Our Commitment to Your Privacy

Coller Capital Limited, Coller Capital Inc., Coller Capital Limited, Korea Branch and Coller Capital (Hong Kong) Limited (collectively “we”, the “firm” or “Coller Capital”) are committed to protecting the privacy of current and prospective counterparties, investors, suppliers and other business contacts as they interact with the firm in person, through the internet, or by other means. Coller Capital is sensitive to the privacy concerns of individuals with whom the firm interacts and has a long-standing practice with the goal of protecting the confidentiality and security of personal information.

This Privacy Notice and Cookies Policy (this “Privacy Policy”) is designed to tell you about Coller Capital’s practices regarding collection, use, storage, and disclosure of personal data (as defined below). Examples of personal data include your full name, email address, postal address, telephone number, job title or the company you work for. We may collect your personal data via, as relevant, the firm’s websites, mobile applications, products, software or services that display a link to this Privacy Policy (collectively, the “Data Sources”). Please be sure to carefully read this Privacy Policy in its entirety before using or submitting personal data to a Data Source.

Additional supplementary information regarding privacy issues may be provided to you in connection with a particular product or service provided or contracted by us or any of our affiliates, whether provided through a website, by telephone, in writing, or other medium. Such additional supplementary information may be required by applicable law or as a result of the type or nature of the product or service in question. You are encouraged to read all information provided to you in connection with the use of your personal data.

If you are based in the United States (in particular, in California or Nevada), please refer to the region-specific sections at the end of this Privacy Policy which set out additional information relevant to the processing of your personal data.

Your Use of this Site

Use of this website (or other Data Source) constitutes your agreement to the terms of this Privacy Policy and applicable laws and regulations. Whenever you submit personal data and any other information via this website (or other Data Source), you acknowledge that such personal data will be collected, used and disclosed in accordance with this Privacy Policy.

Applicable Data Protection Legislation

For the purposes of this Privacy Policy, “Applicable Data Protection Legislation” means all applicable legislation relating to privacy or data protection in force from time to time, including any statute or statutory provision which amends, extends, implements, consolidates or replaces the same, and in particular to the extent applicable and without limitation the Hong Kong Personal Data (Privacy) Ordinance (“PDPO”), the Republic of Korea’s Personal Information Protection Act (“PIPA”), the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), the EU General Data Protection Regulation 2016/679 (“GDPR”), the GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 (“UK GDPR”), and the Data Protection Act 2018. The terms “personal data”, “controller”, and “process” (and its derivatives) shall have the meanings given to them in the Applicable Data Protection Legislation. Where this Privacy Policy uses terms which are defined in the Applicable Data Protection Legislation, the definitions set out in the Applicable Data Protection Legislation will apply.

We recognise that your personal data is valuable, and we process it in accordance applicable law and, to the extent that it applies to your personal data, Applicable Data Protection Legislation.

Data Controller

Coller Capital is the data controller responsible for the processing of your personal data collected from Data Sources under the Applicable Data Protection Legislation (to the extent that it applies to personal data collected about you) and other applicable law.

What Information we Collect, how we use that Information, and Lawful Basis

We collect personal data about you to provide you with products and services and information about those products and services offered by us to you. We make sure that the personal data we collect from you is necessary for and directly related to this purpose. We will use and process your personal data lawfully, fairly and in a transparent manner.

To the extent this information constitutes personal data, we use it to ensure that content from the Data Sources is presented in the most effective manner for you and your device because it is in our legitimate interest to improve our customers’ online experience in relation to the Data Sources.

