I DATA PRIVACY POLICY

Last updated: 23 May 2018

Thank you for visiting our website and for your interest in our company. The protection of your personal data is a matter of great importance to us. Below we inform you according to art. 12, 13, and 21 of the General Data Protection Regulation (GDPR) about the handling of your personal data when visiting our website www.kjl-capital.de.

Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person. This includes information such as the civil name, address, telephone number and date of birth.

I. Responsible Body

Responsible Body according to GDPR

KJL Capital GmbH

Bockenheimer Landstraße 51-53

60325 Frankfurt 
E-Mail: kontakt@kjl-capital.de
Phone: +49 69 96 751 400

II. Purposes and Legal Basis of the Data Processing

1. Informational Use of the Website

You can visit our website without providing any personal information. If you use our website for informational purposes only, i.e. do not register for our newsletter or otherwise provide us with information about yourself, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website.

For the purpose of the technical provision of the website, it is necessary that we process certain automatically transmitted information about you so that your browser can display our website and you can use the website. This information is automatically collected for each visit of our website and stored in our server log files. This information refers to the computer system of the requesting computer.

Furthermore, we use cookies to make our website available to you for use. Cookies are text files that are stored in the internet browser or by the internet browser when you visit a website on your computer system. A cookie contains a characteristic string of characters that enables a unique identification of the browser when the website is called up again. We use these cookies exclusively to provide you with our website and its technical functions. Your information, collected by us through cookies, will not be used by us to create user profiles or to evaluate your browsing behavior.

We process your personal data for the technical provision of our website on the following legal basis:

• for the fulfilment of a contract or for the implementation of pre-contractual measures pursuant to Art. 6 para. 1 letter b GDPR, provided you visit our website to obtain information about our consulting services; and

• to protect our legitimate interests pursuant to Art. 6 para. 1 letter f GDPR in order to make the website technically available to you. Our legitimate interest is to offer you an appealing, technically functioning and user-friendly website as well as to take measures to protect our website from cyber risks and to prevent our website from posing cyber risks to third parties.

2. Active Use of the Website

In addition to the merely informational use of our website, you can also actively use our website, for instance get access to our quarterly reports or to register for our newsletter. In addition to the above-mentioned processing of your personal data for merely informational purposes, we will also process other personal data that we require from you to deliver the afore-mentioned functions.

a. User Requests

In order to process and answer your inquiries to us, e.g. via the email address mentioned in the imprint, we process your personal data provided by you in this context. In any case, this includes your name and email address in order to send you an answer, as well as the other information that you send to us in the context of your message.

We process your personal data in order to respond to user inquiries on the following legal basis:

• to protect our legitimate interests pursuant to art. 6 para. 1 lit f GDPR; our legitimate interest is to answer customer inquiries appropriately.

b. Google Analytics

We use Google Analytics on our website. This is a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 (hereinafter: Google).

Through certification according to the EU-US Privacy Shield

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

Google guarantees that it will follow the EU's data protection regulations when processing data in the United States.

The Google Analytics service is used to analyze how our website is used. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.

Usage and user-related information, such as IP address, place, time, or frequency of your visits to our website will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function, whereby Google truncates the IP address within the EU or the EEA before it is transmitted to the US.

The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. This data can also be used to provide other services related to the use of our website and of the internet in general.

Google states that it will not connect your IP address to other data. In addition, Google provides further information with regard to its data protection practices at

https://www.google.com/intl/de/policies/privacy/partners, including options you can exercise to prevent such use of your data. In addition, Google offers an opt-out add-on at https://tools.google.com/dlpage/gaoptout?hl=en in addition with further information. This add-on can be installed on the most popular browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs Google Analytics' JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services we may use as detailed herein.TODO

III. Links

Some sections of our web pages contain links to the web pages of third parties. These websites are subject to their own data protection principles. We are not responsible for their operation including the data handling. If you send information to or about such third party sites, you should review the privacy statements of those sites before you submit any information that may assigned to you.

IV. Categories of Recipients

Firstly, only our employees will be informed of your personal data. In addition, we share your personal data with other recipients who provide services to us in connection with our website, insofar as this is legally permitted or prescribed. We limit the transfer of your personal data to what is necessary, in particular to be able to complete your order. In some cases, our service providers receive your personal data as contract data processors and are then strictly bound by our instructions when handling your personal data. In some cases, the recipients act independently with your data, which we transmit to them.

Below, we describe the categories of recipients of your personal data:

• IT service providers who administrate and host our website,

V. Transfer into Third countries

We do not transfer your personal data to countries outside the EU or the EEA or to international organisations.

VI. Duration of Storage

1. Informational Use of the Website

When using our website for information purposes only, we store your personal data on our servers exclusively for the duration of your visit to our website. After you have left our website, your personal data will be deleted immediately.

Cookies installed by us are usually also deleted after leaving our website.

2. Active Use of the Website

If you actively use our website, we initially store your personal data for the duration of responding to your inquiry or for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the execution of a contract.

In addition, we will store your personal data until any legal claims arising from the relationship with you become time-barred, in order to use them as evidence if necessary. The limitation period is generally between 12 and 36 months, but can also be up to 30 years.

Upon expiry of the limitation period, we delete your personal data, unless there is a legal obligation to store such data, for example from the German Commercial Code (sec. 238, 257 para. 4 HGB) or from the Tax Code (sec. 147 para. 3, 4 AO). These retention obligations can last from two to ten years.

