DATA PRIVACY STATEMENT - DISCLAIMER

This site is provided by Carlisle Management SCA (hereafter “Carlisle”). It is intended to contain information exclusively for institutional and professional investors. No investment advice is offered or given by Carlisle to any persons accessing information on this site; consequently, prospective investors should take advice from their own professional advisers before making any investment decision.

The following information applies to every page on this website, whether or not such pages individually contain a disclaimer notification. You agree that you have to read and understand the information contained on this page and confirm that you are eligible to read the documents posted on the website before you enter it.

It is possible that the products and services presented on this website are not authorized for persons under another jurisdiction by virtue of their nationality, their place of residence or by virtue of any other reason stipulated in the national legislation to which they are subject. By navigating on this website, you accept sole responsibility for the information provided in that respect. Any information featuring on this website has been thoroughly researched by Carlisle. However, Carlisle does not in any way guarantee or warrant, either implicitly or explicitly, the completeness or accuracy of the information posted on this site.

Carlisle accepts no liability for the financial consequence or any other consequence whatsoever resulting from a decision made based on this website.

Carlisle makes no warranties regarding the compatibility of the website with any device or software with which you may choose to access it.

Carlisle uses industry standard anti-virus software on all of its servers but does not guarantee that the website is secure or free from computer viruses, bugs or other malicious codes or software. It is your responsibility to ensure that each computer you use to access the website is itself protected by an industry standard anti-virus service that is regularly updated and maintained.

No member of the Carlisle Group accepts any liability or responsibility whatsoever for any loss or damage that you may incur as a result of:

1. your use of this website or of its content.
2. any computer virus, bug or other malicious code or software that you may pick up as a result of using this website.
3. your following any link on this website to a third party website or your use of that third party website or of its content.

If you do follow any link on this website to a third party website, we encourage you to review the privacy policy applicable to that site, especially before disclosing any personal information.

Registration

This website should not be regarded as an offer or solicitation to invest in the Funds in any jurisdiction where such activity is unlawful. This website is not directed at you if the Funds is prohibited by any law of any jurisdiction from making the information on this site available to you and is not intended for any use which would be contrary to local law or regulation. You should proceed into this site only if you have satisfied yourself that the country in which you are based imposes no prohibitions or restrictions on the distribution of the promotional material on this site.

General

The information on this website is issued by Carlisle. The content of this website and the layout, appearance and design of the website itself is the property of Carlisle and is protected by all relevant intellectual property rights laws and regulations.

Before investing, all relevant documents, such as reports and accounts and prospectus should be read, which specify the particular risks associated with investment in the Funds, together with any specific restrictions applying and the basis of dealing.

The information herein is not an offer to sell, or to solicit an offer to purchase any securities, anyone in any jurisdiction in which such offer or solicitation is not authorized, or in which the person making such an offer is not qualified to do so, or to anyone to whom it is unlawful to make such an offer or solicitation, or to anyone in any jurisdiction inside of the United States.

The value of any investments and any income generated may go down as well as up and is not guaranteed. Past performance is not a guide to future performance. Changes in rates of exchange may have an adverse effect on the value, price or in income of an investment.

Additional Risk Warnings

The risk associated with certain investments are not appropriate for all investors.

Investment in a Fund is not intended to be a complete investment program for any investor. An investment should be viewed as a medium to long –term investment.

The nature of a Fund’s investments involves certain risks and a Fund may utilize investment techniques (such as the use of leverage and short selling) which may carry additional risks. Prospective investors should carefully consider, among others, the following factors before subscribing.

Potential Concentration of Investments, Counterparty Risk, Foreign Exchange/Exchange Control Risks, Settlement Risk, Currency exposure/Unlisted securities and Derivatives Risks; Inadequate Market, Liquidity and Leverage. Please refer to the prospectus for further information. An investment in a Fund therefore carries substantial risk and is suitable only for persons who can assume the risk of losing their entire investment.

Cookies

This site may use cookies or other information software to retrieve information about a visitor to the site. Carlisle does not however collect information sufficient to identify any individual nor will it use cookies or other information software to process personal data as defined by the amended law of 2 August 2002 relating to the protection of natural persons with regard to the processing of personal data (the “Data Protection Law”). Retrieved information will be limited to such information as is sufficient to identify the number of individual visitors to the site.

