Privacy Policy

This policy explains what, how, and why of the Personal Information (as defined below) we collect when you sign up to our portal or ask to be added to our mailing list. It also explains the specific ways we use and disclose that Personal Information. We take your privacy extremely seriously, and we never hand your Personal Information over to other companies other than for our own use and control.

We are responsible for ensuring that we use your Personal Information in compliance with data protection laws, including (but not limited to) the UK GDPR (which is the EU’s General Data Protection Regulation (GDPR) (2016/679) as transposed into the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018) and the Data Protection Act 2018.

THE BASICS

1. Definitions

These definitions should help you understand this policy. When we say “we,” “us,” “our,” “the firm” and “East X,” we are referring to East X LLP, a UK partnership and East Alpha Limited, registered in England and Wales (Company No.: 10782681). East Alpha Limited is the data controller in respect of your Personal Data. We are a quantitative systematic investment firm based in London. This policy relates to both the investment services (“the Services”) we provide and any information we send out or publish on our portal (“Marketing”). When we say “Investor,” we are referring to the person or entity that is registered with us to use the Services. When we say “you,” we are referring either to an Investor, a potential Investor or to some other person who visits any of our Websites and portals or receives our Marketing materials via a mailing list. A “Subscriber” is a person that has signed up to our portal and has given permission to be included in our Marketing and has agreed to be contacted as part of a monthly / annual performance emails and who may be contacted as an Investor or potential Investor. “Personal Information” means any information that identifies or can be used to identify you or a Subscriber or Investor, directly or indirectly, including, but not limited to, first and last name, email address, phone number, occupation, employer or company or other demographic information. A “Distribution List” is a list of Subscribers and all associated information related to those Subscribers (for example, email addresses).

We offer the Services and Marketing on our website https://www.eastx.com/, our portal https://eastalphafundportaLio/auth/login/, via our HubSpot CRM system. This Privacy Policy applies to these specific websites, as well as any other sites or mobile applications owned or operated by us (each a “Website” and together the “Websites”). The “Websites” include the Websites themselves, and any web pages, interactive features or hosted documents, applications, widgets, blogs, social networks, social network “tabs,” or other online, mobile, or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device, or other technology, manner or means. While providing the Services, and as described in more detail below, we may collect Personal Information about a Website visitor, Member, person or email address on or related to a Distribution List, or Subscriber.

2. Changes

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on our website, portal or attached to any email we send. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this Privacy Policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in effect on each respective date you visited our portal, website or received a link through on our marketing.

3. Scope

This Privacy Policy is effective with respect to any Personal Information that we have collected, or collect, about and/or from you through meeting with you, from a business card you have provided to us, through email you have contacted us on, through your registration to our Services and Marketing.

4. Questions & Concerns

If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter contact us by postal mail or email at:

East X LLP

Attn. Privacy Officer

info@eastx.com

4th Floor, Tea Auction House, Hay’s Galleria, SE1 2HD, United Kingdom

YOUR INFORMATION

(a) Information you provide to us: When you sign up for and use the Services, speak with our investment team, provide business cards, send us an email, or communicate with us in any way, you are voluntarily giving us information that we then collect. That information may include your name, physical address, email address, phone number, as well as details including occupation and employer.

(b) Information we collect or generate about you: When you use the Services or browse our portal (having already voluntarily signed up), we may collect information about your visit to our website or portal, your usage of the Services and downloading and viewing of our Marketing materials. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies.

(c) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the portal or Marketing emails and links. This type of information helps us to improve our Services for both you and for all of our users.

(d) Cookies and tracking: When you visit our Websites, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by us, please read our Cookie Notice.

(e) Web beacons: We use web beacons on our Websites and in our emails as provided by our third-party partners. When we send emails to Investors or potential Investors, we may track behaviour such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our Marketing. To do this, MailChimp includes single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details.

6. Use and Disclosure of Personal Information

We use your Personal Information for the following purposes:

(a) To promote use of our Services to you and others. For example, if we collect your Personal Information when we meet you through our Marketing activities, through provision of a business card or through direct contact and you have not already subscribed to our mailing list or portal we may send you a link inviting you to sign up to our Portal and give consent to our use and storage of your Personal Information. If you use any of our Services and we think you might benefit from investing in another Service we offer, we may send you an email about that. You can stop receiving our emails by following the unsubscribe instructions included in every email we send. You can request removal of all your Personal Information from our records directly by emailing info@eastx.com.

(b) To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.

(c) To bill and collect money owed to us by our Investors. This includes sending you emails, invoices, receipts, notices of delinquency. We use third parties for accounting (Throgmorton) and sometimes invoice payment and collection and so we may forward invoices to them for charging and accounting purposes. To learn more about the steps we take to safeguard your Personal Information, see Section 10 below.

(d) To communicate with our Investors about their account.

(e) To enforce compliance with our Terms of Use and applicable Law. This may include developing tools and algorithms that help us prevent violations.

(f) To protect the rights and safety of our Investors and third parties, as well as our own.

