Legal

Complaints Handling

United Kingdom

1. How to Complain

Azura takes any complaint received very seriously. If you do need to contact us to make a complaint, you can do so by writing to the following address: The Compliance Officer Azura Partners Ltd, 25-26 Albemarle Street, London, W1S 4HX or e-mail: compliance@azura.com. Alternatively, you can call us at +44 (0) 2072928170 (calls are recorded for regulatory purposes). We will be able to take your call from Monday to Friday 8.30am to 6.00pm.

2. How We Process Complaints

Within 5 business days of receiving your complaint, we will send you a letter or email of acknowledgement that will include a copy of this complaints procedure.

3. Who Will Deal with Your Complaint

Officers with an adequate level of seniority, knowledge and experience will deal with your complaint.

4. Follow Up

Our aim is to let you have a full response within 4 weeks of receiving your complaint. In this response, we will:

• Let you know the outcome of our investigation
• Advise you of what we intend to do to rectify the problem
• If we disagree with your complaint, clearly explain the reasons why
• Advise you of your right to refer the matter to the Financial Ombudsman Service

5. If Our Investigation Takes Longer Than 4 Weeks

Sometimes, an analysis into a complaint can take longer than 4 weeks. If this happens, we will:

• Write to you explaining the reason for the delay
• Try to resolve your complaint within a further 4 weeks

5.1 If it takes longer than 8 weeks

In exceptional circumstances, a complaint may take longer than 8 weeks to resolve. If this is the case, we will:

• Write to you again explaining the reason for the delay and giving a revised date for when you can expect a response
• If appropriate, inform you of your right to take your complaint to the Financial Ombudsman Service

6. If You Disagree with Our Decision

We may reconsider our decision if you have new evidence beyond what you told us in your original complaint. You have 6 months from the date of our final response in which to appeal against our decision. If we have not heard from you in that time, we will consider the complaint resolved.

If you are unhappy with the outcome of our enquiry, you may be eligible to refer your complaint to the Financial Ombudsman Service, free of charge but you must do so within six months of our final response. You can contact the Financial Ombudsman Service at 0300 123 9 123; 020 7964 1000 or via https://www.financial-ombudsman.org.uk.

UK Stewardship Code Disclosure Statement

United Kingdom

Rule 2.2.3 of the Conduct of Business Sourcebook of the Financial Conduct Authority (FCA) Handbook requires Azura Partners Limited to make a public disclosure in relation to the nature of our commitment to the UK Stewardship Code ("the Code") published by the Financial Reporting Council (FRC).

The Code aims to enhance the quality of engagement between institutional investors and UK companies to help improve long-term returns to shareholders and the efficient exercise of governance responsibilities. It sets out good practice on engagement with UK investee companies and is to be applied by firms on a "comply or explain" basis. The FRC recognises that not all parts of the Code will be relevant to all institutional investors and that smaller institutions may judge some of the principles and guidance to be disproportionate. It is of course legitimate for some asset managers not to engage with companies, depending on their investment strategy, and in such cases, firms are required to explain why it is not appropriate to comply with a particular principle.

The seven principles of the Code are that institutional investors should:

• Publicly disclose their policy on how they will discharge their stewardship responsibilities;
• Have and publicly disclose a robust policy on managing conflicts of interest in relation to stewardship;
• Monitor their investee companies;
• Establish clear guidelines on when and how they will escalate their activities as a method of protecting and enhancing shareholder value;
• Be willing to act collectively with other investors where appropriate;
• Have a clear policy on voting and disclosure of voting activity; and
• Report periodically on their stewardship and voting activities.

Azura Partners Limited does not comply with the Code as it does not currently invest in listed companies in the UK. Should this change, we will review our commitment to the Code at that time and make appropriate disclosure.

Privacy Policy

United Kingdom

1. Introduction

This Policy sets out the obligations of Azura Partners Ltd, a company registered in the U.K., regulated by the FCA (Financial Conduct Authority) with FRN 824031, whose registered offices are at 25-26 Albemarle Street, London, W1S 4HX ("the Company", "we", "us").

This Policy sets the Company's obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

2. Definitions

• "GDPR": EU Regulation 2016/679 (General Data Protection Regulation).
• "Personal data" is any information relating to an identified or identifiable natural person (a "data subject" as defined) such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• "Data subject" refers to clients, potential clients, suppliers, investors, employees and partners in respect of their personal data under GDPR.
• "Data controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• "Data processor" is a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.
• A "Related Person" means an individual or entity whose information you or a third party provide to us and/or which otherwise comes to our knowledge in connection with our business relationship. A Related Person may include, but is not limited to,
  • any director, officer, employee or authorized signatory of a company,
  • a trustee, settlor, beneficiary or protector of a trust,
  • any nominee or beneficial owner of an account,
  • a substantial interest owner in an account,
  • a controlling person,
  • a payee of a designated payment,
  • or any representative(s) or agent(s).

This Data Protection Notice explains how we process personal data. As a data controller, we are responsible for collecting and processing some of your personal data in relation to our activities. The purpose of this notice is to let you know which personal data we collect about you, the reasons why we use them and why we might share such personal data, how long we keep them, what are your rights and how you can exercise them. Please note that we may also process personal data in respect of an individual who is a Related Person to you.

