Level E Capital SICAV plc Website Privacy and Cookies Policy

Level E Capital SICAV plc (us, we, the Fund) is committed to ensuring that your privacy is protected, and all data collected by us through this website will be processed in accordance with this privacy and cookies policy. Please read this policy carefully to ensure you understand our views and practices regarding your personal data and how we will treat it.

Please note that this policy document only covers data processing activities the Fund carries out in order to administer this website. Investors in the Fund should consult the data protection notice provided during the subscription process for additional information about how their personal data is processed.

For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR), the data controller is Level E Capital SICAV plc. The Fund can be contacted at info@levelecapital.com, or  via Apex Fund Services, its administrator, at Central North Business Centre, Level 1, Sqaq il-Fawwara, Sliema, SLM1670, Malta.

By visiting our Site or by providing us with information you are accepting the practices described in this Privacy and Cookies Policy.

1. WHAT INFORMATION WE PROCESS
   1. We may collect and process the following information from you:
      1. information we may automatically collect such as technical information including the internet protocol (IP) address used to connect to the internet, and information about your visit including the full Uniform Resource Locators (URL) clickstream.
2. HOW DO WE USE YOUR PERSONAL DATA?
   1. We may use your personal information:
      1. to help us provide you with the best possible service on this Website;
      2. to ensure that the content from our Website is presented in the most effective manner for you and your computer;
      3. as part of our efforts to keep our Website safe and secure; and
      4. for analytical and statistical purposes.
3. DISCLOSURE OF INFORMATION
   1. We will only supply your personal information to a third party:
      1. where we need to share the information to provide you with the best possible service on this Website;
      2. where we need to send the information to persons or organisations who work on our behalf to administer this Website, but such persons or organisations may only use this information in order to administer this Website and not for any other purpose;
      3. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of our company, our customers or others, including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
4. WHERE WE STORE YOUR INFORMATION
   1. The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers for the purposes set out above only. In order to ensure that any third party treats your personal data in a way which is consistent with the UK and EU’s laws on data protection, we have put in place agreements with those third parties which contain provisions approved by the EU for protecting personal data.
5. IP ADDRESSES AND COOKIES
   1. We may obtain information about your computer and general internet usage, including your IP address, operating system and browser type, for system administration purposes.
   2. Cookies contain information that is transferred to your computer’s hard drive. Cookies allow us to tailor our Website to your needs by gathering and remembering information about your usage and preferences.
   3. In particular, cookies enable us:
      1. to gather information on IP addresses and pages visited;
      2. to administer the website;
      3. to track users’ movements on the website; and
      4. to undertake statistical analysis.
   4. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Website or accessing certain parts. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you access our Website.
   5. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
   6. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
   7. Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
   8. The table below provides more information about the cookies we use and why:

      Name of cookie	Owner	Purpose for the cookie
      Session Cookies (JSESSIONID)		Created when a new session is started (you connect to our website) and deleted when the session ends. Allows our server to temporarily identify your web browser to ensure that we are providing you with the content you are requesting.

   9. Most browsers allow you to refuse to accept cookies; for example:

      1 in Firefox (version 51) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”;

      in Chrome (version 55), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading; and

      in Internet Explorer (11) you can turn “Cookies” off by opening Internet Explorer, click Internet options and select the “Privacy” tab. Under “Settings” move the slider to the top or bottom to decline or allow “Cookies” by selecting high or low and then press “apply”.

   10. You can delete cookies already stored on your computer; for example:

       in Firefox (version 51), you can delete all cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”;

       in Chrome (version 55), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”; and

   11. In Internet Explorer (11) you can select the safety button and then select Delete Browsing History. Then select the check box next to “Cookies”. Select the preserve favourites website data check box if you don’t want to delete the “Cookies” associated with website in their favourites list. Select delete.
6. LINKS TO OTHER WEBSITES
   1. This policy extends only to our Website and does not cover your use of, provision of data to and collection of your data on any other website.
   2. Our Website may from time to time contain links to and from other websites. If you follow a link to any of these websites please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should always check these policies before you submit any personal data to any third party website.
7. YOUR RIGHTS IN RESPECT OF YOUR INFORMATION

   The GDPR gives you a number of rights in respect of your data, including:

   1. Right to access
      1. You have the right to access the information we hold about you. If you would like a copy of this information please contact info@levelecapital.com. We may request proof of your identity before sharing such information.
   2. Right to rectify your personal data
      1. If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information. You can do so by clicking on the “Update my Contact Preferences” link at the bottom of any emails we send, or by contacting us at info@levelecapital.com.
   3. Right to be forgotten
      1. You may ask us to delete information we hold about you in certain circumstances. It may not be possible for us to delete all of the information we hold about you where we have an ongoing relationship, however please contact us at info@levelecapital.com and we will do our best to assist with your request.
   4. Other rights
      1. In addition to the above, you may also ask us to stop or restrict processing of the information we have about you. You may also ask us to transfer your personal information to a third party in certain circumstances. If you would like any other information on these aspect of your rights, please contact us at info@levelecapital.com.
8. CONTACT
   1. If you have any questions, want to exercise any of your rights or make a complaint, please contact us using the details at the beginning of this policy.
   2. If we are unable to resolve your complaint you may contact the Office of the Information and Data Protection Commissioner at Floor 2, Airways House, Triq Il – Kbira, Tas-Sliema SLM 1549, Malta. Tele: +356 2328 7100.
9. CHANGES TO THIS PRIVACY POLICY

   This policy may be reviewed and amended from time to time. As a result of improvements we make to our services, changes in the law or developments in technology, we may change the information we hold about you, the method and purposes for which we process such information. If we make any substantial change in the way in which we use your personal information we will notify you by email.

10. LAW AND JURISDICTION

    Your use of the Website and the policy is subject to the laws of Malta and the exclusive jurisdiction of the Maltese courts regarding any disputes that may arise under it.