Data Subjects	Personal data	Purpose	Lawful basis
Website users	Usage information including device and browser data (Including IP address, traffic data, clickstream information, time stamp, location data, web logs, other communication data such as your browser type and version, time zone setting and location, plug-in types and versions, operating system and platform; and the resources that you access).	Monitor use of the website to ensure content is presented in the most effective manner for your device and to help develop the website by compiling aggregate statistics about users to analyse usage	Legitimate interests: Understanding user behaviour to present information on the website (of most interest to users) and ensure it is displayed correctly and in a user friendly way;To improve customer online experience.
			Consent (Where applicable, where we have obtained consent from you to use your personal data for these purposes)
		To identify and verify your identity and/or eligibility for our services	Legitimate interests (To make sure enquiry is genuine and not being made for fraudulent reasons or is spam)
			Compliance with legal obligations (To confirm the details you provide to us before entering into a relationship with you)
Customers (Including prospective customers)	Personal contact details (Such as name, title, addresses, telephone numbers, and email addresses)	To identify and verify your identity and/or eligibility for our services	Legitimate interests (To make sure enquiry is genuine and not being made for fraudulent reasons or is spam)
			Compliance with legal obligations (To confirm the details you provide to us before entering into a relationship with you)
		To communicate with you and respond to feedback about your needs and expectations of our offered services and/or products	Legitimate interests (To use your personal data to communicate with you, respond to your requests about the services and facilities you require and develop the relationship between us in the context of your use of our services and facilities)
		Account creation when you register for our services and account maintenance	Legitimate interests: Using your personal data to communicate with you, to respond to your requests and to develop the relationship between us in the context of establishing and operating your account; Keeping you informed of your account activities or service changes.
			Performance of a contract with you (Where we are unable to provide our services without this information)
			Compliance with legal obligations (Relating to how we manage our relationship with you)
		Conducting research and/or analysis on the use of our services and to evaluate and improve our services	Legitimate interests (To understand the trends in the use and popularity of our services to adapt existing and offer new services based on this research and analysis)
		To provide information related to Coller Capital and its affiliates, including offered products, services and other privileges, benefits and advantages from time to time, and share information about our relevant services, news and events	Legitimate interests (To develop our relationship regarding our services, facilities and other privileges, benefits and other advantages)
			Consent (To sending you marketing communications)
		Providing, administering and managing services performing our contractual obligations to you	Performance of a contract with you (Where we are unable to provide our services without this information)
	Your business affiliation	Conducting research and/or analysis on the use of our services and to evaluate and improve our services	Legitimate interests (To understand the trends in the use and popularity of our services to adapt existing and offer new services based on this research and analysis)
		Determining eligibility and suitability for services and other privileges, benefits and other advantages offered	Legitimate interests (To develop our relationship regarding our services, facilities and other privileges, benefits and other advantages)
		To provide information related to Coller Capital and its affiliates, including offered products, services and other privileges, benefits and advantages from time to time, and share information about our relevant services, news and events	Legitimate interests (To develop our relationship regarding our services, facilities and other privileges, benefits and other advantages)
			Consent (To sending you marketing communications)
	Information gathered from other sources	To identify and verify your identity and/or eligibility for our services	Legitimate interests (To make sure enquiry is genuine and not being made for fraudulent reasons or is spam)
			Compliance with legal obligations (To confirm the details you provide to us before entering into a relationship with you)

We may combine information, such as the above personal data, we obtain from other sources with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We will let you know, if it is not identified above, where you must provide us with personal data in order for us to be able to enter into or perform an agreement with you or to comply with a legal obligation. You do not have to provide your personal data to us, but, if you do not provide us with the personal data in these circumstances, we may be unable to respond to your enquiry and/or engage in further communications with you and/or enter into or perform the contract we have entered or propose to enter into with you.

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 purpose. In the circumstance that we use your personal data for a different purpose than the purpose for which we collected it, we will notify you, explain the legal basis which allows us to do and ask for your consent for the additional purpose(s) (such consent only to be requested if required by law).

We do not carry out automated decision-making or profiling in relation to your personal data.

Disclosure of your Personal Data

We may disclose any of your personal data to our affiliated companies, where required by law or as set out in this Privacy Policy. We will not sell, trade or rent your personal data to others.