3. Personal Data We Process About You

We collect and use your personal data in the context of our activities. We may collect various types of personal data about you depending on the nature of the particular service we provide, including:

• Identification information (e.g., full name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, fingerprint, IP address);
• Contact information (e.g., address and email address, phone number);
• Family situation (e.g., marital status, number of children);
• Tax status (e.g., tax ID, tax status);
• Education and employment information (e.g., level of education, remuneration);
• Banking, financial and transactional data (e.g., bank account details, transfer of assets, source of wealth);
• Data relating to your habits and preferences;
• Data which relates to your use of our services;
• Data from your interactions with us (e.g., our meetings, calls, chats, emails, phone conversations);
• Background checks;
• Cookie information (e.g., cookies and similar technologies on websites and in emails)

4. Personal Data Source

The data we use about you may be directly provided by you or obtained from other sources, such as:

• Publications/databases made available by official authorities;
• Databases made publicly available by third parties;
• Any other third parties.

5. Other Cases of Personal Data Collection

In certain circumstances we may collect and use personal data of individuals with whom we have or could have a direct relationship such as:

• Visitors to our websites, including subscribers to our newsletters, funds documentation and investment recommendations;
• Prospective or existing clients;
• Attendees of our events or recipients of our marketing materials; investor in collective investment schemes or designated SPVs for which Azura Partners Ltd acts as an investment manager or an investment advisor.

6. Why We Collect Your Personal Data

6.1 Compliance with Our Legal And Regulatory Obligations

We use your personal data to comply with legal and regulatory obligations (including any legal and regulatory guidance) and to comply with other legal process and law enforcement requirements (including any internal policy), which may include laws outside the country you are located in, including to:

• Comply with regulations dealing with prevention of money-laundering, financial crime, financing of terrorism and market abuse
• Comply with regulations relating to sanctions and embargos
• Comply with regulations relating to financial markets in particular with regard to investor protection
• Detect transactions which deviate from normal patterns
• Record, when necessary, our interactions (such as phone calls, chats, email)
• Define your credit risk score and your capacity to absorb any loss
• Reply to an official request from an administrative or judicial authority
• Prevent tax fraud and fulfil tax control and notification obligations
• Comply with any applicable transaction reporting obligations

6.2 Ability to Make Assessments On You Before Entering Any Contract

We use your personal data to enter into and perform our contracts, including to:

• Provide and perform our obligations with respect to the services we provide (e.g., ancillary and investment activities services, including management or advisory services) or in connection with fulfilling your instructions;
• Send administrative information, such as change of our terms, conditions and policies;
• Manage, administrate and distribute our services related to investment and advisory activities
• Maintain the ongoing relationship with respect to your holdings in specific Azura financial products;
• Provide you with information, including reports, regarding our services;
• Evaluate if we can offer you a service or a product and under which conditions.

6.3 Developing Our Business In Compliance With The Required Regulation

We use your personal data in order to develop our services and to improve our risk management, including:

• To prevent, detect, investigate about fraud;
• To manage our IT infrastructure;
• To personalize our offering of services to you;
• To provide customer management and administration;
• To analyse, evaluate and improve our business;
• To develop our business relationship with you and to improve the quality of our services.

7. We Request Your Consent for Specific Processing

If we need to carry out further processing for purposes other than those above, we will inform you and, where necessary, obtain your consent.

8. How We Share Your Data

Personal data may be disclosed to third parties in connection with the services we are providing to you. The recipients of any such information will depend on the services that are being provided. In order to fulfil the above purposes and subject to any confidentiality restriction we may have expressly agreed with you or any transaction parties, we may disclose your personal data to:

• Azura Partners Ltd Group entities
• Service providers which perform services on our behalf
• Financial, taxation, regulatory or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain professionals such as lawyers, notaries or auditors
• To any other persons as agreed with you. The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a business relationship with, and/or from rendering our services to you.

9. How and For How Long We Keep Your Data

We will retain your personal data within a protected and controlled environment to maintain integrity and confidentiality for the longer of:

• The period required by applicable law or contractual obligations; or
• Such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests. Most personal data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law.

10. Your Rights

You have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by law.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party. Even if you object to the processing of personal data, we are nevertheless allowed to continue the same if the processing is:
  • legally mandatory
  • necessary for the performance of a contract to which you are a party
  • necessary for the performance of a task carried out in the public interest
  • necessary for the purposes of the legitimate interests we follow, including the establishment, exercise or defence of legal claims. We will not, however, use your personal data for direct marketing purposes without your consent or if you ask us not to do so. You also have the right to complain to the Information Commissioner's Office. Find out how to report a concern on their website: https://ico.org.uk

11. Contact Us

If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact us at: Azura Partners Ltd, 25-26 Albemarle Street, London W1S 4HX, United Kingdom.

Complaints Handling

Monaco

Azura takes any complaint received with the most serious approach with a clear and transparent process for dealing on a timely manner.

1. How to Complain

If you do need to contact us to make a complaint, you can do so by writing to the following address: The Compliance Officer, Azura Monaco SAM, 1, Avenue Henry Dunant, 98000 Monaco. Alternatively, you can call us at +377 92000311 (calls are recorded for regulatory purposes). We will be able to take your call from Monday to Friday 8.30am to 6.00pm or send to us an email at compliance@azura.com.

2. How We Process Complaints

Within 5 business days of receiving your complaint, we will send you a letter or email of acknowledgement that will include a copy of this complaints procedure.

