Privacy Policy

Insaaph Capital Proprietary Limited and Consilience 1010 Limited (collectively, "Insaaph", "We", "Our"), respect your concerns about privacy. This privacy policy (the "Privacy Policy") describes the types of personal information we obtain, how we use the information, with whom we share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. For the purposes of EU, and UK data protection laws, Insaaph Capital Proprietary Limited is a data controller of your personal information.

This Privacy Policy applies to the privacy practices of Insaaph with respect to its processing of personal information online through the Website and mobile applications listed in Appendix A of this Privacy Policy (collectively, the "Sites"), as well as our offline privacy practices (unless they are specifically covered by a separate privacy policy).

We may obtain information about you in various ways, such as through our Sites, subscription documents and other documents and forms we receive from you or on your behalf.

We will collect and process the following data about you. This is information about you that you give us by filling in forms on the Sites or by corresponding with us by phone, e-mail or otherwise. The information you give us may include:

• Your name
• Address
• E-mail address
• Phone number
• Financial and credit card information
• Personal description and photographic images we collect from you
• Information used to create your online account (such as username and password)
• Information about your transactions with us, our funds or our affiliates
• Other personal information you provide to us, such as through emails, subscription documents and other onboarding documents
• Technical information, including IP address, browser type, time zone setting, operating system and platform
• Information about your visit, including URLs, click stream data, page response times, and page interaction information
• Information we receive from other sources including business partners and analytics providers

If you are a candidate applying for a position with Insaaph, we may collect additional personal information including national identification numbers, employment and education history, and results of background checks to the extent permitted by applicable law.

When you visit our Sites, open our emails or interact with Insaaph-related tools, widgets or plug-ins, we may obtain certain information by automated means, such as through cookies, web server logs, web beacons and JavaScript.

The information we obtain in this manner may include IP addresses, unique device identifiers, browser and operating system characteristics, device characteristics, language preferences, clickstream data, referring/exit URLs, information on actions taken, dates and times of activity and other technical information.

These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products, services and Sites; (3) tailor our products, services and Sites around your preferences; (4) measure the usability of our products, services and Sites and the effectiveness of our communications; and (5) otherwise manage and enhance our products, services and Sites.

Information about our cookie practices is available in our Cookies Policy. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

When you use the Sites, we may collect personal information about your online activities, over time and across third-party websites, to provide you with advertising about products and services tailored to your interests. Where required by applicable law, we will obtain your consent to the processing of your personal information for direct marketing purposes.

You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users considering demographic data, users' inferred interests and browsing context.

We use information held about you in the following ways:

• To carry out our obligations arising from any contracts entered into between you and us
• To comply with applicable laws and legislation
• To provide you with information about other goods and services we offer
• To notify you about changes to our service
• To create, manage and administer accounts you hold with us
• To verify your identity and conduct identity and background checks for anti-money laundering (AML) purposes
• To manage career opportunities, including recruitment purposes
• To ensure that content from our site is presented in the most effective manner for you

We will use this information:

• To administer our site and for internal operations
• To comply with applicable laws and legislation
• To improve our site to ensure content is presented effectively
• To allow you to participate in interactive features of our service
• As part of our efforts to keep our site safe and secure
• To measure advertising effectiveness
• For auditing, billing and reconciliation activities
• To protect against fraud and other unlawful activity
• To make suggestions and recommendations to you about goods or services

We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

As a general matter, we use the personal information we obtain to comply with applicable legal requirements, carry out our contractual obligations and pursue our legitimate interests (such as managing our Sites and client relationships). Where required by applicable law, we obtain consent to process personal information.

We do not sell or otherwise share personal information about you, except as described in this Privacy Policy. We share your personal information with members of our group for the purposes identified in this Privacy Policy.

Personal information shall be disclosed, to the extent necessary, 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 of the Website and other agreements; or to protect the rights, property, or safety of the Insaaph Capital Team, our customers, or others.

When you provide personal information to Insaaph you are providing it to an entity which is not located in the European Economic Area ("EEA"). We may transfer the personal information we obtain about you to recipients in countries other than the country in which the information originally was collected.

If you are located in the EEA or UK, we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of personal information to recipients in countries for which an adequacy decision has not been issued.

We offer you certain choices in connection with the personal information we obtain about you. In certain circumstances and to the extent permitted by law, you may have the following rights:

• Access - To request a copy of the personal information we process in relation to you
• Object - To object to the processing of your personal information
• Correction - To request that we update or correct your personal information
• Erasure - To ask that we delete personal information we process in relation to you
• Restriction - To request that we restrict how we process your personal information
• Portability - To request a copy of your personal information in a commonly used electronic format
• Automated decision making - To request manual intervention if you are subject to automated decisions

Depending on your location, you may have the right to file a complaint with a data protection authority if you are not satisfied with our response.

Our Sites may provide links to other websites, apps and features. These websites, apps and features may operate independently from us and may have their own privacy policies. To the extent that any website, app or feature is not owned or controlled by us, we are not responsible for the content or privacy practices.

We maintain administrative, technical, organisational and physical safeguards which are designed to protect the personal information we obtain against unauthorised or unlawful use, disclosure, access, loss, destruction or damage.

The safeguards we employ include, where appropriate, pseudonymisation and encryption, and the maintenance of plans and procedures to restore access and availability to personal information in a timely manner.

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.

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our privacy practices. We will indicate in this Privacy Policy when it was most recently updated.

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us.

This Privacy Policy applies to Insaaph online processing of personal information through the following websites and mobile apps:

• insaaphcapital.com (website application)
• app.insaaphcapital.com (mobile and in-browser application)