Legal Information

Spring Capital Partners GmbH
Opernplatz 14
60313 Frankfurt
Germany

Commercial register no. HRB 129475

Managing Director: Delphine Kadel

Email: investorrelations@springcapitalpartners.com

Tel: +49 (0) 69 153294 495

Spring Capital Partners GmbH is entitled to exclusively engage in investment brokerage (by promotion of the potential investor's willingness to enter into a transaction but excluding the reception and transmission of orders) to professional clients as defined in Annex II MiFID II and as implemented in the respective national legislation. Spring Capital Partners GmbH is only allowed to provide its service according to Article 29 (3) of MiFID II and as implemented in the respective national legislation for the account and under the liability of Acolin Europe AG, Reichenaustrasse 11 a-c, 78467 Konstanz, authorised and regulated by the German Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) and is entered in the public register of tied agents held by BaFin.

The information contained on this website is for professional investors only and should not be circulated to retail investors.

The funds are not offered for sale in the USA, its territories or possessions nor to any US persons including citizens of the United States, nor in any jurisdiction in which the fund is not authorised to be publicly sold. The funds are available only in jurisdictions where their promotion and sale are permitted.

The information contained in the website may not be redistributed directly or indirectly to any citizen or resident of the United States or any other jurisdiction where its distribution may be restricted by law. It is the responsibility of persons accessing the website to ensure that they are allowed to access the information contained herein. This website and the information contained herein does not constitute an offer or recommendation or invitation to purchase any funds or products.

Spring Capital Partners GmbH (“Spring”) does not provide and nothing contained in this website should be deemed to constitute the provision of financial, investment, tax or any other professional advice in any way. This site does not constitute or form part of any offer to issue or sell, or any solicitation of an offer to subscribe or purchase any investment nor shall it or the fact of its distribution form the basis of, or be relied on in connection with, any contract therefore.

The information contained within this site is strictly confidential and may not be reproduced, distributed or published by any recipient for any purpose without the prior written consent of Spring.

No representation, warranty, or undertaking, express or limited, is given as to the accuracy or completeness of the information or opinions contained within this website by Spring or any of its directors or employees and no liability is accepted by such persons for the accuracy or completeness of any such information or opinions. As such, no reliance may be placed for any purpose on the information and opinions contained within this site.

Risk Warnings

Please remember that the value of investments and the income from them can fluctuate (this may partly be the result of exchange rate fluctuations) and you may not get back the full amount invested. Past performance is not a guide to the future. Where Spring has expressed its own views and opinions, these may change.

By using this website you confirm that you accept these terms as binding. We reserve the right to change the terms of this Disclaimer without notice, and by accessing or using the website, you agree to abide by such changes.

Data Privacy Policy

Spring Capital Partners GmbH, German commercial register no. HRB 129475 (“Spring Capital”), are committed to protecting and respecting your privacy.

This Privacy Policy explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data and keep it safe.

By accessing this Site, you acknowledge that you have read and agree to the practices described in this Policy.

Personal data is any information that enables us to identify you, either directly or indirectly in conjunction with any other information we hold, by reference to an identifier such as name, address, date of birth or government identification number.

Our Data Protection Officer (DPO) is:

Delphine Kadel, Managing Director
Email:    delphine.kadel@springcapitalpartners.com
Tel:         +49 (0) 69 153294 495

The legal basis we rely on: Legitimate interest

Under Article 6 (1b) of the GDPR, the legal basis that Spring Capital employs for processing your personal data is that processing of your personal data is necessary for the performance of a contract to which you, the ‘data subject’ is party, or in order to take steps at your request prior to entering into such a contract.

For example, we might use your email address or telephone contact details to inform you of certain investment opportunities that we think might interest you.

When do we collect your data?

• Via business cards from meetings
• Contact details given over the phone
• Incoming email requests
• Incoming information requests via our website
• When we collect information from publicly-available sources where you have provided your consent to share information or where the information is made public as a matter of law

What sort of personal data do we collect?

We use different methods to collect personal data from and about you including through:

• Personal data you give us. You may give us your personal data including name and contact details, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you ask us about, or apply for, our products or services; subscribe to our services or publications; request marketing to be sent to you, or give us some feedback.

Personal data we collect

As you interact with our Site, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy below for further details.