However, we may make certain disclosures in answering any query from you or providing you with services. We may disclose such disclosures:

Type of Personal Data	Recipient of Personal Data	Purpose of Transfer	Lawful Basis for Transfer
Financial Information	Service providers which may include the general partners’ investment manager, investment adviser, administrator, custodian and registrar, as well as the Coller website’s host and IT and technical providers	To ensure any enquiries or applications are processed by the appropriate party in accordance with your reasonable expectations	Legitimate interest (For our legitimate business interests, being the opening of investor accounts and administering and managing your investments and interests in our investment funds)
			Performance of a contract with you (To fulfil our obligations under our subscription or other supplemental agreement with you)
	Lawyers and accountants and other similar external advisors	Where we need to take steps to defend ourselves in respect of a legal claim or to comply with our legal obligations	Compliance with legal obligations (To comply with applicable laws, regulations, legal processes or governmental requests – these may include anti-money laundering and other financial crimes laws)
	Regulators, authorities and governmental bodies
Personal Contact Details	Regulators, authorities and governmental bodies	Where we are required to do so to comply with our legal obligations	Compliance with legal obligations (To comply with applicable laws, regulations, legal processes or governmental requests – these may include anti-money laundering and other financial crimes laws)
	Service providers which may include the general partners’ investment manager, investment adviser, administrator, custodian and registrar, as well as the Coller Capital website’s host, IT and technical providers.	To ensure your request is processed by the appropriate party in accordance with your reasonable expectations.	Legitimate interest (For our legitimate business interests, being the improvement of our service delivery)
Additional Data (including Details of outside directorships and other outside interests and Information about criminal convictions and offences)	Service providers which may include the General Partner’s investment manager, investment adviser, administrator, custodian and registrar, as well as the Coller Capital website’s host, IT and technical providers	To ensure any enquiries or applications are processed by the appropriate party in accordance with your reasonable expectations	Legitimate interest (For our legitimate business interests, being the opening of investor accounts and administering and managing your investments and interests in our investment funds)
			Performance of a contract with you (To fulfil our obligations under our subscription or other supplemental agreement with you)
	Regulators, authorities and governmental bodies	Where we are required to do so to comply with our legal obligations	Compliance with legal obligations (To comply with applicable laws, regulations, legal processes or governmental requests – these may include anti-money laundering and other financial crimes laws)
Device and Web Data	Third party analytics providers	To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.	Consent (Where applicable, where we have obtained consent from you to use your personal data for these purposes)
			Legitimate interest (For our legitimate business interests, being the improvement of our service delivery)
	Law enforcement agencies or other governmental bodies or authorities involved in the prevention of crime	To protect your Personal Data stored on, or accessible through, our website from unauthorised access or theft	Public interest (To monitor and prevent unauthorised attempts to access to your account data or other personal data stored on, or accessible through, our website, including your financial data)
Information about your use of our information and communications systems, including internet or other electronic network activity information	Service providers which may include the general partners’ investment manager, investment adviser, administrator, custodian and registrar, as well as the Coller Capital website’s host, IT and technical providers.	To ensure your request is processed by the appropriate party in accordance with your reasonable expectations and to analyse customer deliverability statistics, opens and clicks.	Legitimate interest (For our legitimate business interests, being the improvement of our service delivery)
Website Marketing Data	Third party service providers.	Where you have indicated that you wish for us to receive communications from third party service providers.	Consent (Where applicable, where we have obtained consent from you to use your personal data for these purposes)

We do not share your personal data with third parties for those third parties’ direct marketing purposes.

Retention and Data Integrity

We will keep a record of the personal data that we receive from you in order to answer any queries from you, respond to any requests for more information about the services and facilities we provide, and/or in order to provide those services and facilities.

We will only retain the personal data collected from you for as long as is necessary, including your account remaining active and not having been cancelled, and reasonable to fulfil the purposes for which we have initially collected such personal data (and any other purpose as described above) and/or to comply with our legal or regulatory obligations.