3. Who Will Deal with Your Complaint

Officers with an adequate level of seniority, knowledge and experience will deal with your complaint.

4. Follow Up

Our aim is to let you have a full response within 4 weeks of receiving your complaint. In this response, we will:

• Let you know the outcome of our investigation
• Advise you of what we intend to do to rectify the problem
• If we disagree with your complaint, clearly explain the reasons why

5. If Our Investigation Takes Longer Than 4 Weeks

Sometimes, an analysis into a complaint can take longer than 4 weeks. If this happens, we will:

• Write to you explaining the reason for the delay
• Try to resolve your complaint within a further 4 weeks

5.1 If it takes longer than 8 weeks

In exceptional circumstances, a complaint may take longer than 8 weeks to resolve. If this is the case, we will:

• Write to you again explaining the reason for the delay and giving a revised date for when you can expect a response
• If appropriate, inform you of any additional action you may be able to initiate

6. If You Disagree with Our Decision

We may reconsider our decision if you have new evidence beyond what you told us in your original complaint. You have 6 months from the date of our final response in which to appeal against our decision. If we have not heard from you in that time, we will consider the complaint resolved.

Privacy Policy

Monaco

1. Introduction

This Policy sets out the obligations of Azura Monaco SAM, a company registered in Monaco, regulated by CCAF with agreement 2019-03, whose registered offices are at 1 avenue Henry Dunant, 98000, Monaco ("the Company", "we", "us").

This Policy sets the Company's obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

2. Definitions

• "GDPR": EU Regulation 2016/679 (General Data Protection Regulation).
• "Personal data" is any information relating to an identified or identifiable natural person (a "data subject" as defined) such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• "Data subject" refers to clients, potential clients, suppliers, investors, employees and partners in respect of their personal data under GDPR.
• "Data controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• "Data processor" is a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.
• A "Related Person" means an individual or entity whose information you or a third party provide to us and/or which otherwise comes to our knowledge in connection with our business relationship. A Related Person may include, but is not limited to,
  • any director, officer, employee or authorized signatory of a company,
  • a trustee, settlor, beneficiary or protector of a trust,
  • any nominee or beneficial owner of an account,
  • a substantial interest owner in an account,
  • a controlling person,
  • a payee of a designated payment,
  • or any representative(s) or agent(s).

This Data Protection Notice explains how we process personal data. As a data controller, we are responsible for collecting and processing some of your personal data in relation to our activities. The purpose of this notice is to let you know which personal data we collect about you, the reasons why we use them and why we might share such personal data, how long we keep them, what are your rights and how you can exercise them. Please note that we may also process personal data in respect of an individual who is a Related Person to you.

3. Personal Data We Process About You

We collect and use your personal data in the context of our activities. We may collect various types of personal data about you depending on the nature of the particular service we provide, including:

• Identification information (e.g., full name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, fingerprint, IP address);
• Contact information (e.g., address and email address, phone number);
• Family situation (e.g., marital status, number of children);
• Tax status (e.g., tax ID, tax status);
• Education and employment information (e.g., level of education, remuneration);
• Banking, financial and transactional data (e.g., bank account details, transfer of assets, source of wealth);
• Data relating to your habits and preferences;
• Data which relates to your use of our services;
• Data from your interactions with us (e.g., our meetings, calls, chats, emails, phone conversations);
• Background checks;
• Cookie information (e.g., cookies and similar technologies on websites and in emails)

4. Personal Data Source

The data we use about you may be directly provided by you or obtained from other sources, such as:

• Publications/databases made available by official authorities;
• Databases made publicly available by third parties;
• Any other third parties.

5. Other Cases of Personal Data Collection

In certain circumstances we may collect and use personal data of individuals with whom we have or could have a direct relationship such as:

• Visitors to our websites, including subscribers to our newsletters, funds documentation and investment recommendations;
• Prospective or existing clients;
• Attendees of our events or recipients of our marketing materials; investor in collective investment schemes or designated SPVs for which Azura Monaco acts as an investment manager or an investment advisor.

6. Why We Collect Your Personal Data

6.1 Compliance with Our Legal And Regulatory Obligations

We use your personal data to comply with legal and regulatory obligations (including any legal and regulatory guidance) and to comply with other legal process and law enforcement requirements (including any internal policy), which may include laws outside the country you are located in, including to:

• Comply with regulations dealing with prevention of money-laundering, financial crime, financing of terrorism and market abuse
• Comply with regulations relating to sanctions and embargos
• Comply with regulations relating to financial markets in particular with regard to investor protection
• Detect transactions which deviate from normal patterns
• Record, when necessary, our interactions (such as phone calls, chats, email)
• Define your credit risk score and your capacity to absorb any loss
• Reply to an official request from an administrative or judicial authority
• Prevent tax fraud and fulfil tax control and notification obligations
• Comply with any applicable transaction reporting obligations

6.2 Ability to Make Assessments On You Before Entering Any Contract

We use your personal data to enter into and perform our contracts, including to:

• Provide and perform our obligations with respect to the services we provide (e.g., ancillary and investment activities services, including management or advisory services) or in connection with fulfilling your instructions;
• Send administrative information, such as change of our terms, conditions and policies;
• Manage, administrate and distribute our services related to investment and advisory activities
• Maintain the ongoing relationship with respect to your holdings in specific Azura financial products;
• Provide you with information, including reports, regarding our services;
• Evaluate if we can offer you a service or a product and under which conditions.

