QALORA PRIVACY POLICY

1. GENERAL

1.1 Privacy and data protection is important to us at Qalora Capital AB, reg. no 559016-3183 (“Qalora”, “we”, “us” or “our”). This privacy policy (“Privacy Policy”) aims to inform you about our processing of your personal data, and what rights you have as a data subject. Qalora’s processing of personal data is carried out in accordance with applicable legislation, including the general data protection regulation (“GDPR”).

1.2 This Privacy Policy applies to the personal data we may process in connection with customer engagements, business contacts and recruitments.

1.3 Set forth below is a description of how we process your personal data, and if you wish to receive additional information on the processing of your personal data, you are welcome to contact us at: [email protected]

2. PERSONAL DATA WE PROCESS

2.1 Personal data refers to information which, directly or indirectly, may be associated with a living natural person. We process the following types of personal data: (i) name, (ii) e-mail address, (iii) address, (iv) website and social media profile, (v) phone number, (vi) investment history and (vii) investment preferences.

2.2 We process personal data about persons who:

2.2.1 are customers of Qalora or enter a business or legal relationship with Qalora;

2.2.2 are representatives and/or employees of customers, business partners, potential customers or potential business partners of Qalora;

2.2.3 are employees of Qalora or applies for jobs at Qalora;

are otherwise affected by our services; or

receives our newsletters, other communication and/or attend our events.

2.3 The personal data that Qalora processes is either provided by you directly, the company which you represent or by a company which you have engaged and which uses our services. We may also collect personal data from private and public registers, publicly accessible sources as well as from public authorities if necessary.

3. PURPOSE FOR THE PROCESSING

3.1 We process personal data for the purposes of:

3.1.1 administrating and performing our services in accordance with agreements with our customers and other business partners;

3.1.2 communicating with you in order to administrating and performing our services;

3.1.3 evaluating and improving our services and systems;

3.1.4 managing customer relationships and entering business or legal relationships;

3.1.5 recruiting staff, including administrating and performing agreements with employees;

3.1.6 sending newsletters, information, offers and marketing of our services;

3.1.7 fulfilling our legal obligations, strive to prevent crime and safeguarding our interests in a dispute; and

3.1.8 administrating and performing an acquisition, reconstruction or similar of Qalora.

4. LEGAL BASIS

4.1 We process personal data in accordance with this Privacy Policy (i) in order to fulfill our obligations in accordance with an agreement with you (or with the company which you represent), (ii) in order to fulfil legal obligations pursuant to applicable legislation, (iii) if we have a legitimate interest to process the personal data, and/or (iv) if we have your consent to process your personal data.

4.2 If we process your personal data for any specific purpose which requires your consent under the GDPR, or any other data protection legislation, we will obtain your consent in advance.

4.3 If we process your personal data for any specific purpose upon which we have a legitimate interest to process the personal data we always prior thereto and in each individual case conduct an assessment of interests in order to for example evaluate whether our interest is overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data in accordance with GDPR. We only process personal data based on our legitimate interest if we make the assessment that our legitimate interest is not overridden by the interests and rights of the relevant data subject. You as a data subject have a right, at any time, to object to processing based on our legitimate interest in accordance with section 7.2.8 below.

4.4 If Qalora is the target in connection with a merger, acquisition, reorganization, asset transfer (including our customer database) or similar process, your personal data may, to the extent necessary for the purpose, be transferred to a third party involved with us in such process, provided however that such third party conducts similar activities as Qalora. The legal basis for such processing of your personal data is our legitimate interest to facilitate such process, provided however that we prior thereto have assessed that our interest to do so is overridden by your legitimate interests under GDPR. If your personal data is transferred to a third party in connection with an asset transfer (including our customer database), the relevant third party shall continue the processing of your personal for the same purposes and in the same way as described in this Privacy Policy unless otherwise is specifically announced to you in connection with such transfer of your personal data.

4.5 In order for us to provide direct marketing of our services to potential company customers or business partners for which you act as a representative, we may process personal data of representatives of such businesses, which we may collect from publicly accessible sources. The legal basis for such processing of your personal data is our legitimate interest to market our services, provided however that we prior thereto have assessed that our interest to do so is overridden by your legitimate interests under GDPR. You have the right at any time to object to direct marketing and processing for such purpose (your rights as a data subject are specified in section 6 below).

5. SECURITY MEASURES; EXTERNAL PARTIES ETC.

Personal data will always be processed confidentially and protected by appropriate security measures. Qalora ensures that companies that process and/or manage personal data on our behalf, use a high level of security measures in order to protect your personal data. However please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk. You are responsible for keeping any passwords you use to access our platforms safe.