How and why we process your data

We want to provide you with the best possible customer experience. One way to achieve that is to get the richest picture of your business and the way you work and your requirements.

We then use this information to not only deliver a high level of customer service but also to make you aware of investment products that we deem to be appropriate for your business/clients.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

If at any time you wish to change how we use your data, you can contact us to either unsubscribe from any future marketing communications or request us to remove your data entirely, which we are obliged to do as part of the new data privacy law in-line with our legal and regulatory responsibilities

We will use your personal data for the following purposes:

• To confirm your identity;
• To respond to your questions and provide related customer services;
• To detect and prevent fraud or other financial crime;
• To monitor and protect the security of our information, systems and network;
• For internal business intelligence purposes, to conduct research, product development and enhancement;
• To inform you of changes made to our Site and other services;
• To conduct marketing and commercial activities and to market relevant offers and promotions to you;
• To ensure that content from our Site is presented most effectively for you and your computer;
• To display content based on your interests;
• Enable you to search information on our Site;
• Assess your needs and interests in order to better tailor offers; and
• Improve our Site.

Of course, you are free to opt out of hearing from us by any of these channels at any time. If you would like to have all your details removed from our CRM system please email dataprotection@springcapitalpartners.com or call us on +49 (0) 69 153294 495.

How we protect your data

We know how much data security matters to all our customers. We will treat your data with the utmost care and take all appropriate steps to protect it.

Access to your personal data is password-protected and is stored within CRM system.

We regularly monitor our system for possible vulnerabilities and attacks.

Who do we share your personal data with?

Your personal data will be treated as being strictly confidential. We may share your personal data with the parties set out below for the purposes set out in this Policy:

• A member of our group;
• Companies that provide services to help us confirm your identity, meet our compliance and regulatory obligations, and to detect and prevent fraud or other financial crime;
• Our professional advisors such as auditors, accountants and lawyers, etc.;
• Companies that provide services to help us with our business activities, such as data storage, maintenance services, database management, web analytics and payment processing;
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We may also disclose your personal data as required by law, such as to comply with a subpoena, or a similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, and to any other third party with your prior consent to do so, unless notification is prohibited by the applicable law.

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

Where personal data relating to European based data subjects is shared with a third party located in a non-EU country that has not received an adequacy decision by the European Commission, we rely on appropriate safeguards. We never share your data with third parties for their own purposes

Where your data may be processed?

Sometimes we will need to share your data with third-parties and suppliers outside the European Economic Area (EEA), such as the United States.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA, for example our contracts with third-parties stipulate the standards they must follow at all times.

How long do we keep your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, after which time it will be destroyed securely if it is no longer needed for the lawful purposes for which it was obtained.

In some limited cases, it may be necessary to retain your personal data for longer if we need to hold it for liability claim purposes (e.g. if any complaints were to be made to an ombudsman service), and for example to hold and provide to a regulatory body.

If you consent to receive marketing from us, any information we use for this purpose will be held by us until such time as you notify us that you no longer wish to receive marketing information from us.

What are your rights with regards to your data?

Unless subject to an exemption under the GDPR, you may have the following rights with respect to your personal data:

• to request a copy of your personal data which Spring Capital holds about you;
• to request that Spring Capital corrects any of your personal data if it is found to be inaccurate or out of date;
• to request your personal data to be erased where it is no longer necessary for Spring Capital to retain such data;
• to withdraw your consent to the processing of your personal data at any time;
• to request that Spring Capital provides you with your personal data, and where possible, to transmit the data directly to another data controller (known as the right to data portability);
• where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• to object to the processing of your personal data with regards to Direct Marketing;
• to lodge a complaint with an EU Data Protection Authority, such as the Information Commissioner’s Office (ICO) in the UK.

Where we rely on our legitimate interest

In cases where we are processing your data on the basis of legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data. For example, regulatory requirement.

Marketing

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other entities within our group. If you no longer wish to be contacted for marketing purposes, please contact us or simply click the ‘unsubscribe’ link in any email communication that we send you.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Automated decision making

We do not use automated decision making to segment and target product offers based on our customers’ demands and needs. For further details, you may contact our Data Protection Officer whose details are provided in the ‘Contact Details’ section of this Policy.

Further processing

If we wish to use your personal data for a new purpose, not defined by this Policy, then we will provide you with a new notice explaining this new use prior to the commencement of the new processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Changes to this privacy policy

We will update this Policy from time to time, so please check back periodically.