Privacy Policy & Data Protection

This Privacy Statement is a "privacy notice" for the purposes of Applicable Data Protection Law, and in particular the European Union's General Data Protection Regulation ("GDPR"), given by Carlisle when acting in its capacity as a data controller in relation to its collection and use of Personal Data, as defined by GDPR.

Where Personal Data about you is collected and then used by Carlisle or someone else under this Privacy Statement as the result of you engaging with Carlisle, Carlisle is the data controller in respect of that Personal Data.

Carlisle does not sell or otherwise pass on your contact details to any third party outside the Carlisle Group for marketing purposes.

In this Privacy Statement, the phrase "those connected with you" refers to (a) your employees or other people who deal with us on your behalf, whether you are a client that is an individual, a corporate body or some other form of entity or organisation, or an investor in, or an owner of, a client and (b) those people who represent other entities or organisations that we might deal with, such as advisers, regulators, suppliers or anyone else that makes any form of enquiry in relation to us or our services.

Please read this Privacy Statement carefully to understand our practices regarding your Personal Data and how we will treat it. In addition, if you leave a voicemail message with us, that message may be Processed in a similar manner, and for the same or similar purposes, to email and postal correspondence from or concerning you.

If you have any queries regarding anything in this Privacy Statement, please contact our Compliance Officer, whose contact details can be found at the end of this document.

In the remainder of this Privacy Statement, "we" refers to Carlisle and "us" and "our" is to be read accordingly.

Purpose of Data Protection

The purpose of data protection legislation is to protect the rights and privacy of individuals ("Data Subjects") in respect of the Processing of Personal Data concerning them. "Personal Data" is any information relating to an identified or identifiable natural person (known as a "data subject"). A person is "identifiable" if he or she can be identified, directly or indirectly, not only by things such as a name or an identification number, but also by things such as location data or some factor specific to (for example) the physical, physiological or social identity of that person. More common examples of Personal Data include names, identification numbers, contact information, identity documents, medical records and photographic images. "Processing" covers any activity involving Personal Data and includes such things as the collection, recording, storage, adaptation, use, disclosure and destruction of Personal Data.

Whose Personal Data do we process?

Clients (and potential clients)

We have clients that are individuals and clients that are corporate bodies, including limited liability partnerships, government departments and agencies and other public bodies. Even where our clients are not themselves individuals, they will be represented by individuals and they may be owned by individuals and invested in by individuals. As a result, we will inevitably process Personal Data in the course of our relationships with those clients too.

As a potential client and then (if applicable) as a client, the Personal Data that we Process will include personal and/or professional contact details (addresses, telephone numbers, email addresses), copy identity documents and proofs of address, copy professional and educational certificates, details of bank accounts and/or other payment details, details of financial standing and investment objectives.

Investors, Legal and Beneficial Owners, Settlors, Protectors and Beneficiaries

We deal with individuals and various types of organisations that are connected with clients, such as owners and investors and beneficiaries,

As a person connected with a potential client and (if applicable) then a client that falls under this paragraph, the Personal Data that we Process about you will include personal and/or professional contact details (addresses, telephone numbers, email addresses), copy identity documents and proofs of address, copy professional and educational certificates and data to facilitate tax information exchange.

Other Client-Connected People: Advisers and Regulators

We also deal with those organisations that provide professional advice or services to us or to our clients, those that supervise and regulate us and our clients, those that supply goods and services to us and our past, present and (in the case of job applicants) future staff.

As an "Other Client-Connected" person, the Personal Data that we Process about you will include personal and/or professional contact details (addresses, telephone numbers, email addresses).

Suppliers (and potential suppliers)

As a potential supplier and then (if applicable) as a supplier, the Personal Data that we Process will include personal and/or professional contact details (addresses, telephone numbers, email addresses), documents and other proofs of standing and reputation and details of bank accounts and/or other payment details.

Potential employees

If you are an applicant for a job with us (a potential employee), the Personal Data that we Process about you will include:

1. your name, address and contact details, including telephone numbers and email addresses;
2. details of your qualifications, skills, experience and employment history including notice periods and reasons for leaving and references;
3. information about your current and past levels of remuneration, including entitlement to benefits;
4. whether or not you have a disability that we may need to make adjustments for during the recruitment process;
5. information about your entitlement to reside and/or work in the place where you have applied for a job; and
6. equal opportunity monitoring information, including information about your ethnic origin, sexual orientation, health and religion or beliefs where required by legislation.
7. Any other information provided by you on your CV. For the information we require you to submit on your CV please refer to the careers section of our website.