VII. Your Rights as Data Subject

Under the legal provisions you are entitled to the following rights as data subject, which you can assert against us:

Right to information: You are entitled to request confirmation from us at any time within the scope of art. 15 GDPR as to whether we are processing personal data relating to you; If this is the case, you are also entitled under art. 15 GDPR to receive information about such personal data as well as other specific information (inter alia, processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the data.

Right to correction: According to art. 16 GDPR, you are entitled to demand correction of the personal data stored about you if it is inaccurate or incorrect.

Right to deletion: You are entitled, under the conditions of art. 17 GDPR, to request from us the deletion of personal data relating to you without delay. Among other things, there is no right of deletion if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defence of legal claims.

Right to limitation of processing: Under the conditions of art. 18 GDPR you are entitled to request from us the limitation of the processing of your personal data.

Right to data transferability: You are entitled, under the conditions of art. 20 GDPR, to request from us the provision to you of the personal data relating to you that you have submitted to us in a structured, current and machine-readable format.

Right of revocation: You have the right to revoke your consent to the processing of personal data at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates.

Right to objection: You are entitled to object to the processing of your personal data under the conditions of art. 21 GDPR, meaning that we have to terminate the processing of your personal data. The right of objection exists only within the limits provided for in art. 21 GDPR. In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your personal data despite your objection.

Right of appeal to a supervisory authority: You are entitled to file a complaint with a supervisory authority, in particular in the Member State of your place of residence, work or suspected infringement, under the conditions laid down in Article 77 GDPR, if you believe that the processing of personal data concerning you infringes the GDPR. The right of appeal is not prejudicial to any other administrative or judicial remedy.

However, we recommend that you always address a complaint to our data protection officer first.

If possible, your applications for the execution of your rights should be addressed in writing to the above address or directly to our data protection officer.

VIII. Scope of your Obligations to provide Data

Generally, you are not obliged to provide us with your personal data. However, if you do not provide this information, we will not be able to make our website available to you, answer your questions and enter into a contract with you. Personal data which we do not necessarily require for the above-mentioned processing purposes are marked as voluntary information by a ” if applicable ” or another symbol.

IX. Automated Decision Making/ Profiling

We do not use automated decision making or profiling (an automated analysis of your personal circumstances).

X. Amendments

We reserve the right to change this privacy policy at any time. Any changes will be announced by publishing the amended privacy policy on our website. Unless otherwise specified, such amendments shall take immediate effect. Please check this privacy policy regularly to ensure you have the latest version.

II Legal Notices

1. Content

The author reserves the right not to be responsible for the topicality, correctness, completeness or quality of the information provided. Liability claims regarding damage caused by the use of any information provided, including any kind of information which is incomplete or incorrect, will therefore be rejected. All offers are not-binding and without obligation. Parts of the pages or the complete publication including all offers and information might be extended, changed or partly or completely deleted by the author without separate announcement.

2. Referrals and links

The author is not responsible for any contents linked or referred to from his pages – unless he has full knowledge of illegal contents and would be able to prevent the visitors of his site from viewing those pages. If any damage occurs by the use of information presented there, only the author of the respective pages might be liable, not the one who has linked to these pages. Furthermore the author is not liable for any postings or messages published by users of discussion boards, guest books or mailing lists provided on his page.

3. Copyright

The author intended not to use any copyrighted material for the publication or, if not possible, to indicate the copyright of the respective object. The copyright for any material created by the author is reserved. Any duplication or use of objects such as images, diagrams, sounds or texts in other electronic or printed publications is not permitted without the author’s agreement.

4. No offer or advisory services and limited distribution regarding website content

The content published on this website (information, products, data, services and tools) constitutes neither a solicitation nor offer to buy, hold or sell the investment or financial instruments or other products mentioned on this website nor a solicitation or offer to carry out or conclude any legal or other transactions. This content is provided exclusively for information purposes. The information and data contained in this website does not constitute investment, legal, tax or other advice nor is it to be construed as a basis for investment or other decisions. You should seek appropriate professional advice before making any investment decision. Accordingly, no element of this website is part of any offer to issue or solicitation to subscribe to or buy shares, fund units or other investments or other financial products or securities. Our content is provided to you solely for your information only and may not be reproduced or distributed to any other person.

The units of the KJL Capital Funds that are issued may only be sold or offered for sale in jurisdictions in which such offer or sale is permitted. Therefore the units of this fund may not be offered for sale or sold in the USA, or offered for sale or sold to or for the account of US citizens or US persons resident in the USA. The documents and the information may not be distributed in the USA. The distribution and publication of the documents and the information and the offer or sale of units may also be subject to restrictions in other jurisdictions. Historical data is no guarantee of future results. KJL Capital GmbH gives no guarantee that market forecasts, implied yields or called target prices will be achieved. Changes in the underlying assumptions may have a material impact on forecasts, yields and prices. The income from investments is subject to fluctuations. You should make a decision about a purchase not before the submission of all documents and information on risks and the prior law, tax and investment advice. All data are subject to change. All information without engagement. KJL Capital GmbH accepts no liability for loss or damages of any kind from access to its website or its links. The notices are governed by the law of the Federal Republic of Germany.

5. Legal validity of this disclaimer

This disclaimer is to be regarded as part of the internet publication which you were referred from. If sections or individual terms of this statement are not legal or correct, the content or validity of the other parts remain uninfluenced by this fact. KJL Capital GmbH accepts no liability for loss or damages of any kind from access to its website or its links. The notices are governed by the law of the Federal Republic of Germany.