Why should you read this document?

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, and your financial situation (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, Identification document. Your Personal Data may also identify you indirectly, for example, your employment situation, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your Investment requirements, Your Personal Data may include:

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity

• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history

• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents

• Any pre-existing Investment and Insurance products and the terms and conditions relating to these The basis upon which Black Swan Capital will deal with Your Personal Data

When we speak with you about your Investment requirements we do so on the basis that both parties are entering a contract for the supply of services.

In order to perform that contract, and to arrange the investments you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from Product providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The De Autoriteit Financiële Markten/ Dutch Authority for Financial Markets(AFM), or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to Investment advice. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain. If we use technology solutions to assist in the collection of Your Personal Data, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used, should it be used.

What happens to Your Personal Data when it is disclosed to us?

In the course of handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by specified employees and financial adviser representatives within BSC and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service

• Submit Your Personal Data to Investment Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.

• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any Investment product you may take out, or to inform you of any developments in relation to those products of which we might become aware

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

• Investment Providers

• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, or Product specialists

• In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your Investment enquiry and to provide you with our professional services. Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right or obligation to hold to such information we will retain records indefinitely.

Your rights in relation to Your Personal Data

You can:

• request copies of Your Personal Data that is under our control

• ask us to further explain how we use Your Personal Data

• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)

• ask us to send an electronic copy of Your Personal Data to another organization should you wish

• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to make contact with Black Swan Capital in relation to the use of Your Personal Data

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:

David Bellingham, Chief Executive Officer, Black Swan Capital, Amsterdam Paleis op de Dam, Herengracht 282, Amsterdam, 1016 BX, The Netherlands.

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

You can contact Black Swan Capital by telephone at +31 241 1230, and if you have a concern or a compliant you can contact the company by email at compliance@blackswancapital.eu. For general enquiries, you can contact us at info@blackswancapital.eu.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens (DPA), who can be contacted through their website at https://autoriteitpersoonsgegevens.nl/en or by telephone on +31 70 888 85 00.