1. This data protection information applies to data processing by:

CAM Alternatives GmbH
Gereonshof 12
50670 Cologne
Germany
Telephone +49 221 937085 0
Telefax +49 221 937085 19
Email: cgn.info@altamarcam.com

Data Protection Officer:

Jochen Geck
Telephone: +49 (0) 6172 68755 03
Telefax: +49 (0) 6172 68755 10
Email: cgn.dataprotection@altamarcam.com

2. Collection and saving of personal data as well as type and purpose of their use

Visiting our website: When you visit our website www.altamarcam.com, the browser on your device automatically sends information to the server on our website. This information is temporarily stored in a so-called log file.

The following information is recorded without your doing and stored until it is automatically deleted:

• IP address of the requesting computer,
• Date and time of access,
• Name and URL of the retrieved file,
• Website from which access is made (referrer URL),
• the browser used and, if applicable, the operating system of your computer as well as the name of your access provider.

The mentioned data will be processed by us for the following purposes:

• Ensuring a smooth connection of the website,
• Ensure comfortable use of our website,
• evaluation of system security and stability and
• for other administrative purposes.

Investor Portal: Investors can access investor information via CAM’s investor portal hosted by a third-party provider (e.g. Intralinks, Sungard).

The main purposes of the data processing carried out by CAM include those necessary to execute the specific agreements reached, as well as to comply with the legal and fiscal obligations that may arise from the relationship with CAM. CAM will only transfer investor’ personal data between AltamarCAM Group companies for commercial purposes, when it has the consent of its investors.

The AltamarCAM Group companies includes the following companies:

• CAM Alternatives GmbH
• Altamar Credit, S.L.
• Altamar Real Estate, S.L.
• Altamar Capital SGIIC, S.A.U.
• Altamar Alternative Asset Management, S.L.
• Altamar Alquileres Inmobiliarios, S.L.
• Altamar Private Equity SGIIC, S.A.U.
• Altamar Infraestructuras S.L.
• Altamar Advisory Partners, S.L.
• Altamar Global Investments, S.A.
• Altamar Fund Services, S.L.
• Altamar Capital Partners, S.L.
• Altan Real Estate, S.L.
• Altan Capital, SGIIC, S.A.U.
• Galdana Ventures, S.L.
• Altamar Partners Luxembourg, S.A.R.L.
• Galdana Partners Luxembourg, S.A.R.L.

CAM has identified all the data processing it carries out and has adopted the necessary security measures to prevent any loss and incidents in accordance with the provisions of the data protection regulations.

CAM undertakes to ensure that all communications of personal data are considered confidential. However, depending on the product contracted, different entities may be assignees of personal data. Among others: (i) where applicable, the depositary entities of the funds contracted, (ii) regulatory bodies and public institutions that may be located within or outside the European Economic Area, to which it is legally obliged to provide them, (iii) entities of the AltamarCAM Group, or (iv) service providers such as IT, administration or advisory services.

CAM is providing its clients with detailed information on data protection via its investor portals (as mentioned above) or on an individual basis.

For the Altamar entities you can find detailed information on data protection using the following links:

• Altamar Private Equity Data Protection Policy (https://www.altamarcapital.com/en/data-protection-policy-private-equity),
• Altamar Global Investments Data Protection Policy (https://www.altamarcapital.com/download/Politica-de-proteccion-de-datos-Clientes-Agencia-Valores-13-12-2019_EN.pdf) and
• Altamar Advisory Partners Data Protection Policy (https://www.altamarcapital.com/wp-content/uploads/2019/04/Data Protection Policy for Altamar Advisory Partners.pdf).

CAM reserves the right to unilaterally modify its privacy policy, always in accordance with current legislation, without affecting the processing of your data. Interested parties will be informed immediately of the change so that they can exercise the rights they consider appropriate.

3. Transfer of data
   

We do not transfer your personal data to third parties for purposes other than those listed below. We will only disclose your personal data to third parties if:

• you have given your express consent to this in accordance with Art. 6 (1) p. 1 lit. a GDPR,
• the disclosure is necessary in accordance with Art. 6 (1) p. 1 lit. f GDPR for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data
• in the event that there is a legal obligation for disclosure pursuant to Art. 6 (1) p. 1 lit. c GDPR, as well as
• this is legally permissible and necessary according to Art. 6 para. 1 p. 1 lit. b GDPR for the processing of contractual relationships with you.

4. Cookies
   

We use cookies on our site. These are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site. Cookies do not do any damage to your end device, do not contain viruses, Trojans or other malware. Information is stored in the cookie that results in each case in connection with the specifically used terminal device. However, this does not mean that we immediately become aware of your identity.

Cookies provide information about the use of a website. The main purpose of our cookies is to improve your experience on our website. For example, cookies help us to identify you and remember your preferences while you are browsing. The information collected in the cookies also allows us to improve our website by analyzing the routes users use to access our website.

Types of cookies used by CAM:

Cookies we use on our website are technical cookies only:

– Technical cookies: The use of technical cookies is intended on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These will be deleted automatically after leaving our site.

