1. Introduction

This is the privacy policy (the “Privacy Policy”) of Sorair Technologies Ltd (“Sorair”, “we”, “us”). We have our registered office at R27, Atlas Centre, Fermi Avenue, ESA BIC, Didcot, Harwell Oxford, OX11 0QX, United Kingdom.

In the context of our activities, we collect, hold, use and further process personal data of various individuals who are involved with our business activities. Pursuant to applicable data protection and privacy legislation, we qualify as the controller with respect to such personal data.

This policy is intended to ensure compliance with the relevant privacy regulations, including without limitation the General Data Protection Regulation.

2. We highly value data protection and privacy

We recognize the importance of data protection and privacy and, hence, strive to protect the personal data we process in accordance with applicable data protection legislation and more specifically with the General Data Protection Regulation and relevant national (implementing) legislation.

In this Privacy Policy we set forth how we collect personal data, for what purposes we may use personal data and to whom personal data may be disclosed by us. Further, this Privacy Policy includes important information regarding the rights of the individuals whose personal data we process (each a data subject). In view hereof, we encourage data subjects to carefully read this Privacy Policy.

From time to time, we may need to update this Privacy Policy. The most recent version of this Privacy Policy is available on our website.

NOTE: Where you provide personal data to us, which personal data relate to another individual than yourself (for example, when you send us a copy of a colleague’s passport), please ensure that this individual is aware thereof and is referred to this Privacy Policy on our website prior to providing us with his/her personal data. It is our obligation to ensure that all individuals whose personal data we process are aware of and understand the information in this Privacy Policy. However, in certain cases, we do not have any direct contact with such individuals for which reason we rely on you to provide the information on our behalf (for example, generally we do not have direct contact with ultimate beneficial owners of investors that committed to one or more funds we manage, but we do require to process their personal data).

NOTE: Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. Whose personal data do we collect and how?

We may collect the following data:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.

• Contact Data includes name, address (if needed), email address and telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Profile Data includes (if applicable) your username and password, profile picture, reviews made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our platform and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

In the context of our activities, we may collect and process the above mentioned personal data of the following data subjects:

• contact persons of our current, prospective and former clients and (co-)investors

• directors, officers, proxyholders and other authorized representatives of current, former and prospective institutional investors and their ultimate beneficial owners

• Sorair directors, officers, authorized representatives of relationship general partners and co- investors

We may collect personal data relating to these data subjects in various ways:

• directly from the data subject (e.g. pursuant to a subscription agreement or by receipt of an email or business card);

• indirectly from other sources (e.g. from public records or from a counterparty in possession of the data).

4. Personal data

Personal data is information that can be used to identify you, such as your name, address, email address, telephone number, and date of birth. Personal data also includes your bank account details, IP address and IDs. We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Other data, including your religion, ethnicity, or membership in a trade union, is considered special data. We may only use categories of special data if permitted by law or if consent for this specific processing is obtained. In all other situations, we are prohibited from using this special personal data.

5. Legal basis for processing

Processing of personal data is only allowed when it is based on one of the “grounds” permitted bylaw.

We only use your personal data when it is necessary for one or more of the following reasons:

• To perform a contract with you

• To comply with a legal obligation

• For a legitimate interest of Sorair (or those of a third party) and your interests and fundamental rights do not override those interests.

• Because you give your consent for a specific purpose

IF YOU FAIL TO PROVIDE PERSONAL DATA:

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).

6. Purposes for which we use your personal data

We use your personal data for the legitimate interests of Sorair or a third party (such as our affiliates), to help make our operations, business development and services as effective, reliable and efficient as possible as well as to comply with our legal and regulatory requirements.

This is done for one or more of the following purposes, depending on the nature of your relationship with us:

• to evaluate potential investment opportunities or potential employees or interns or business partners or service providers.

• to evaluate new clients and (co-)investors and to investigate, assess and advise on the feasibility of our clients’ objectives.

• to handle complaints and queries relating to our services and to handle any disputes that may arise.

• to negotiate and execute agreements, carry out the agreement entered into by and between Sorairs and our contracting party and to contact and communicate with our contracting parties.

• to maintain a database in which all service providers engaged by Sorair are recorded in order to create a network and to know who to contact in a certain situation.

• to comply with legal obligations, for example to comply with our obligations regarding know-your- client and anti-money laundering.

• for marketing purposes, to inform our clients and (co-)investors about Sorair and our services, to invite persons to attend events and meetings (and keep record of attendees) and for general communication purposes.

• to negotiate and execute agreements with our clients and (co-) investors, for example to provide the requested services to our clients and (co-)investors, in order to contact our clients and (co-)investors for updates on matters regarding to the investments of our clients and (co-)investors (for example to send our clients and (co-)investors reports regarding returns on investments) and other activities relating to client management, financial management and administration

• Staying in contact with current and potential members of our community;

• Evaluating potential investment opportunities or potential employees or interns or business partners or service providers;

• Sending invoices;

• Providing requested services or information;

• Providing investors with information about their investment;

• Verifying investors’ identities in order to accept and maintain their investments;

• Verifying information about potential investments;

• Investigating complaints;

• Complying with tax and regulatory requirements;

• Complying with anti-money laundering, anti-corruption, and other financial laws.

7. With whom do we share your personal data?

Sorair may share certain of the aforementioned personal data with third parties, such as group companies of Sorair, investment vehicles to which Sorair (envisages to) makes any capital commitment, our clients and (co-)investors, (regulatory) authorities (such as tax authorities, financial intelligence units and supervisory authorities), and third parties that provide services to Sorair (such as trusted advisors, consultants and other service providers that may require personal data to render their services to Sorair). We will only share your personal data with these parties if such is necessary for the purposes as listed above.

We also may share your personal data with internal third parties, external third parties and 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 privacy policy.

In the context of the processing activities as described above, we may also engage third parties to process the personal data on our behalf (for example providers of certain IT applications that we use in the context of our activities). We will enter into the required contractual arrangements with those parties to ensure lawful and fair processing of your personal data on our behalf. 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.

Some of the parties with whom we may share your personal data will be located in countries outside the European Economic Area, which countries may offer a lower level of data protection than the United Kingdom. In such case, Sorair shall ensure that the international transfer of your personal data shall comply with the applicable data protection laws.

8. How do we protect your personal data?

We have implemented the necessary administrative, technical and organizational measures to ensure a level of security appropriate to the specific risks that we have identified in relation to the processing of personal data. We protect your personal data against destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Further, we seek to ensure that we keep your personal data accurate and up to date. However, you are responsible for this and we kindly request that you inform us of any changes to your personal data (such as a change in your contact details).

9. How long do we keep your personal data?

Your personal data will not be kept by Sorair for longer than necessary in relation to the purposes for which we collect and use the personal data (we refer to the purposes as set forth above). Sorair will retain your personal data in accordance with our recording policy. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you have any specific question in this respect, please feel free to contact us.

10. What are your rights and who may you contact if you have further questions?

Under certain circumstances, you may:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Have the right to withdraw consent

To exercise these rights, or in case of questions on how we collect and use personal data, please contact us at Kunmi@sorair.co.uk.