5.2 We may disclose your personal data to external parties with whom we collaborate in order to perform our service and/or conduct our business e.g. licensors, marketing agencies, e-mail service providers and database and website service providers, etc. We may also disclose your personal data when we have a legal obligation to do so, e.g. due to anti-money laundering legislation, tax legislation, court orders or requests from government authorities.

5.3 We may transfer and store personal data in countries outside the EU/EEA in order to perform our services and/or conduct our business. When Qalora transfers personal data to such countries, we will take reasonable legal, technical and organizational measures to ensure that your personal data is adequately protected, at the same level as it would have been within EU/EES, through the use of relevant safeguards. For the avoidance of doubt, such transfer as referred to herein, if applicable, will only include the type of personal data relevant for the purpose of the processing.

6. STORAGE AND DELETION OF PERSONAL DATA

6.1 Personal data will only be stored for a limited period of time and no longer than necessary in order for us to fulfil the purposes of the processing, or for as long as we are required to store the information according to applicable legislation and relevant guidelines. This will depend on a number of factors, including for example (i) the laws and regulations that we are required to follow, (ii) whether we are in a legal or other type of dispute with each other or a third party, (iii) the type of information that we hold about you, (vi) whether we are asked by you or a regulatory authority to keep your personal data for a valid reason. If processing of your personal data is no longer necessary, it will be erased in accordance with our erasure procedure.

6.2 If Qalora is subject to liquidation or bankruptcy or if Qalora’s customer database is transferred in accordance with section 4.2 above, Qalora shall thereafter erase your personal data, provided however that we are not required to store the information according to applicable legislation and relevant guidelines. If Qalora is subject to a merger, acquisition, reorganization or similar process, we will continue the processing of your personal data pursuant to this Privacy Policy unless otherwise is specifically announced to you in connection with such process.

6.3 If we are processing your personal data for direct marketing purposes with legitimate interest as legal ground in accordance with section 4.3 above, we will not store your personal data for longer than one (1) month before informing you about our processing of your data. You as a data subject have the right, at any time, to object to such processing of your personal data, after which we shall cease the direct marketing to you as well as the processing of your personal data for that purpose.

6.4 You may unsubscribe from our newsletters or similar communication at any time. In such event we will no longer store or process your personal data for such purposes.

7. YOUR RIGHTS AS A DATA SUBJECT

7.1 Qalora is the controller for the processing of your personal data, and as a data subject you have certain rights as regards your personal data. The rights are however not absolute, meaning that there are exceptions to some of the rights where we cannot proceed and fulfill your request.

7.2 As a data subject, you have the following rights:

7.2.1 Right to withdraw your consent – meaning that you have the right to withdraw your consent where Qalora process your personal data based on consent;

7.2.2 Right to access – meaning that you have the right to request a confirmation of our processing of your personal data, to receive information about the processing, access the personal data in question, and the right to obtain a copy of your personal data;

7.2.3 Right to rectification – meaning that you have the right to have any incorrect personal data about you as a data subject corrected by us;

7.2.4 Right to erasure – meaning that you have the right to have your personal data erased under certain circumstances. This right is limited, and we may be obligated to save your personal data in accordance with applicable law;

7.2.5 Right to object – meaning that you have the right to object to Qalora’s processing of your personal data under certain circumstances;

7.2.6 Right to restricted processing – meaning that you have the right to have Qalora restrict the processing of your personal data, but not delete it;

7.2.7 Right to data portability – meaning that you may request Qalora to transfer your personal data to another data controller; and

7.2.8 Right to object processing based on legitimate interest – meaning that you have the right at any time to object to Qalora’s processing of your personal data processed by us if we base such processing on our legitimate interest to do so.

7.3 If you feel that our processing of your personal data does not comply with applicable data protection legislation, you are entitled to lodge a complaint with the Swedish Data Protection Authority (Sw. Datainspektionen).

7.4 Any requests by you as a data subject under this Privacy Policy shall be sent to us at: [email protected] Requests will be handled as soon as possible, but no later than within one (1) month from the date which Qalora received the request.

8. LINKS TO THIRD PARTY SITES

Our website may contain links to third party sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by Qalora and, therefore, we strongly advise you to review the privacy policy of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

9. AMENDMENTS AND ADDITIONS

Qalora has the right to amend this Privacy Policy from time to time without giving prior notice to such change. Should any change affect the processing of personal data, which is based on your consent, Qalora shall collect a new consent from you regarding such processing. The latest version will always be available on Qalora’s website: https://www.qalora.com, and we advise you to review this Privacy Policy periodically for any changes.

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