6.3 Developing Our Business In Compliance With The Required Regulation

We use your personal data in order to develop our services and to improve our risk management, including:

• To prevent, detect, investigate about fraud;
• To manage our IT infrastructure;
• To personalize our offering of services to you;
• To provide customer management and administration;
• To analyse, evaluate and improve our business;
• To develop our business relationship with you and to improve the quality of our services.

7. We Request Your Consent for Specific Processing

If we need to carry out further processing for purposes other than those above, we will inform you and, where necessary, obtain your consent.

8. How We Share Your Data

Personal data may be disclosed to third parties in connection with the services we are providing to you. The recipients of any such information will depend on the services that are being provided. In order to fulfil the above purposes and subject to any confidentiality restriction we may have expressly agreed with you or any transaction parties, we may disclose your personal data to:

• Azura Partners SAM Group entities
• Service providers which perform services on our behalf
• Financial, taxation, regulatory or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain professionals such as lawyers, notaries or auditors
• To any other persons as agreed with you. The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a business relationship with, and/or from rendering our services to you.

9. How and For How Long We Keep Your Data

We will retain your personal data within a protected and controlled environment to maintain integrity and confidentiality for the longer of:

• The period required by applicable law or contractual obligations; or
• Such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests. Most personal data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law.

10. Your Rights

You have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by law.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party. Even if you object to the processing of personal data, we are nevertheless allowed to continue the same if the processing is:
  • legally mandatory
  • necessary for the performance of a contract to which you are a party
  • necessary for the performance of a task carried out in the public interest
  • necessary for the purposes of the legitimate interests we follow, including the establishment, exercise or defence of legal claims. We will not, however, use your personal data for direct marketing purposes without your consent or if you ask us not to do so. You also have the right to complain to the Information CCIN. Find out how to report a concern on their website: https://www.ccin.mc

11. Contact Us

If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact us at: Azura Monaco SAM, 1, Avenue Henry Dunant, 98000 Monaco.

Complaints Handling

Switzerland

Azura takes any complaint received with the most serious approach with a clear and transparent process for dealing on a timely manner.

1. How to Complain

If you do need to contact us to make a complaint, you can do so by writing to the following address: The Compliance Officer, Azura Suisse SA, place de Longemalle 2, 1204 Geneva. Alternatively, you can call us at +377 92000311 (calls are recorded for regulatory purposes). We will be able to take your call from Monday to Friday 8.30am to 6.00pm or send to us an email at compliance@azura.com.

2. How We Process Complaints

Within 5 business days of receiving your complaint, we will send you a letter or email of acknowledgement that will include a copy of this complaints procedure.

3. Who Will Deal with Your Complaint

Officers with an adequate level of seniority, knowledge and experience will deal with your complaint.

4. Follow Up

Our aim is to let you have a full response within 4 weeks of receiving your complaint. In this response, we will:

• Let you know the outcome of our investigation
• Advise you of what we intend to do to rectify the problem
• If we disagree with your complaint, clearly explain the reasons why

5. If Our Investigation Takes Longer Than 4 Weeks

Sometimes, an analysis into a complaint can take longer than 4 weeks. If this happens, we will:

• Write to you explaining the reason for the delay
• Try to resolve your complaint within a further 4 weeks

5.1 If it takes longer than 8 weeks

In exceptional circumstances, a complaint may take longer than 8 weeks to resolve. If this is the case, we will:

• Write to you again explaining the reason for the delay and giving a revised date for when you can expect a response
• If appropriate, inform you of any additional action you may be able to initiate

6. If You Disagree with Our Decision

We may reconsider our decision if you have new evidence beyond what you told us in your original complaint. You have 6 months from the date of our final response in which to appeal against our decision. If we have not heard from you in that time, we will consider the complaint resolved.

Privacy Policy

Switzerland

1. Introduction

This Policy sets out the obligations of Azura Suisse SA (CHE-422.159.303), a company registered in Geneva, regulated by the Swiss Financial Market Supervisory Authority (FINMA) and subject to supervision by the supervisory organisation AOOS in accordance with the Federal Act on Financial Institutions (FinIA). CCAF with agreement 2019-03, whose registered offices are at Place de Longemalle 2, 1204 Geneva ("the Company", "we", "us").

This Policy sets the Company's obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

2. Definitions

• "GDPR": EU Regulation 2016/679 (General Data Protection Regulation).
• "Personal data" is any information relating to an identified or identifiable natural person (a "data subject" as defined) such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• "Data subject" refers to clients, potential clients, suppliers, investors, employees and partners in respect of their personal data under GDPR.
• "Data controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• "Data processor" is a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.
• A "Related Person" means an individual or entity whose information you or a third party provide to us and/or which otherwise comes to our knowledge in connection with our business relationship. A Related Person may include, but is not limited to,
  • any director, officer, employee or authorized signatory of a company,
  • a trustee, settlor, beneficiary or protector of a trust,
  • any nominee or beneficial owner of an account,
  • a substantial interest owner in an account,
  • a controlling person,
  • a payee of a designated payment,
  • or any representative(s) or agent(s).

This Data Protection Notice explains how we process personal data. As a data controller, we are responsible for collecting and processing some of your personal data in relation to our activities. The purpose of this notice is to let you know which personal data we collect about you, the reasons why we use them and why we might share such personal data, how long we keep them, what are your rights and how you can exercise them. Please note that we may also process personal data in respect of an individual who is a Related Person to you.