In addition, we also use temporary cookies that are stored on your end device for a specified period of time to optimize user-friendliness. If you visit our site again to use our services, it will automatically recognize that you have already been here and what entries and settings you have made so that you do not have to enter them again.

These are the website’s own cookies that are essential for the proper functioning of the Website and are stored for technical reasons and for purposes of personalization (they allow the user to access the Website with some general pre-defined characteristics, such as the language selected, they identify the user’s browser connection, control data communication and maintain user safety in navigation), and they also allow use of the various services the website provides. If the user disables cookies of this type by adjusting the browser settings, it will no longer be possible to continue navigating at the Website.

Control and management of Cookies:

At any time, you can retract the consent to the installation of cookies that you have given by deleting the cookies along with the above indications or by installing a rejection system in your web browser. You can configure your browser so that no cookies are stored on your computer, or a notice appears each time before a new cookie is created.

Depending on the specific browser being used, the procedure for rejecting and deleting cookies will be one of the following:

• Google Chrome: https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DDesktop&hl=en
• Firefox: https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-sitios-web-rastrear-preferencias
• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari: https://support.apple.com/en-us/guide/safari/sfri11471/mac

The web browsers are the tools in charge of storing the Cookies and from this place you must make your right to delete or disable them. This Website cannot guarantee the correct or incorrect handling of cookies by the above-mentioned browsers.

5. Embedding Google Services

Google Maps: We use the services of Google Maps on our site. This gives you convenient access to interactive maps. Google Maps is a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter only called “Google”.

When you visit our website, Google receives information, such as a visit to the corresponding subpage of our homepage. This is even if there is no Google Account and regardless of whether you are logged in to a Google Account. When you are logged in, the data will be assigned to your user account. If you do not wish to be associated with your profile on Google, you must log out before activating the button. Google stores your data as usage profiles and uses them for its own purposes. You can find the Google Maps Terms of Use under “Google Maps Terms of Use. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right.

Google Fonts: We also use Google Fonts to display external fonts on our website. The Google Fonts are installed locally. A connection to Google servers does not take place.

CAM cannot control and is not responsible for the content or accuracy of Google’s terms and conditions or privacy policies referenced in this Cookie Policy.

Further information and the possibility to prevent the use of data can be found at Google:

The third-party cookies used belong to Google located in the USA, so their data processing involves an international transfer of data to a country that does not have a level of protection comparable to the European one. However, Google complies with the appropriate safeguards set out in the General Data Protection Regulation. Specifically, it has standard contractual clauses which can be accessed at these links:

6. Rights of the persons concerned

You have the right:

• to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you may request information about the purposes of processing, the category of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of your data, if these have not been collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information on their details;
• to immediately request the correction of incorrect or complete personal data stored by us in accordance with Art. 16 GDPR;
• to request the deletion of your personal data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
• pursuant to Art. 18 GDPR, to restrict the processing of your personal data if you dispute the accuracy of the data, if the processing is unlawful but you refuse to delete the data and we no longer need the data, but if you need it to assert, exercise or defend legal claims or if you have filed an objection to the processing pursuant to Art. 21 GDPR;
• you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are reasons for this which arise from your particular situation or the objection to direct advertising is directed. In the latter case, you have a general right of objection, which we will implement without specifying a particular situation.
• pursuant to Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, current and machine-readable format or to request its transfer to another person responsible;
• in accordance with Art. 7 para. 3 GDPR, to revoke your consent to us at any time. As a result, we are no longer allowed to continue processing data based on this consent in the future and
• to complain to a supervisory authority pursuant to Art. 77 GDPR. In general, you can contact the supervisory authority of your usual place of residence or workplace or our office.

If you wish to exercise your right of revocation or objection, simply send an e-mail to cgn.dataprotection@altamarcam.com

7. Term of data storage

We are saving personal data only as long as it is required and feasible by law according to the purpose(s) we had collected it for.

• Data storage period for Cookies:

_ga: (Consent-based analysis cookies). It is used to track users and it lasts 2 years

_gat: Analysis cookie that is used to limit the analysis requests sent from the browser to Google services. It lasts 10 minutes

_gid: (Consent-based analysis cookies). It is used to group user behavior and it lasts 24 hours.

The term of data storage with regard to the data contained in the Investor Portal is among other things determined by:

• legal obligations we are liable to (e.g. it is required by law that we save and archive the documentation of certain transactions for a certain period of time before we can delete it) or
• the legal circumstances we are in, requiring data availability due to existing statutory limitations, litigations or regulatory investigations.

8. Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are being continuously improved in line with technological developments.

9. External service providers

This data protection information does not apply to data protection, information or other practices of any external service provider, including those operating a website or offering a service that is linked to the services we render. Accordingly, there is no liability for us in such a context. Acceptance and provision of such a link in connection with our services does not indicate that we or one of our affiliated companies support the linked website or service.

9. Relevance and Modification of this Data Protection Declaration

This data protection declaration is currently. Due to the further development of our website and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. You can call up and print out the most recent privacy statement at any time at the respective link on the website https://www.altamarcam.com/de/privacy-policy/.

October 2022