Privacy Policy

Dynam may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Policy.

The personal data we, collect and process may include:

• information obtained from identification documentation (including your name, contact details, nationality and national identify numbers (where applicable));
• your professional title and occupation;
• your age and marital status;
• financial information, tax status, account details and evidence of ownership of financial assets;
• personal identifiers such as your social security number, national insurance number, tax file number, IP address or our internal electronic identifiers;
• information which we or our service providers need to conduct ‘know your client’ checks such as details relating to your passport and credit history; and
• other information you provide in the course of your dealings with us or which they each require to provide you with products and services.

In certain circumstances, we also collect and process what are known as ‘special categories’ of personal data (as defined by Data Protection Legislation). Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in Dynam obtaining information about actual or alleged criminal convictions and offences.

You are not obliged to provide us with your personal data where it is requested but we may be unable to provide certain products and services or proceed with your business relationship with Dynam if you do not do so.

The information we collect comes from:

• application forms or other materials you or your authorised representative submits to us during the course of your relationship with Dynam;
• your or your authorised representative’s interactions with Dynam, transactions and use of our products and services (including the use of our Website);
• your or your authorised representative’s business dealings with Dynam, including via email, telephone, social media or as stated in contracts with you;
• depending on the products or services you or your authorised representative requires, third parties (including for credit and money laundering checks, among other things); and
• recording and monitoring tools that they use for compliance or security purposes (e.g. recording of telephone calls, monitoring emails, etc.).

Our primary purpose in collecting your personal information is to facilitate the efficient transmission of news and updates on funds managed or advised by Dynam or provide general updates on the markets we operate in, and to provide you with any information products or services that you request from us.

Data Protection Legislation permits us to process your personal data in the way that it does because the processing is:

• necessary for the purposes of the legitimate interests that we pursue, which are to run and administer client funds, to discharge our legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services; or
• necessary for the purposes of the legitimate interests that we pursue, which are to manage client funds, to discharge our legal obligations, to store and disclose information where necessary and to to evaluate, develop and improve our services; or
• necessary in order to comply with a legal obligation to which we are subject.

To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.

The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Policy:

• third parties such as service providers of Dynam, auditors, regulatory authorities and technology providers, agents, contractors, service providers or related companies if this is necessary to respond to your enquirers or for any other related purposes;
• any regulatory, supervisory or governmental authorities to the extent we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud);
• tax authorities.

Dynam does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.

Personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or to countries not regarded by the European Commission as providing an adequate level of data protection. When we, or our permitted third parties, transfer personal information in this manner will ensure that the transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.

We do not carry out automated decision-making or profiling.

At any time, you have the right:

• to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
• to request access to or a copy of any personal data which we hold about you;
• to rectification of your personal data, if you consider that it is inaccurate;
• to ask us to delete your personal data, if you consider that we do not have the right to hold it;
• to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• to restrict processing of your personal data;
• to data portability (moving some of your personal data elsewhere) in certain circumstances;
• to object to your personal data being processed in certain circumstances; and
• not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

We will only keep the information we collect about you for as long as required for the purposes set out in this Privacy Policy or as required to comply with any legal obligations to which we are subject being the longest of the following periods:

• a minimum of six years;
• as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with Dynam;
• the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
• any retention period that is required by law; or
• the end of the period in which litigation or investigations might arise in respect of an investment in a fund managed or advised by Dynam.

This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

We ensure that there are appropriate technical, physical, electronic, and administrative safeguards in place to protect your personal details from unauthorised access.

This privacy notice may be amended from time to time without notice, in which case the date of this privacy notice will be revised. If our privacy policy changes in any way, we will place an updated version on this page.

Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

This Privacy Policy is for your information and should not be used as the basis for any decision to invest in funds managed or advised by Dynam. The views and information expressed on this Website do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.

This Website may contain hyperlinks to external websites. Dynam is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

a. Our use of cookies
Dynam Capital, Ltd or any third party service provider, functionary or agent appointed by the company acting on its behalf (together “Dynam”, “we”, “us”, “our”) set and access cookies and similar technology on your device to obtain information about how you access and make use of our website http://www.dynamcapital.com/ (the “Website”).

This helps us to provide you with a good experience and allows us to improve the Website. Unless you have adjusted your browser settings so that it will refuse cookies, the Website will set cookies when you load and navigate them.

If you have any questions about this Cookies Policy, please email info@dynamcapital.com

What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a Website. Cookies are then sent back to the originating website during your browsing session or on each subsequent visit, or to another website that recognises that cookie.

The cookies we set do lots of different jobs, like help us to improve the Website and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. You can find more information about cookies at http://www.allaboutcookies.org/.c.

What we use cookies for?
We only collect information we feel is essential for you to use our Website efficiently and to improve services for you, for example:

• for technical purposes essential to the effective operation of the Website;
• Enabling a service to recognise your device so you don’t have to give the same information several times during one task;
• measuring how many people are using our Website, to ensure there is enough capacity for our Website to operate at a reasonable speed;
• completion and support of the current activity being undertaken by the user, for example previously viewed pages;
• Website and system administration, for example, tracking the number of website users for marketing purposes;
• Remembering pages viewed.

d. Cookies categories
We use the following types of cookies:

• Strictly necessary cookies – these cookies are essential in order to enable you to move around a Website and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
• Performance cookies – these cookies collect information about how visitors use a Website (for example, by recording which pages or features visitors use most often (usually on an anonymous basis).

Cookies can also be categorised in accordance with how long they are saved on your device: "session cookies" are short-term cookies that are only saved on the device's memory for the duration of a user's visit to the Website, whereas "persistent cookies" remain saved in the device's memory for a set period of time, even after the browser session has ended.

e. Refusing or restricting cookies
Where we require consent to plant cookies, you may refuse to accept cookies, when you first visit the Website by declining to provide your consent or if after you have provided such consent or if we do not require your consent - by activating the setting on your browser which allows you to refuse the setting of cookies.

The "Help" or "Internet Settings" functions within your browser should tell you how. Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers.

Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of the Website.

f. Changes to this Policy
We may amend this Cookies Policy at any time by posting the amended terms on the Website. All amended terms will automatically take effect immediately on posting. Please check this Cookies Policy periodically to inform yourself of any changes. If you do not accept the changes made to this Cookies Policy, you should immediately stop using the Website.

Questions, comments and requests regarding this Privacy Policy are welcomed and should be marked for the attention of Craig Martin, Chairman, Dynam Capital info@dynamcapital.com.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Office of the Data Protection Authority, which regulates and supervises the use of personal data in Guernsey.