3. Personal Data We Process About You

We collect and use your personal data in the context of our activities. We may collect various types of personal data about you depending on the nature of the particular service we provide, including:

• Identification information (e.g., full name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, fingerprint, IP address);
• Contact information (e.g., address and email address, phone number);
• Family situation (e.g., marital status, number of children);
• Tax status (e.g., tax ID, tax status);
• Education and employment information (e.g., level of education, remuneration);
• Banking, financial and transactional data (e.g., bank account details, transfer of assets, source of wealth);
• Data relating to your habits and preferences;
• Data which relates to your use of our services;
• Data from your interactions with us (e.g., our meetings, calls, chats, emails, phone conversations);
• Background checks;
• Cookie information (e.g., cookies and similar technologies on websites and in emails)

4. Personal Data Source

The data we use about you may be directly provided by you or obtained from other sources, such as:

• Publications/databases made available by official authorities;
• Databases made publicly available by third parties;
• Any other third parties.

5. Other Cases of Personal Data Collection

In certain circumstances we may collect and use personal data of individuals with whom we have or could have a direct relationship such as:

• Visitors to our websites, including subscribers to our newsletters, funds documentation and investment recommendations;
• Prospective or existing clients;
• Attendees of our events or recipients of our marketing materials; investor in collective investment schemes or designated SPVs for which Azura Monaco acts as an investment manager or an investment advisor.

6. Why We Collect Your Personal Data

6.1 Compliance with Our Legal And Regulatory Obligations

We use your personal data to comply with legal and regulatory obligations (including any legal and regulatory guidance) and to comply with other legal process and law enforcement requirements (including any internal policy), which may include laws outside the country you are located in, including to:

• Comply with regulations dealing with prevention of money-laundering, financial crime, financing of terrorism and market abuse
• Comply with regulations relating to sanctions and embargos
• Comply with regulations relating to financial markets in particular with regard to investor protection
• Detect transactions which deviate from normal patterns
• Record, when necessary, our interactions (such as phone calls, chats, email)
• Define your credit risk score and your capacity to absorb any loss
• Reply to an official request from an administrative or judicial authority
• Prevent tax fraud and fulfil tax control and notification obligations
• Comply with any applicable transaction reporting obligations

6.2 Ability to Make Assessments On You Before Entering Any Contract

We use your personal data to enter into and perform our contracts, including to:

• Provide and perform our obligations with respect to the services we provide (e.g., ancillary and investment activities services, including management or advisory services) or in connection with fulfilling your instructions;
• Send administrative information, such as change of our terms, conditions and policies;
• Manage, administrate and distribute our services related to investment and advisory activities
• Maintain the ongoing relationship with respect to your holdings in specific Azura financial products;
• Provide you with information, including reports, regarding our services;
• Evaluate if we can offer you a service or a product and under which conditions.

6.3 Developing Our Business In Compliance With The Required Regulation

We use your personal data in order to develop our services and to improve our risk management, including:

• To prevent, detect, investigate about fraud;
• To manage our IT infrastructure;
• To personalize our offering of services to you;
• To provide customer management and administration;
• To analyse, evaluate and improve our business;
• To develop our business relationship with you and to improve the quality of our services.

7. We Request Your Consent for Specific Processing

If we need to carry out further processing for purposes other than those above, we will inform you and, where necessary, obtain your consent.

8. How We Share Your Data

Personal data may be disclosed to third parties in connection with the services we are providing to you. The recipients of any such information will depend on the services that are being provided. In order to fulfil the above purposes and subject to any confidentiality restriction we may have expressly agreed with you or any transaction parties, we may disclose your personal data to:

• AZURA SUISSE SA Group entities
• Service providers which perform services on our behalf
• Financial, taxation, regulatory or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain professionals such as lawyers, notaries or auditors
• To any other persons as agreed with you. The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a business relationship with, and/or from rendering our services to you.

9. How and For How Long We Keep Your Data

We will retain your personal data within a protected and controlled environment to maintain integrity and confidentiality for the longer of:

• The period required by applicable law or contractual obligations; or
• Such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests. Most personal data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law.

10. Your Rights

You have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by law.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party. Even if you object to the processing of personal data, we are nevertheless allowed to continue the same if the processing is:
  • legally mandatory
  • necessary for the performance of a contract to which you are a party
  • necessary for the performance of a task carried out in the public interest
  • necessary for the purposes of the legitimate interests we follow, including the establishment, exercise or defence of legal claims. We will not, however, use your personal data for direct marketing purposes without your consent or if you ask us not to do so. You also have the right to complain to the Information CCIN. Find out how to report a concern on their website: https://www.ccin.mc

11. Contact Us

Contact us If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact us at: AZURA SUISSE SA, Place de Longemalle 2, 1204 Geneva.

Complaints Handling

Singapore

Azura takes any complaint received with the most serious approach with a clear and transparent process for dealing on a timely manner.

1. How to Complain

If you do need to contact us to make a complaint, you can do so by writing to the following address: The Compliance Officer, Azura Investment Partners Pte Ltd, 8 Temasek Boulevard, #08-02 Suntec Tower Three, Singapore 038988. Alternatively, you can call us at +65 67088011 (calls are recorded for regulatory purposes). We will be able to take your call from Monday to Friday 9.00am to 6.00pm or send to us an email at compliance@azura.com.

