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PRIVACY POLICY SUPPLEMENT FOR RESIDENTS OF THE EEA AND INVESTORS IN CAYMAN ISLAND ENTITIES

LAST UPDATED: APRIL 1, 2024

EEA INVESTORS

As required under the General Data Protection Regulation 2016/679 (as amended, the “GDPR”), if you are resident in the European Economic Area (“EEA”) or if you are not a natural person and your shareholders, directors, officers, members, agents, designees and/or beneficiaries (“Underlying Data Subjects”) are resident in the EEA or have invested into an entity organized under the laws of the EEA (together or as appropriate in the circumstances, an “EEA Investor”), we are providing the notice as set out in the Appendix hereto in order to inform you of our privacy policies and practices with respect to the processing of personal data for EEA Investors. For the avoidance of doubt, the EEA includes the member states of the European Union plus Iceland, Norway, and Liechtenstein.

CAYMAN ISLANDS DATA PROTECTION
 

For each entity organized under the laws of the Cayman Islands through which you may have invested (regardless of your nationality or location of residence), the applicable entity also has obligations to you under applicable data protection laws. The Data Protection Act (as amended) of the Cayman Islands (as amended, the “DPL”) provides similar rights to investors and requires data controllers and processors to implement specific requirements similar to those applicable under the GDPR. Therefore, if you have invested through an entity organized under the laws of the Cayman Islands, please consider yourself an EEA Investor (albeit in a Cayman Islands only context) and note that you will have rights in relation to personal data as set out below. For the avoidance of doubt, considering yourself an EEA Investor (in a Cayman Islands only context) by no means seeks to imply that you have rights under the GDPR that are not otherwise applicable to you based on your nationality or location of residence. For any investor in an entity organized under the laws of the Cayman Islands, please note that you may raise complaints with the Cayman Islands Ombudsman via https://ombudsman.ky/data-protection.

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