The provisions contained in this Policy supersede all previous notices or policies regarding our use personal data.

Contact Details

Contacting the Regulator

If you feel that your data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your data, you have the right to lodge a complaint the relevant data protection authority in your country.

In Germany that is Bundesbeauftragter für den Datenschutz und die informationsfreiheit.

In the UK that is the Information Commissioners Office.

Any Questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your data and your rights to control it.

If you have any questions that have not been covered, please contact our Data Protection Officer who will be pleased to help you.

Email: dataprotection@springcapitalpartners.com

Or write to us at

Data Protection Officer
Spring Capital Partners GmbH
Opernplatz 14
60313 Frankfurt
Germany

Cookie Policy

This Cookie Policy applies to Spring Capital Partners GmbH (“we”, “us” or “our”, “Spring Capital”).

Like most businesses, we employ “cookies” or similar technologies. This Cookie Policy tells you about the use of Cookies and similar technologies on www.springcapitalpartners.eu/(the “Site”).

When you first access the Site from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By clicking “accept cookies”, closing the message, or continuing to browse the Site, you signify that you understand and agree to the use of these technologies, as described in this Cookie Policy.

You do not have to accept cookies and consent can be withdrawn at any time (see How to Control Cookies, below). You can change your browser settings to refuse or restrict cookies, and you may delete them after they have been placed on your device at any time. If you do not accept or delete our cookies, some areas of the Site that you access may take more time to work, or may not function properly.

WHAT ARE COOKIES?

Cookies are small files containing a string of characters that we may store on your computer or mobile device when you visit the Site. When you visit the Site again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.

Cookies set by a website owner (in this case, Spring capital) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable us to provide third party features or functionality through the Site (i.e. advertising, social media functions and analytics).

THE COOKIES WE USE

Cookies make the use of the Site easier by, among other things, saving your preferences. We may also use cookies to deliver content tailored to your interests. Our cookies may enable us to relate your use of the Site to personal data that you previously submitted.

The information that we collect with cookies allows us to statistically analyze usage of the Site, and to improve and customize our content and other offerings. However, we only disclose information collected with cookies to third parties on an aggregated basis without the use of any information that personally identifies you.

The specific types of first party and third party cookies placed by the Site and the purposes they perform are described in the table below:

HOW TO CONTROL COOKIES

When you first access the Site from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By clicking “accept cookies”, closing the message, or continuing to browse the website, you signify that you understand and agree to the use of these technologies, as described in this Cookie Policy.

You do not have to accept cookies and consent can be withdrawn at any time, although you may not be able to use certain features on the Site. You can do this by clicking the appropriate opt-out provided in the cookie table above or by activating the settings on your browser that allows you to refuse all or some cookies.

Please follow the links below to helpful information for the most popular browsers:

• Microsoft Internet Explorer:

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

• Google Chrome:

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

• Mozilla Firefox:

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Apple Safari:

https://support.apple.com/kb/PH21411?locale=en_US

In addition, you can exercise advertising cookie choices by visiting:

• http://www.aboutads.info/choices/,
• http://www.networkadvertising.org/choices/; or
• http://youronlinechoices.com/.

WEB BEACONS

As well as cookies, we use other technologies to recognize and track visitors to the Site. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie.

Web beacons allows us, for example, to monitor how users move from one page within our websites to another, to track access to our communications, to understand whether users have come to our websites from an online advertisement displayed on a third-party website, to measure how ads have been viewed and to improve site performance.

TARGETING ADVERTISING

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and service that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements.

CHANGES TO THIS COOKIE POLICY

We will update this Cookie Policy from time to time, so please check back periodically.

The provisions contained in this Cookie Policy supersede all previous notices or policies regarding our use of cookies and similar technology on the Site.

We encourage you to check frequently to see the current Cookie Policy to be informed of how Spring Capital is committed to protecting your information and providing you with improved content on the Site in order to enhance your experience.

CONTACT DETAILS

To raise queries or complaints about this Cookie Policy or our Site, please in the first instance contact the Data Protection Officer, Delphine Kadel.

By email: delphine.kadel@springcapitalpartners.com

By post:

The Data Protection Officer
Spring Capital Partners GmbH
Opernplatz 14
60313 Frankfurt
Germany