The Foundation is a foundation company created under the laws of the Cayman Islands.

The purpose of this document is to provide you with information on the Foundation's use of your personal data in accordance with the Cayman Islands Data Protection Act, (2021 Revision) and, in respect of EU data subjects, the EU General Data Protection Regulation (together, the "Data Protection Legislation").

If you are an individual, this Data Privacy Notice will affect you directly. If you are an institution or a legal person/entity/arrangement that provides us with personal data on individuals in connection with your business with us, this Data Privacy Notice will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

Your personal data will be processed by the Foundation, and by persons engaged by the Foundation.  Under the Data Protection Legislation, you have rights, and the Foundation has obligations, with respect to your personal data.  The purpose of this notice is to explain how and why the Foundation, and persons engaged by the Foundation, will use, store, share and otherwise process your personal data. This notice also sets out your rights under the Data Protection Legislation, and how you may exercise them.

Your personal data

By virtue of your business with the Foundation or by virtue of you otherwise providing us with personal information on individuals connected with you (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the Data Protection Legislation.

You may provide us with personal data in the context of the following: (i) engaging in transactions with the Foundation; (ii) in the course of your provision of services to, or contracts with, the Foundation (e.g. contractors, consultants, counterparties); or (iii) any other circumstances in which you provide the Foundation with personal information relating to individuals.

We may also obtain personal data on you from other public accessible directories and sources. These may include websites; bankruptcy registers; tax authorities; governmental agencies and departments, and regulatory authorities, to whom we have regulatory obligations; credit reference agencies; sanctions screening databases; and fraud prevention and detection agencies and organisations, including law enforcement.

This includes information relating to you and/or any individuals connected otherwise connected with you in relation to your business with the Foundation such as: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, and source of funds details.

How the Foundation may use your personal data

The Foundation, as the data controller, may collect, store and use your personal data for purposes including the following:

The processing is necessary for the performance of a contract, including:

• administering or managing the Foundation;
• facilitating the provision of services to or by the Foundation;
• facilitating the continuation or termination of the contractual relationship between you and the Foundation; and
• facilitating the transfer of funds, and administering and facilitating any other transaction, between you and one or more of the Foundation.

The processing is necessary for compliance with applicable legal or regulatory obligations, including:

• undertaking customer/counterparty due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our customers and counterparties (and, where applicable, their beneficial owners);
• sanctions screening and complying with applicable sanctions and embargo legislation;
• complying with requests from regulatory, governmental, tax and law enforcement authorities;