with its regulatory obligations.

2. Application

(2.1.) This Redwheel Data Protection Policy (the “Policy”) aims to provide clients (referred to as ‘you’ or ‘your’) with information on how Redwheel collects and processes your personal data.

(2.2.) This Policy is issued on behalf of the following Redwheel group entities (collectively referred to as ‘us’, ‘we’, ‘the Firm’ or ‘Redwheel’):

(2.2.a.) RWC Partners Limited;

(2.2.b.) RWC Asset Management LLP;

(2.2.c.) Redwheel Australia Pty Ltd

(2.2.d.) RWC Asset Advisors (US) LLC; and

(2.2.e.) Redwheel Europe Fondsmæglerselskab A/S

(2.2.f.) RWC Singapore (PTE)

(2.3.) Redwheel is a controller of your personal data for the purposes of data protection laws, including, as appropriate, the European Union’s General Data Protection Regulation, the UK GDPR, the UK Data Protection Act 2018, the Australia Privacy Act 1988, the Personal Data Protection Act 2012 or, if applicable, relevant state and federal laws and regulations governing the protection of personal information and We will let you know which specific Redwheel group entity will be the controller for your data when you purchase a product or service with us.

3. Important Information

3.1. Relationship with other documents

It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

3.2. Nominated Representative

Redwheel has a nominated representative for data protection and privacy matters who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the nominated representative using the details set out below:

Huan Ke

Chief Compliance Officer

RWC Partners Limited

Verde 4^th Floor, 10 Bressenden Place London, SW1E 5DH

Email: [email protected] Telephone: +44 (0) 20 7227 6000

3.3. Complaints

You have the right to make a complaint at any time to the relevant supervisory authority for data protection listed

below. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so please contact us in the first instance using the details above.

3.4 Changes to the privacy notice and your duty to inform us of changes

This Policy was last updated in September 2024. Subsequent updates to the Policy will be made as and when required. The latest version of the Policy can be found on our website: www.redwheel.com or upon request from the nominated representative.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

3.5. Redwheel website

Redwheel’s website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

4. The data we collect about you

(4.1.) Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

(4.2.) Redwheel collects your personal information from the following sources, as applicable:

(4.2.a) For existing and/or former clients/investors, information provided directly by you via subscription and related documents, or through third party service providers, such as, appointed administrators or custodians, including (i) name, address, income, financial and investment qualifications, and tax- related information and (ii) in the case of individuals, birth date, nationality, passport or other identification number, and employment information, or in the case of entities, date and jurisdiction of formation, entity type, tax identification number, and business information);

(4.2.b) Information provided by you via interactions with our employees and This includes, for example, chat logs, or call recordings with members of our sales and investor support teams. Information may also be recorded in a number of databases;

(4.2.c.) Information we have collected from publicly available sources, such as Companies House, financial regulators, electoral registers, websites and social media, etc;

(4.2.d.) Information we receive from third party data aggregators such as Thomson Reuters WorldCheck. This information may include records of adverse media associations, criminal proceedings, aliases or other legal or financial information

(4.2.e.) Information provided by you where you act as a service provider to This information may include email address, entity types, tax identification number and business information;

(4.2.f.) Information we collect by conducting checks on actual or potential counterparties and service providers. This information is collected by a due diligence questionnaire and may include information on beneficial ownership, subcontracting, policies and procedure and IT security;

(4.2.g.) Information we collect by undertaking referencing checks. This information may include work references, education and qualifications, ID verification and criminal background checks; and

(4.2.h.) Information we collect by virtue of your use of our website, including but not limited to:

(4.2.h.1.) Identity Data such as first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;

(4.2.h.2.) Contact Data such as billing address, delivery address, email address and telephone numbers;

(4.2.h.3.) Transaction Data such as details of products and services you have purchased from us;

(4.2.h.4.) Usage Data such as information about how you use our website, products and services;

(4.2.h.5.) Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences; and

(4.2.h.6.) Technical Data such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

(4.3.) We may also collect, use and share Aggregated Data such as statistical or demographic data for any Aggregated Data may be derived from your personal data but is not considered personal data as a matter of law as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

(4.4.) Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

5. How we use your personal data

(5.1.) We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

(5.1.1.) Where we need to perform the contract we are about to enter into or have entered into with you;

(5.1.2.) Where we need to comply with a legal or regulatory obligation;

(5.1.3.) Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; or

(5.1.4.) Where we have undertaken a legitimate interest assessment and concluded that we need your consent. You have the right to withdraw consent to marketing at any time by contacting us

(5.2.) In the table below we have set out a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where

(5.3.) Marketing: we will provide you with marketing material in relation to Redwheel and the products/services we provide unless you have notified us of your instruction to opt-out of receiving such communications in the

(5.4.) Third party marketing: We do not share your personal information with any third-party company outside of the Redwheel group for marketing purposes.

(5.5.) Opting out: You can request that we stop sending you marketing communications at any time. To do so, please contact our nominated representative or by changing your marketing preferences in the unsubscribe link in our direct marketing communications. For the avoidance of doubt, where you have opted-out of receiving future marketing communications from us, this will not impact us communicating with you where we have a legal and/or contractual obligation to do so.

(5.6.) Change of purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for a purpose not described above, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

(5.7.) Automated Decision Making: automated decision making refers to decisions about you being made without involving human participation. We do not make automated decision about you nor profile you.