We will make reasonable efforts to keep your personal data accurate, complete and current.

We will delete our copy of your personal data within an appropriate time period after our last contact with you although we may retain a record of the existence of the relationship, to the extent and for so long as we are required to do so by law or regulation. For example, if you have contacted us to ask us for the processing of your personal data to be erased, we will retain a record of your request in order to ensure we comply with your wishes.

Where we provide personal data to third parties who provide services on our behalf, as detailed in the “Disclosure of your personal data” section above, we do so subject to strict contractual terms that protect the personal data in accordance with Applicable Data Protection Legislation.

Information Security

We use appropriate technical, organisational, administrative and physical security measures to reduce the risks of loss of, unauthorised access to, or inadvertent destruction of, your personal data. We train our employees to handle personal and business information in accordance with approved policies and procedures that we have established to ensure compliance with applicable laws, regulations and internal policies for protecting personal data, including Applicable Data Protection Legislation. Only those employees with proper authority and training are allowed access to your personal data.

You acknowledge that the transmission of information via the internet is not secure. We cannot guarantee the security of your data transmitted to our public website, any other site used by us and accessible by you or through electronic communications, and any transmission is at your own risk.

International Transfers of Personal Data

If you provide personal data to us, it may be transferred to, processed in, stored at or accessible from one or more destinations internationally to jurisdictions outside the jurisdiction of the Coller Capital entity to which you provided such data and outside the European Economic Area (“EEA”), and United Kingdom (“UK”) as relevant, including territories that have not been deemed to offer adequate protection to personal data by the European Commission or, as relevant, are not subject to an adequacy regulation enacted by the UK Government. It may also be processed by staff operating outside the EEA or, as relevant, UK who work for Coller Capital or are a third party service provider. Such staff may be engaged in, among other things, the provision of support services.

Where we make such a transfer of personal data outside the EEA, or UK as appropriate, we shall ensure appropriate safeguards are used and make such transfer on the condition that enforceable data subject rights and effective legal remedies are available. This may include an approved data protection framework, or standard data protection clauses within agreements that we will enter into which enable you to exercise your rights in accordance with the Applicable Data Protection Legislation.

Your Rights

With respect to the personal data that we collect about you as detailed in this Privacy Policy, and to which the GDPR, UK GDPR, PIPA or HK PDPO applies, you (and in some instances your legal representative(s)) may have the right (depending on the Applicable Data Protection Legislation) to:

• request access to that personal data;
• receive a copy of the personal data that you have provided in a structured, commonly used and machine readable format so that you can share it with others;
• request the transfer of your personal data to another party;
• not be subject to a decision based solely on automated processing, including profiling;
• withdraw your consent at any time (to the extent we are processing your personal data based on your consent);
• ask that personal data be erased (please note that we may be required to retain certain personal data, but we will not retain such information for longer than is necessary for the relevant purposes. We require certain key personal data from you in order to provide you with information or services and if you ask us to remove all or part of such information, you may no longer be able to use or access such information or services, including our public website or parts of it);
• request the rectification of your personal data, if you consider that it is inaccurate;
• object to us possessing your personal data by asking for the processing of that personal data to be restricted or stopped; and/or
• make a complaint to the appropriate data protection authority, which in the UK is the Information Commissioner’s Office, about the manner in which Coller Capital processes your personal data.

Please contact us using the details in the “Contact information” section below if you wish to exercise any of these rights.