(g) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.

(h) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.

(i) To prosecute and defend a court, arbitration, or similar legal proceeding.

(j) To respond to lawful requests by public authorities, including to meet national security or Law enforcement requirements.

(k) To provide, support, and improve the Services we offer. This also includes, for example, aggregating information from your use of the Services or visits to our Websites, Portal and Marketing and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.

(l) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

(m)To consider any application for employment (including, in some cases, verifying your qualifications and references with third parties for the purpose of undertaking background checks);

Combined Information: We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners), to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this Privacy Policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this Privacy Policy applicable to, Personal Information.

However, when we use Personal Information we make sure that the usage complies with law and the law allows us and requires us to use Personal Information for a variety of reasons. These include:

· we need to do so in order to perform our contractual obligations with our customers and third-party providers such as Edgefolio, HubSpot and Throgmorton;

· we have obtained your consent;

· we have legal and regulatory obligations that we have to discharge;

· we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

· the use of your Personal Information as described is necessary for our legitimate business interests, such as:

- allowing us to effectively and efficiently manage and administer the operation of our business;

- maintaining compliance with internal policies and procedures;

- monitoring the use of our copyrighted materials;

- enabling quick and easy access to information on our Services;

- offering optimal, up-to-date security solutions for mobile devices and IT systems; and

- obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

7. Third Parties

We may disclose Personal Information for the following purposes:

(a) to our Service Providers. Sometimes, we share your information with our third-party Service Providers, who help us provide and support our Services. For example, if you have signed up to our portal, this is provided by our partner Edgefolio. We may also then provide your email address to those who operate our mailing lists. Your email will also be saved in HubSpot, our CRM system. Just like with the other third parties we work with, these third-party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include payment processors and providers of hosting services and content delivery services.

(b) to the extent required by law, for example if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;

(c) if we sell our business or assets, in which case we may need to disclose your Personal Information to the prospective buyer for due diligence purposes; and

(d) if we are acquired by a third party, in which case the Personal Information held by us about you will be disclosed to the third party buyer.

8. International Transfers of Personal Information

Our customers and our operations are spread around the world. As a result, we collect and transfer Personal Information on a global basis. That means that we may transfer your Personal Information to locations outside of the United Kingdom (“UK”).

7.1 Where we transfer your Personal Information to another country outside the UK, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside the UK, for example, this may be done in one of the following ways:

· the country that we send the data to might be approved by the UK Government as offering an adequate level of protection for Personal Information;

· the recipient might have signed up to a contract based on “model contractual clauses” approved by the UK Government, obliging them to protect your Personal Information;

· the recipient may have adhered to binding corporate rules (only for intra-firm transfers);

· in other circumstances the law may permit us to otherwise transfer your Personal Information outside the UK.

8.2 You can obtain more details of the protection given to your Personal Information when it is transferred outside the UK (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Information) by contacting us as described in Section 13 below.

SECURITY

9. Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system, or that of our service providers, that materially affects you, then East X will notify you as soon as possible and later report the action we took in response.

10. Safeguarding Your Information

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

Accounts on our portal require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. We cannot resend forgotten passwords. We will only reset them.

We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep your Personal Information safe. We only authorise access to employees who need it to carry out their job responsibilities.

We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).

We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your Personal Information. We may occasionally ask for proof of identity before we share your Personal Information with you.

As a condition of employment, our employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Information is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by our employees is prohibited and may result in disciplinary measures.

However, whilst we take appropriate technical and organisational measures to safeguard your Personal Information, please note that we cannot guarantee the security of any Personal Information that you transfer over the internet to us.

COMPLIANCE

11. How Long We Keep Your Personal Information

How long we will hold your Personal Information for will vary and will be determined by the following cumulative criteria:

· the purpose for which we are using it – we will need to keep your Personal Information for as long as is necessary for that purpose; and

· legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Information.

12. Rights of Data Subjects

In all the above cases in which we collect, use or store your Personal Information, you may have the following rights which you can exercise free of charge. These rights include:

· the right to obtain information regarding the processing of your Personal Information and access to the Personal Information which we hold about you;

· the right to withdraw your consent to the processing of your Personal Information at any time. Please note, however, that we may still be entitled to process your Personal Information if we have another legitimate reason for doing so. For example, we may need to retain Personal Information to comply with a legal obligation;

· in some circumstances, the right to receive some Personal Information in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Information which you have provided directly to us;

· the right to request that we rectify your Personal Information if it is inaccurate or incomplete;

· the right to request that we erase your Personal Information in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Information, but we are legally entitled to retain it;

· the right to object to, or request that we restrict, our processing of your Personal Information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Information but we are legally entitled to refuse that request; and

· the right to lodge a complaint with the Information Commissioner's Office if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed in Section 13 below.

13. Questions and Concerns

For further information regarding the processing of your Personal Information by us, this Privacy Policy, questions relating to consent, or in order to exercise the rights mentioned above, please contact our data protection officer using the following contact details: