Privacy Policy AVARAS HOLDING AG Investment Management Group Limited (AVARAS HOLDING AG or We) understands and appreciates that you are concerned about the confidentiality and security of information that AVARAS HOLDING AG collects about you. AVARAS HOLDING AG SP recognises each individual’s right to privacy and is committed to the protection and confidentiality of your personal information. AVARAS HOLDING AG is bound by the Privacy Act 1988 (Cth) and must protect your personal information in accordance with that Act and other applicable laws, such as the Spam Act 2007 (Cth). In addition to the Privacy Act, individuals located in the European Union (EU) also have rights under EU based rules known as the General Data Protection Regulation (GDPR). The GDPR has harmonised the data privacy laws of each individual EU country, giving more rights to individuals located in the EU and imposing more obligations on organisations holding personal information. Details of additional rights of individuals located in the EU and how we meet them are outlined in this policy below. HOW DO WE COLLECT PERSONAL INFORMATION? We collect personal information so that we can provide you with our products and services and comply with our legal and regulatory obligations. We will not collect any information that identifies you as an individual unless you knowingly provide it to us. We primarily collect this information when you complete an application form or subscribe for information or notifications from us or our affiliates. In addition, when you browse our website, read or download information, our system will record the date and time of your visit and the pages viewed and information downloaded. In most cases, we will collect your personal information directly from you. However, we can also collect your personal information from other sources, such as our affiliates or from third parties such as your authorised representatives and advisers. WHAT PERSONAL INFORMATION DO WE COLLECT? Any information that identifies you is deemed to be personal information. The personal information we collect about you will depend on the circumstances of collection. We collect information that is reasonably necessary to be able to provide you with our products or services. For instance, we can ask for identification information such as your name, date of birth, residential address, email address, telephone number, financial and investment information, bank account details, citizenship, social security number and/or tax file/identification number.
Sensitive information
The Privacy Act protects your sensitive information — such as information about your religion, ethnicity, health or biometrics. We will not collect your sensitive information. HOW DO WE USE YOUR PERSONAL INFORMATION? Any information we collect from you, can be used by any entity carrying out functions on behalf of AVARAS HOLDING AG and its related entities for: – the purpose of enabling AVARAS HOLDING AG to provide services or information to you in accordance with your requests or reasonable expectations; – the purpose of enabling AVARAS HOLDING AG to undertake research, planning, product development, risk assessment, risk modelling and marketing; and – any other purpose required by or to the extent permitted by law.
DIRECT MARKETING
We may use the information we gather to provide you with targeted communications about products and services we think will be of interest to you. We may also send you details of offers or services provided by AVARAS HOLDING AG’s related entities. You may at any time choose not to receive these communications. Doing so will not cost you anything, and we commit to ensuring that you stop receiving any unwanted communications as soon as possible. If you do not want to receive such communications, please contact us.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We will only disclose personal information to third party entities carrying out functions on behalf of AVARAS HOLDING AG and its related entities on a confidential basis. You should note that information we collect from you can also be disclosed to third parties if that disclosure is required, or to the extent permitted, by law.

OVERSEAS RECIPIENTS
We may disclose your personal information to external service providers in the following offshore locations: Canada, Malaysia, Luxembourg, Hong Kong and the SWISS. We take steps to ensure that our external service providers keep your personal information confidential and use it only for the purposes for which they are authorised.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
AVARAS HOLDING AG regards the security of your personal information as a priority and takes all reasonable steps to protect your information from loss and unauthorised access, destruction, use, modification or disclosure. AVARAS HOLDING AG stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our secure premises and systems as well as offsite using trusted third parties. We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure. Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use. AVARAS HOLDING AG cannot ensure or warrant the security of any information you transmit to us or receive from our products or services and you do so at your own risk. Once we receive your information, we take reasonable steps to preserve the security of information on our own system. From time to time the website contains links to other websites. AVARAS HOLDING AG is not responsible for the privacy practices or the content of these websites.

COOKIES
A cookie is a small data file placed on your computer by AVARAS HOLDING AG’s server. A cookie contains information about your visit to the website. When you visit the website again, our server will look for the cookie and structure itself based on the information provided. A cookie identifies your computer to our web server when you visit the website. We do not use the cookie to store personal information about you. AVARAS HOLDING AG uses browser cookies to improve the speed and reliability of our security system. It is recommended that you turn off any cookie warnings in your browser before using this website, otherwise you may not be able to use the full functionality of this website. ACCEPTANCE AND CHANGES TO THE PRIVACY POLICY You acknowledge and accept that your use of the website indicates your acceptance of the website’s terms and conditions of use and this Privacy Policy. This Privacy Policy may change from time to time. Any information collected after an amended Privacy Policy has been posted on the website will be subject to that amended Privacy Policy. ACCESS AND UPDATING OF INFORMATION You are able to access and update the personal information that we hold about you at any time. To amend personal information that AVARAS HOLDING AG holds, please contact us. IF YOU HAVE A PRIVACY COMPLAINT At AVARAS HOLDING AG, we value our customers. We will always aim to be fair and responsive. If you have a privacy complaint, you have the right to expect that we will handle it in a friendly and professional way. When we receive a complaint, we receive this as valuable feedback that may help us improve our services and to ensure your needs are met in a satisfactory and appropriate manner. If you wish to complain, at any time, about the handling, use or disclosure of your personal information, you can provide your written complaint by email, letter or by personal delivery to any one of our contact details noted below or verbally by telephone.