If you wish to exercise your right to make a complaint to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK: they may be contacted at: Water Lane, Wycliffe House Wilmslow, Cheshire SK9 5AF, e-mail: casework@ico.org.uk, website: https://ico.org.uk, helpline 0303 123 1113;

You also have the right to lodge a complaint with the Guernsey Data Protection Authority, the Cayman Islands Data Protection Ombudsman, the Korean Personal Information Protection Commission, the Hong Kong Office of the Privacy Commissioner for Personal Data or another relevant authority or a supervisory authority (as applicable) in the jurisdiction of your usual residence or place of work or of the place of the alleged breach, if you consider that the processing of your personal data carried out by us or any of our affiliates or third-party service providers has breached data laws. You may also appeal to certain courts against (i) any failure of the Guernsey Data Protection Authority or another relevant authority (as applicable) to give written notice of whether the complaint is either being investigated or not being investigated and where applicable, the progress and the outcome of the investigation or (ii) a determination of the Guernsey Data Protection Authority or another relevant authority (as applicable) not to investigate the complaint or a determination that a controller or processor has not breached or is not likely to breach an operative provision in connection with the complaint.

In addition to the above, you can review, update, and correct your account information and preferences at any time.

You also have the right to opt out of marketing communications at any time. You may do so by clicking “unsubscribe” links provided in promotional email messages, by amending your communication preferences, or by contacting us using the details in the “Contact information” section below.

Changing your Cookie Preferences

If you would like to disable cookies, you can set your web browser to reject cookies. However, if you disable the cookie function, you may not be able to access or receive all the information contained on the website. How to alter your cookie setting will depend on the type of browser or device you use. The “Help” or “Internet Settings” functions within your browser should tell you how. For information on how to manage cookies on popular browsers please see the following links:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

To opt out of being tracked by Google Analytics across all websites, you may be able to use the tool provided by Google available at: http://tools.google.com/dlpage/gaoptout.

Please note that Google and other third parties (including, for example, advertising networks, social media platforms and providers of external services like web traffic analysis services) may also use cookies as a result of you visiting other websites, over which we have no control.

We have a presence on the following social media platforms:

LinkedIn – https://www.linkedin.com/company/coller-capital/

YouTube – https://www.youtube.com/channel/UCuxowG9Q9rOJdYBqxdwSKHA/featured

Twitter- https://twitter.com/Coller_Capital/

The website includes links to these social media platforms and social sharing icons. Whenever you leave our website following the above links, cookies might be set by these social media platforms. Cookies might also be set by these social media platforms if you are logged in to any of these social media platforms or if you decide to share.

The cookie policies for those social media platforms are available through the following links and contain information on how to control the setting of cookies:

LinkedIn – https://www.linkedin.com/legal/cookie-policy

YouTube – https://support.google.com/youtube/answer/32050?co=GENIE.Platform%3DDesktop&hl=en

Twitter – https://help.twitter.com/en/rules-and-policies/twitter-cookies

Children

We do not knowingly collect or maintain personal data from any person under the age of sixteen. No parts of our website (or other Data Source) are directed to or designed to attract anyone under the age of sixteen.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy and any other relevant policies or procedures at any time. Any changes we may make to this Privacy Policy will be posted on this page. You should regularly check and review this page to ensure you understand how we may be processing personal data. Any changes we may make to this Privacy Policy (which will, unless otherwise indicated, apply to personal data already obtained before the changes were made) will be effective from the date on which those changes have been posted on this page. Where we decide it is appropriate to do so, we may also notify you of any changes we have made by e-mail.

Contact Information

If you have any questions concerning this Privacy Policy or the policies or procedures referred to above, please contact us by emailing CCcompliance@collercapital.com and/or by post at Coller Capital Limited of Park House, 116 Park Street, London, W1K 6AF marked for the attention of:

• Legal & Compliance department; or
• only in relation to marketing communications, the Marketing department.

Note for Individuals Based in California

California Consumers have certain rights afforded them under the CPRA. For additional information on such rights and how to exercise such rights, please visit Addendum for California Residents.

Note for Individuals Based in Nevada

Under Nevada law, we do not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal data we have collected about you by contacting us as set forth in the “Contact Information” section.

Do Not Track

Our website (or other Data Source) does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.