(5.8.) We may combine information that we receive about you from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

(5.9.) Please note that you must not supply to us, and we will not accept, any other person’s personal data other than your own person data.

6. Disclosures of personal data

(6.1.) We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above with:

(6.1.1.) Other legal entities within the Redwheel group who are based in the US, UK, Denmark, Australia and Singapore (together the “Relevant Regions”);

(6.1.2.) Service providers acting as data processors (or equivalent) based within or outside of the Relevant Regions;

(6.1.3.) Professional advisers, which may be acting as data controllers, including lawyers, bankers, auditors, based both inside and outside of the Relevant Regions, who provide us with their relevant services;

(6.1.4.) HM Revenue & Customs, regulators and other authorities acting as joint controllers based both inside and outside of the Relevant Regions; and

(6.1.5.) Technology service providers acting as data processors based both inside and outside of the Relevant Regions.

(6.2.) We require all third parties who act as data processors to respect the security of your personal data and to treat it in accordance with the We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

(7.1.) We share your personal data within the Redwheel group. This may involve transferring your data between the Relevant Regions.

(7.2.) We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

(7.3.) Many of our external third parties are based outside of the Relevant Regions, including the UK and the EEA, so their processing of your personal data will involve a transfer of data outside of the UK and EEA which may not same level of protection offered under the European Union’s General Data Protection Regulation, the UK GDPR and the UK Data Protection Act 2018.

(7.4.) Whenever we transfer your personal data out of the UK or EEA, we ensure a consistent level of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(7.4.1.) the country to which we send the data is not restricted by the UK Government or the European Commission, or other relevant authorities in the Relevant Regions;

(7.4.2.) the country to which we send the data is recognised by European Commission as “adequate” which means that the country has been assessed to offer adequate level of protection for personal data;

(7.4.3.) the recipient may have adhered to binding corporate rules (only for intragroup transfers); or

(7.4.4.) the recipient has signed a contract based on “model contractual clauses” approved by the UK Government or the European Commission (where relevant), obliging them to protect your personal data.

8. Data Security

(8.1) We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

(8.2.) We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

(9.1.) We will retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.

(9.2.) To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Your legal rights

(10.1.) Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

(10.1.1) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

(10.1.2) Request correction of the personal data that we hold about Please note that whilst we accept responsibility for maintaining the personal information entrusted to us, to the extent allowed by law, we are not responsible for its accuracy over time. If you identify any accuracy or incompleteness in your personal information, you can request correction of personal data we hold about you. We reserve the right to verify the accuracy of the new data you provide to us;

(10.1.3) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

(10.1.4) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights;

(10.1.5) Request restriction of processing of your personal This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

(10.1.6) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and

(10.1.7) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

(10.2.) If you wish to exercise any of the rights set out above, please contact our nominated representative (details provide in section 2).

(10.3.) You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

(10.4.) We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

(10.5.)We try to respond to all legitimate requests within one Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Special Categories of Personal Data

(11.1) Generally, we do not collect any Special Categories of Personal Data about you nor do we collect any information about criminal convictions and offences unless there is a legal and/or regulatory requirement to do so, for example, if you invest with us or to be employed by us, then we are required to undertake anti- money laundering checks and financial crime assessments which may disclose criminal convictions and

(11.2) To the extent applicable, we will collect, use and disclose special categories personal data only for primary purpose for which it was collected, or for directly related purposes which would reasonably be expected by you, or for purposes to which you have consented and in other circumstances required or authorized by Special categories personal data shall include the followings:

(11.2.a.) personal data revealing racial or ethnic origin;

(11.2.b.) personal data revealing political opinions;

(11.2.c.) personal data revealing religious, spiritual or philosophical beliefs;

(11.2.d.) personal data revealing trade union membership;

(11.2.e.) genetic data;

(11.2.f.) biometric data (where used for identification purposes);

(11.2.g.) data concerning health;

(11.2.h.) data concerning a person’s sex life;

(11.2.i.) data concerning a person’s sexual orientation;

(11.2.j.) criminal record (in the context of Australia);

(11.2.k.) membership of a professional or trade association, or trade union (in the context of Australia).

Disclaimer

Redwheel ® is a registered trademark of RWC Partners Limited (“RWC”). The term “Redwheel” may include any one or more Redwheel branded regulated entities including, RWC Asset Management LLP which is authorised and regulated by the UK Financial Conduct Authority and the US Securities and Exchange Commission (“SEC”); RWC Asset Advisors (US) LLC, which is registered with the SEC; RWC Singapore (Pte) Limited, which is licensed as a Licensed Fund Management Company by the Monetary Authority of Singapore; Redwheel Australia Pty Ltd is an Australian Financial Services Licensee with the Australian Securities and Investment Commission; and Redwheel Europe Fondsmæglerselskab A/S (“Redwheel Europe”) which is regulated by the Danish Financial Supervisory Authority.

Redwheel may act as investment manager or adviser, or otherwise provide services, to more than one product pursuing a similar investment strategy or focus to the product detailed in this document. Redwheel and RWC (together “Redwheel Group”) seeks to minimise any conflicts of interest, and endeavours to act at all times in accordance with its legal and regulatory obligations as well as its own policies and codes of conduct.

This document has been prepared for general information purposes only and has not been delivered for registration in any jurisdiction nor has its content been reviewed or approved by any regulatory authority in any jurisdiction.