2. How We Process Complaints

Within 5 business days of receiving your complaint, we will send you a letter or email of acknowledgement that will include a copy of this complaints procedure.

3. Who Will Deal with Your Complaint

Officers with an adequate level of seniority, knowledge and experience will deal with your complaint.

4. Follow Up

Our aim is to let you have a full response within 4 weeks of receiving your complaint. In this response, we will:

• Let you know the outcome of our investigation
• Advise you of what we intend to do to rectify the problem
• If we disagree with your complaint, clearly explain the reasons why

5. If Our Investigation Takes Longer Than 4 Weeks

Sometimes, an analysis into a complaint can take longer than 4 weeks. If this happens, we will:

• Write to you explaining the reason for the delay
• Try to resolve your complaint within a further 4 weeks

5.1 If it takes longer than 8 weeks

In exceptional circumstances, a complaint may take longer than 8 weeks to resolve. If this is the case, we will:

• Write to you again explaining the reason for the delay and giving a revised date for when you can expect a response
• If appropriate, inform you of any additional action you may be able to initiate

6. If You Disagree with Our Decision

We may reconsider our decision if you have new evidence beyond what you told us in your original complaint. You have 6 months from the date of our final response in which to appeal against our decision. If we have not heard from you in that time, we will consider the complaint resolved.

Privacy Policy

Singapore

1. Introduction

This Policy sets out the obligations of Azura Investment Partners Pte. Ltd., a company registered in Singapore, regulated by MAS, whose registered offices are at 8 Temasek Boulevard #08-02 Suntec Tower Three Singapore 038988 ("the Company", "we", "us").

This Policy sets the Company's obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

2. Definitions

• "Data subject" refers to clients, potential clients, suppliers, investors, employees and partners in respect of their personal data under the Personal Data Protection Act 2012.
• "Data controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• "Data processor" is a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.
• A "Related Person" means an individual or entity whose information you or a third party provide to us and/or which otherwise comes to our knowledge in connection with our business relationship. A Related Person may include, but is not limited to,
  • any director, officer, employee or authorized signatory of a company,
  • a trustee, settlor, beneficiary or protector of a trust,
  • any nominee or beneficial owner of an account,
  • a substantial interest owner in an account,
  • a controlling person,
  • a payee of a designated payment,
  • or any representative(s) or agent(s).

This Data Protection Notice explains how we process personal data. As a data controller, we are responsible for collecting and processing some of your personal data in relation to our activities. The purpose of this notice is to let you know which personal data we collect about you, the reasons why we use them and why we might share such personal data, how long we keep them, what are your rights and how you can exercise them. Please note that we may also process personal data in respect of an individual who is a Related Person to you.

3. Personal Data We Process About You

We collect and use your personal data in the context of our activities. We may collect various types of personal data about you depending on the nature of the particular service we provide, including:

• Identification information (e.g., full name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, fingerprint, IP address);
• Contact information (e.g., address and email address, phone number);
• Family situation (e.g., marital status, number of children);
• Tax status (e.g., tax ID, tax status);
• Education and employment information (e.g., level of education, remuneration);
• Banking, financial and transactional data (e.g., bank account details, transfer of assets, source of wealth);
• Data relating to your habits and preferences;
• Data which relates to your use of our services;
• Data from your interactions with us (e.g., our meetings, calls, chats, emails, phone conversations);
• Background checks;
• Cookie information (e.g., cookies and similar technologies on websites and in emails)

4. Personal Data Source

The data we use about you may be directly provided by you or obtained from other sources, such as:

• Publications/databases made available by official authorities;
• Databases made publicly available by third parties;
• Any other third parties.

5. Other Cases of Personal Data Collection

In certain circumstances we may collect and use personal data of individuals with whom we have or could have a direct relationship such as:

• Visitors to our websites, including subscribers to our newsletters, funds documentation and investment recommendations;
• Prospective or existing clients;
• Attendees of our events or recipients of our marketing materials; investor in collective investment schemes or designated SPVs for which Azura Monaco acts as an investment manager or an investment advisor.

6. Why We Collect Your Personal Data

6.1 Compliance with Our Legal And Regulatory Obligations

We use your personal data to comply with legal and regulatory obligations (including any legal and regulatory guidance) and to comply with other legal process and law enforcement requirements (including any internal policy), which may include laws outside the country you are located in, including to:

• Comply with regulations dealing with prevention of money-laundering, financial crime, financing of terrorism and market abuse
• Comply with regulations relating to sanctions and embargos
• Comply with regulations relating to financial markets in particular with regard to investor protection
• Detect transactions which deviate from normal patterns
• Record, when necessary, our interactions (such as phone calls, chats, email)
• Define your credit risk score and your capacity to absorb any loss
• Reply to an official request from an administrative or judicial authority
• Prevent tax fraud and fulfil tax control and notification obligations
• Comply with any applicable transaction reporting obligations

6.2 Ability to Make Assessments On You Before Entering Any Contract

We use your personal data to enter into and perform our contracts, including to:

• Provide and perform our obligations with respect to the services we provide (e.g., ancillary and investment activities services, including management or advisory services) or in connection with fulfilling your instructions;
• Send administrative information, such as change of our terms, conditions and policies;
• Manage, administrate and distribute our services related to investment and advisory activities
• Maintain the ongoing relationship with respect to your holdings in specific Azura financial products;
• Provide you with information, including reports, regarding our services;
• Evaluate if we can offer you a service or a product and under which conditions.

6.3 Developing Our Business In Compliance With The Required Regulation

We use your personal data in order to develop our services and to improve our risk management, including:

• To prevent, detect, investigate about fraud;
• To manage our IT infrastructure;
• To personalize our offering of services to you;
• To provide customer management and administration;
• To analyse, evaluate and improve our business;
• To develop our business relationship with you and to improve the quality of our services.

7. We Request Your Consent for Specific Processing

If we need to carry out further processing for purposes other than those above, we will inform you and, where necessary, obtain your consent.

8. How We Share Your Data

Personal data may be disclosed to third parties in connection with the services we are providing to you. The recipients of any such information will depend on the services that are being provided. In order to fulfil the above purposes and subject to any confidentiality restriction we may have expressly agreed with you or any transaction parties, we may disclose your personal data to:

• Azura Investment Partners Pte. Ltd. Group entities
• Service providers which perform services on our behalf
• Financial, taxation, regulatory or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain professionals such as lawyers, notaries or auditors
• To any other persons as agreed with you. The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a business relationship with, and/or from rendering our services to you.

9. How and For How Long We Keep Your Data

We will retain your personal data within a protected and controlled environment to maintain integrity and confidentiality for the longer of:

• The period required by applicable law or contractual obligations; or
• Such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests. Most personal data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law.

10. Your Rights

You have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by law.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party. Even if you object to the processing of personal data, we are nevertheless allowed to continue the same if the processing is:
  • legally mandatory
  • necessary for the performance of a contract to which you are a party
  • necessary for the performance of a task carried out in the public interest
  • necessary for the purposes of the legitimate interests we follow, including the establishment, exercise or defence of legal claims. We will not, however, use your personal data for direct marketing purposes without your consent or if you ask us not to do so.

11. Contact Us

Contact us If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact us at: Azura Investment Partners Pte Ltd., 8 Temasek Boulevard, #08-02 Suntec Tower Three, Singapore 038988.

Complaints Handling

Dubai

Azura takes any complaint received with the most serious approach with a clear and transparent process for dealing on a timely manner.

1. How to Complain

The Compliance Officer, Azura Middle East Limited, Office 30-08 ICD Brookfield Place, DIFC, Dubai, UAE. Alternatively, you can call us at +971 4 5969171 (calls are recorded for regulatory purposes). We will be able to take your call from Monday to Friday 9.00am to 6.00pm or send to us an email at compliance@azura.com.

2. How We Process Complaints

Within 5 business days of receiving your complaint, we will send you a letter or email of acknowledgement that will include a copy of this complaints procedure.

3. Who Will Deal with Your Complaint

Officers with an adequate level of seniority, knowledge and experience will deal with your complaint.

4. Follow Up

Our aim is to let you have a full response within 20 business days of receiving your complaint. In this response, we will:

• Let you know the outcome of our investigation
• Advise you of what we intend to do to rectify the problem
• If we disagree with your complaint, clearly explain the reasons why

5. If Our Investigation Takes Longer Than 20 Business Days

Sometimes, an analysis into a complaint can take longer than 20 business days. If this happens, we will:

• Write to you explaining the reason for the delay
• Try to resolve your complaint within a further 20 business days

5.1 If it takes longer than 40 business days

In exceptional circumstances, a complaint may take longer than 40 business days to resolve. If this is the case, we will:

• Write to you again explaining the reason for the delay and giving a revised date for when you can expect a response
• If appropriate, inform you of any additional action you may be able to initiate

6. If You Disagree with Our Decision

We may reconsider our decision if you have new evidence beyond what you told us in your original complaint. You have 6 months from the date of our final response in which to appeal against our decision. If we have not heard from you in that time, we will consider the complaint resolved.

Privacy Policy

Dubai

1. Introduction

This Policy sets out the obligations of Azura Middle East Limited, a company registered in the Dubai International Financial Centre (DIFC), regulated by the Dubai Financial Services Authority (DFSA), whose registered offices are at Office 30-08 ICD Brookfield Place, DIFC, Dubai, UAE ("the Company", "we", "us").

This Policy sets the Company's obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

2. Definitions

• "Data subject" refers to clients, potential clients, suppliers, investors, employees and partners in respect of their personal data under the DIFC Data Protection Law (DIFC Law no 5 of 2020) and DIFC Data Protection Regulations (hereafter referred to as the "Data Protection Law").
• "Data controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• "Data processor" is a natural or legal person, public authority, agency or other body, which processes personal data on behalf of the controller.
• A "Related Person" means an individual or entity whose information you or a third party provide to us and/or which otherwise comes to our knowledge in connection with our business relationship. A Related Person may include, but is not limited to,
  • any director, officer, employee or authorized signatory of a company,
  • a trustee, settlor, beneficiary or protector of a trust,
  • any nominee or beneficial owner of an account,
  • a substantial interest owner in an account,
  • a controlling person,
  • a payee of a designated payment,
  • or any representative(s) or agent(s).

