Privacy Notice

This privacy notice (“Notice”) is provided by Daniel Global Asset Management Ltd and the other entities listed in Schedule 1. Throughout this Notice, all references to “Daniel Global Asset Management Ltd”, “DGAM”, “we”, “us” or “our” refer to Daniel Global Asset Management Ltd and its direct and indirect affiliated entities from time to time.

General

We are committed to safeguarding Personal Data, meaning information relating to a living individual who can be identified from that information. Personal Data is handled in accordance with applicable Data Protection Legislation, including laws governing the processing of Personal Data and privacy.

We will generally process your Personal Data as a data controller, as defined under applicable Data Protection Legislation.

This Notice explains how we collect, use and protect Personal Data when you:

• Visit our website (the “Site”);
• Inquire about or use services associated with our business made available through the Site (the “Services”);
• Express interest in our business;
• Are employed by, or otherwise connected to, our suppliers or business partners;
• Are related or otherwise connected to our staff, such as when nominated as an emergency contact;
• Apply for a job or work experience with Daniel Global Asset Management Ltd; or
• Visit our corporate offices globally.

This Notice also applies to any other Personal Data you provide to us or that we obtain through our day-to-day business activities.

Where you are seeking specific information about how we process Personal Data relating to:

• Investors or former investors, please refer to the privacy notice available through the DGAM Investor Portal; or
• Employees and contractors, please refer to the applicable internal employee privacy notice.

Scope of This Notice

This Notice describes, among other things:

• The types of Personal Data we collect;
• The purposes for which we process Personal Data;
• The circumstances under which we disclose Personal Data;
• The security measures applied to protect Personal Data;
• Your rights as a data subject; and
• How to contact us to exercise those rights.

Where the processing of Personal Data is necessary to provide requested Services, failure to provide such data may prevent us from delivering those Services or responding to your inquiries.

We may update this Notice from time to time. Any changes will be posted on the Site and will become effective upon posting. Continued use of the Site or Services following the publication of an updated Notice will be subject to the revised terms.

Types of Personal Data We Collect

We may collect or receive the following categories of Personal Data:

Contact Information

Full name, email address and telephone number.

Sources may include information provided directly by you, your employer, our business partners or our staff where relevant.

Audio and Visual Data

This may include recorded telephone calls where recording is legally required or otherwise permitted.

Sources may include your direct interactions with us.

Technical and Usage Information

This may include your IP address, device identifiers, browser information, browsing history, clickstream data and referral URLs.

This information may be generated automatically through cookies and similar technologies.

Preferences and Communications

This may include marketing preferences, feedback, comments and content submitted through the Site or Services.

Recruitment Data

This may include CVs, application materials, interview notes, qualifications, references, work authorization information and, where legally permitted or required, criminal background information or health information relating to reasonable workplace adjustments.

Where Personal Data is provided on behalf of another individual, you confirm that you have informed that individual of this Notice and are authorized to provide their information to us.

Purposes of Processing

We may process Personal Data for purposes including:

• Operating and maintaining the Site and Services;
• Communicating with you and responding to inquiries;
• Conducting business analytics, compliance reviews, audits and internal record keeping;
• Maintaining security, preventing fraud and protecting system integrity;
• Managing recruitment and talent assessment;
• Complying with legal, regulatory and contractual obligations;
• Supporting corporate transactions, including mergers, acquisitions or restructuring; and
• Sending marketing communications where legally permitted.

Daniel Global Asset Management Ltd does not sell Personal Data.

Lawful Basis for Processing

We process Personal Data on one or more of the following legal bases:

• Our legitimate interests or those of a third party;
• Your consent, where required;
• Compliance with legal or regulatory obligations;
• Performance of a contract or steps taken before entering into a contract;
• Protection of vital interests; or
• Performance of a task carried out in the public interest, where applicable.

Special category Personal Data is processed only where legally permitted and where appropriate safeguards are in place.

Data Retention

Personal Data is retained only for as long as reasonably necessary, taking into account:

• The duration of our relationship with you;
• Applicable legal and regulatory retention requirements;
• Limitation periods relating to potential legal claims; and
• Legitimate operational and business requirements.

Data Security

We apply appropriate technical, physical and organizational safeguards designed to protect Personal Data against unauthorized access, disclosure, alteration, loss or misuse.

Although we follow recognized security practices, no method of electronic transmission or storage is completely secure. We therefore cannot guarantee the absolute security of Personal Data.

Cookies and Similar Technologies

We use cookies and similar technologies to operate the Site, improve performance, remember preferences and analyze how visitors use the Site.

Non-essential cookies are used only where legally permitted and, where required, after obtaining your consent.

For more information, please refer to our Cookie Notice.

International Transfers

Personal Data may be transferred to, stored in or processed in countries outside the jurisdiction in which it was originally collected.

Where required, we implement appropriate safeguards, which may include:

• Adequacy decisions;
• Standard Contractual Clauses;
• Transfer risk assessments; and
• Other legally recognized or comparable protections.

Your Rights

Depending on your jurisdiction and subject to applicable legal limitations, you may have the right to:

• Request access to your Personal Data;
• Request correction or rectification of inaccurate Personal Data;
• Request deletion or erasure of Personal Data;
• Request restriction of processing;
• Object to certain processing activities;
• Request data portability;
• Withdraw consent at any time where processing is based on consent; and
• Lodge a complaint with an applicable supervisory authority.

Contact Us

To exercise your rights or submit a privacy-related inquiry, please contact:

Daniel Global Asset Management Ltd
Email: [Insert Privacy Email Address]
Address: [Insert Registered or Business Address]
Telephone: [Insert Telephone Number]

Supplemental Privacy Notice for California Residents

This section applies where the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to our processing activities.

We do not sell Personal Data or share Personal Data for cross-context behavioral advertising.

Subject to applicable law, California residents may have additional rights, including:

• The right to know and access;
• The right to correction;
• The right to deletion;
• The right to limit certain uses of sensitive Personal Data; and
• The right not to receive discriminatory treatment for exercising their privacy rights.

Requests may be submitted using the contact details above. We may take reasonable steps to verify your identity before processing a request, as required by law.

Accessibility

Alternative formats of this Notice are available upon request. Please contact us using the details provided above.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our operations, legal requirements or data-processing practices. The updated version will be published on the Site.

Last updated: July 2024