Privacy Policy

Cadarn Capital Ltd – Privacy Notice

This notice describes how Cadarn Capital Ltd (“Cadarn”) uses personal data.

It outlines Cadarn’s data protection obligations and your data protection rights under the regime introduced by the EU General Data Protection (Regulation 2016/679, the "General Data Protection Regulation").

The GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

Cadarn needs to use your personal data to provide its services to you. This notice
outlines the following points about the processing of your personal data:

—which data items are used, how they are used and who they are shared with;
—why this is done and the lawful basis; and
—your rights and Cadarn’s obligations..

Why Cadarn Needs To Process Personal Data

Your Data are collected to effectively and properly manage your relationship with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the Data for several different purposes, including:

1. to carry out obligations (such as but not limited to placement agent services – for example making qualified introductions) arising from any agreements entered into between you and Cadarn;
2. to provide you with information, products or services that you request from us
(including through our website) or which we feel may interest you; and
3. to competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting.

Data Collection

‍Cadarn may collect data:

1. when you or an agent of yours contacts Cadarn in relation to business and
services offered;
2. when you complete documents or forms during the course of business with
Cadarn;
3. from Service Providers and other third parties that assist us in conducting
business;
4. when you telephone Cadarn; and
5. when you use the Cadarn website.

Types Of Data That Might Be Collected

During Cadarn’s relationship with you Cadarn will collect and process Data about
you, including:

1. information which individuals and entities provide when contacting us (including
through using this website) such as their names, postal addresses, telephone
numbers, identification documents and email addresses;
2. corporate information;
3. details of services provided to you; and
4. where permitted or required by regulators or the law, special categories of
personal information such as information relating to criminal convictions or
offences.‍

Data Sharing

Cadarn uses Service Providers to conduct aspects of its business, so information may be disclosed to them and their affiliates Data that you have provided in order to fulfil the purposes for which the Data is held. These Service Providers may disclose such Data to each other and to each other’s affiliates in order to achieve the same purposes. Cadarn and its Service Providers may also be required to disclose your Data to governmental agencies, self-regulatory organisations, industry associations and similar bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain countries and states give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from Cadarn and its Service Providers, including your Data. Cadarn and its Service Providers will comply with
these laws to the extent required.

Cadarn will not sell your Data to any third party. Wherever possible, Service Providers are required to enter into confidentiality agreements that prohibit them from selling or improperly using your Data.‍

Data Retention

Cadarn will retain your personal information for a period of up to seven years
following the point where the business relationship has ceased.

It may be necessary to retain your personal information beyond this period depending on additional legal/regulatory obligations. Thereafter, Cadarn will refrain from collecting any further personal information on you and shall take appropriate steps to dispose of any records containing your personal information to the extent this is operationally feasible and proportionate.‍

Cookies

We do not collect data about our users other than if you contact Cadarn using the
'Contact Us' form. This website does not place cookies on your computer and does not use any other means of data collection. From emails we may collect your name, your email address and any other information which you decide to supply.‍

Lawful Basis For Processing

Cadarn assesses all personal data that is collected or stored to ensure that there is a legal basis for each type of data under GDPR. The majority of lawful basis for Cadarn’s processing is to meet its obligations to the FCA (legal obligation basis) or to fulfil its obligations to clients under contract (contract basis).

Other lawful basis may be used where Cadarn assesses this is necessary and
appropriate.‍

Data Subject Rights

You have the following rights, in certain circumstances, in relation to your personal
information:

—Right to access your personal information (in an easily readable form);
—Right to rectify your personal information;
—Right to restrict the use of your personal information (in certain specific
circumstances);
—Right to request that your personal information is erased (in certain specific
circumstances). Please note that the right for your data to be erased (the "right to
be forgotten") that applies in some contexts under the General Data Protection
Regulation is not likely to be applicable to most, if not all, of the personal
information you provide to Cadarn, given the specific nature of the purposes
for which Cadarn uses the data, as described above;
—Right to object to processing of your personal information (in certain specific
circumstances);
—Right to data portability (in certain specific circumstances);
—Right to withdraw consent (in certain specific circumstances); and
—Right to receive information regarding any entities we disclose your data to.

Where Cadarn or its Service Provider(s) requires your personal information to comply with AML or other legal requirements, failure to provide this information means Cadarn will not be able to accept you as a client or investor.

Cadarn shall notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.‍

Changes To This Notice

Cadarn will need to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the Cadarn website ‍

How To Contact Cadarn

Under the GDPR, data subjects can make a complaint to the supervisory authority
including the Member State in which they reside or work or the place of the alleged
infringement.

If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how Cadarn has processed your personal data, please contact Cadarn by writing to info@cadarncapital.com.

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Disclaimer

It is the responsibility of the individual user to consider his or her legal and regulatory position in the relevant jurisdiction, the risks associated with trading such products and to ensure that the use of the content and the subsequent making of any investment does not contravene any such restrictions or applicable laws and regulations of any jurisdiction. Please seek the advice of professionals, as appropriate, regarding the evaluation of any specific security, index, report, opinion, advice or other content. This does not exclude or restrict any duty or liability that Cadarn Capital Ltd has to its clients under the Financial Services and Markets Act 2000 (as amended from time to time) or any other regulatory system under the laws of applicable jurisdictions.

Cadarn Capital Ltd, its subsidiaries, associated entities, partners, employees, representatives or suppliers will not be liable, on any grounds whatsoever, contractually or not, for any direct or indirect damage that may arise as the result of it being possible or impossible to gain access to this site, the accessing, visiting or use of this site and/or the information provided, the sending, or receiving of information via this site and/or the operation or non-operation of this site, except in the event of intentional or serious blame on its part. The information contained on this site, including any third party data is published in good faith and Cadarn Capital Ltd believes that the information is accurate at the time of publication but no representation or warranty, express or implied, is made by Cadarn Capital Ltd as to its accuracy or completeness and it should not be relied on as such.

Cadarn Capital Ltd shall therefore have no liability, save for any liability that Cadarn Capital Ltd may have under the UK Financial Services and Markets Act 2000, for any loss or damage arising out of the use or reliance on the information provided including without limitation, any loss of profit or any other damage, direct or consequential. Nor will Cadarn Capital Ltd, its subsidiaries, associated entities, partners, employees, representatives or suppliers be, under any circumstances, liable for any corruption of data that may occur as the result of technical problems (e.g. transmission errors, technical failures, breakdowns, intervention of third parties, etc.) and/or for any damage or loss relating to software or hardware that is the result of any virus, defect or malfunction in relation to access or use of the site.

Cadarn Capital Ltd is directed at persons who fall within the definition of ‘professional clients’ or ‘eligible counterparties’ as defined in the rules of the Financial Conduct Authority (“FCA”) of the United Kingdom.

The information on this website is provided for information only and does not constitute, and should not be construed as, tax, financial, investment, or legal advice given by the Cadarn Capital to any party; and it is not an offer, contract, guarantee, or solicitation for the purchase or sale of any financial or investment product.

I certify that I am not a US person. Cadarn Capital Ltd is not registered as an investment advisor with the SEC and therefore this document is neither directed at nor intended for US investors.

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