This Data Protection Notice explains how we process personal data. As a data controller, we are responsible for collecting and processing some of your personal data in relation to our activities. The purpose of this notice is to let you know which personal data we collect about you, the reasons why we use them and why we might share such personal data, how long we keep them, what are your rights and how you can exercise them. Please note that we may also process personal data in respect of an individual who is a "Related Person" to you.

3. Personal Data We Process About You

We collect and use your personal data in the context of our activities. We may collect various types of personal data about you depending on the nature of the particular service we provide, including:

• Identification information (e.g., full name, ID card and passport numbers, nationality, place and date of birth, gender, photograph, fingerprint, IP address);
• Contact information (e.g., address and email address, phone number);
• Family situation (e.g., marital status, number of children);
• Tax status (e.g., tax ID, tax status);
• Education and employment information (e.g., level of education, remuneration);
• Banking, financial and transactional data (e.g., bank account details, transfer of assets, source of wealth);
• Data relating to your habits and preferences;
• Data which relates to your use of our services;
• Data from your interactions with us (e.g., our meetings, calls, chats, emails, phone conversations);
• Background checks;
• Cookie information (e.g., cookies and similar technologies on websites and in emails)

4. Personal Data Source

The data we use about you may be directly provided by you or obtained from other sources, such as:

• Publications/databases made available by official authorities;
• Databases made publicly available by third parties;
• Any other third parties.

5. Other Cases of Personal Data Collection

In certain circumstances we may collect and use personal data of individuals with whom we have or could have a direct relationship such as:

• Visitors to our websites, including subscribers to our newsletters, funds documentation and investment recommendations;
• Prospective or existing clients;
• Attendees of our events or recipients of our marketing materials; investor in collective investment schemes or designated SPVs for which Azura Monaco acts as an investment manager or an investment advisor.

6. Why We Collect Your Personal Data

6.1 Compliance with Our Legal And Regulatory Obligations

We use your personal data to comply with legal and regulatory obligations (including any legal and regulatory guidance) and to comply with other legal process and law enforcement requirements (including any internal policy), which may include laws outside the country you are located in, including to:

• Comply with regulations dealing with prevention of money-laundering, financial crime, financing of terrorism and market abuse
• Comply with regulations relating to sanctions and embargos
• Comply with regulations relating to financial markets in particular with regard to investor protection
• Detect transactions which deviate from normal patterns
• Record, when necessary, our interactions (such as phone calls, chats, email)
• Define your credit risk score and your capacity to absorb any loss
• Reply to an official request from an administrative or judicial authority
• Prevent tax fraud and fulfil tax control and notification obligations
• Comply with any applicable transaction reporting obligations

6.2 Ability to Make Assessments On You Before Entering Any Contract

We use your personal data to enter into and perform our contracts, including to:

• Provide and perform our obligations with respect to the services we provide (e.g., ancillary and investment activities services, including management or advisory services) or in connection with fulfilling your instructions;
• Send administrative information, such as change of our terms, conditions and policies;
• Manage, administrate and distribute our services related to investment and advisory activities
• Maintain the ongoing relationship with respect to your holdings in specific Azura financial products;
• Provide you with information, including reports, regarding our services;
• Evaluate if we can offer you a service or a product and under which conditions.

6.3 Developing Our Business In Compliance With The Required Regulation

We use your personal data in order to develop our services and to improve our risk management, including:

• To prevent, detect, investigate about fraud;
• To manage our IT infrastructure;
• To personalize our offering of services to you;
• To provide customer management and administration;
• To analyse, evaluate and improve our business;
• To develop our business relationship with you and to improve the quality of our services.

7. We Request Your Consent for Specific Processing

If we need to carry out further processing for purposes other than those above, we will inform you and, where necessary, obtain your consent.

8. How We Share Your Data

Personal data may be disclosed to third parties in connection with the services we are providing to you. The recipients of any such information will depend on the services that are being provided. In order to fulfil the above purposes and subject to any confidentiality restriction we may have expressly agreed with you or any transaction parties, we may disclose your personal data to:

• Azura Middle East Limited group entities
• Service providers which perform services on our behalf
• Financial, taxation, regulatory or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
• Certain professionals such as lawyers, notaries or auditors
• To any other persons as agreed with you. The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a business relationship with, and/or from rendering our services to you.

9. How and For How Long We Keep Your Data

We will retain your personal data within a protected and controlled environment to maintain integrity and confidentiality for the longer of:

• The period required by applicable law or contractual obligations; or
• Such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests. Most personal data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law.

10. Your Rights

You have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data is inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by law.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party. Even if you object to the processing of personal data, we are nevertheless allowed to continue the same if the processing is:
  • legally mandatory
  • necessary for the performance of a contract to which you are a party
  • necessary for the performance of a task carried out in the public interest
  • necessary for the purposes of the legitimate interests we follow, including the establishment, exercise or defence of legal claims. We will not, however, use your personal data for direct marketing purposes without your consent or if you ask us not to do so.
• To complain: Should you not be satisfied with the way we have responded to your concerns you have the right to submit a complaint to us. If you are still unhappy with our reaction to your complaint, you can escalate it to our Compliance Department. You can also contact the DIFC Protection Commissioner (DIFC the Gate, Level 14, PO Box 74777, Dubai, T.: +971 4 362 2600)

11. Contact Us

If you have any questions relating to our use of your personal data under this Data Protection Notice, please contact us at: Azura Middle East Limited, Office 30-08 ICD Brookfield Place, DIFC, Dubai, UAE