If your application for a job with us is unsuccessful, we will retain your Personal Data for a minimum of 6 months after the last point of contact with you (or any recruitment agency through which you have applied to us), but only up until our next clear out of job applicant Personal Information that is no longer required, which takes place biannually at about six month intervals. We will delete any Personal Information no longer required in an appropriate and secure manner.

If your application for a job with us is successful, our retention of your Personal Data will be governed by our separate notice on staff Personal Data referred to as the Employee Privacy Notice, which will be made available to you by our HR department as part of your becoming an employee.

Enquirers and visitors to our website

You may give us Personal Data by filling in a contact form on our website or by corresponding with us by email. In each of the above cases, the Personal Data that we Process will include personal and/or professional contact details (addresses, telephone numbers, email addresses).

How we use the Personal Data we Process

Clients (and potential clients)

As a potential client, we will process Personal Data about you and those connected with you, for the purpose of carrying out our business and in order to:

1. respond in our legitimate interests to your enquiries about our services and/or other requests;
2. carry out due diligence or other "know-your-customer", anti-money laundering, counter-terrorist financing or anti-bribery checks in accordance with legal obligations to which we are subject or in our legitimate interests to satisfy our regulatory obligations and our own risk management procedures;
3. take steps in our legitimate interests to prevent, detect or investigate crime, fraud, misconduct or any unlawful action or omission, whether or not relating to your enquiry and whether or not there is any suspicion of any illegality;
4. enter into an agreement with you regarding the provision of services;
5. verify and carry out financial transactions in relation to the provision of the services under the agreement with you;
6. manage our infrastructure and business operations and to comply with policies and procedures that may be required by law or where necessary for our legitimate interest to satisfy other applicable industry regulation, guidelines or notices and/or that may have been put in place by us, including those relating to regulatory review and/or oversight, internal or external auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity; and
7. correspond with you concerning our present and future services and relevant news and service updates with your consent where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications.

If you become a client, we will continue to process Personal Data about you for such of the purposes described above as continue to be relevant. In addition, we will process Personal Data about you and those connected with you regarding the on-going provision of services, as described below. If you do not become a client, we will only keep Personal Data that you have made available to us if it is necessary for us to keep it for legitimate business purposes and/or as we are required to keep it by law or regulation.

If you do become a client, we will need to process Personal Data in order: under the agreement entered into between you and us to:

1. provide you with services and to administer and manage our relationship with you;
2. carry out your instructions and to respond to enquiries made by you;
3. recover any fees owed to us under our agreement with you;

under our legal obligations to:

1. collect and use certain information, for example with regard to the ownership of assets and for the purpose of the automatic exchange of information concerning tax matters;
2. carry out on-going due diligence or other "know-your-customer", anti-money laundering, counter-terrorist financing or anti-bribery checks;
3. to comply with other applicable law and regulations in the various jurisdictions in which we operate;

or in our legitimate interests:

1. to manage our infrastructure and business and to further our business interests;
2. to comply with policies and procedures under applicable professional regulation, guidelines or notices and/or that may have been put in place by us, including those relating to regulatory review and/or oversight, risk management, internal or external auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity; and
3. other purposes which we may notify you of from time to time, and obtaining your consent where necessary.

Investors, Legal and Beneficial Owners, Settlors, Protectors and Beneficiaries

If you are an investor in, or the legal or beneficial owner of, a client that is a corporate body, a partnership or an unincorporated association or body or if you are a settlor, protector or beneficiary of a trust or a founder, council member or a beneficiary of a foundation, you may be a person connected with a potential client and/or client and, as such, we will process Personal Data about you and those connected with you in order:

1. to provide services to the client with which you are connected,
2. under our legal obligations to:
   1. collect and use certain information, for example with regard to the ownership of assets and for the purpose of the automatic exchange of information concerning tax matters;
   2. carry out on-going due diligence or other "know-your-customer", anti-money laundering, counter-terrorist financing or anti-bribery checks;
   3. to comply with other applicable law and regulations in the various jurisdictions in which we operate;
3. to manage our infrastructure and business and to further our business interests;
4. to comply with policies and procedures under applicable professional regulation, guidelines or notices and/or that may have been put in place by us, including those relating to regulatory review and/or oversight, risk management, internal or external auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing and business continuity; and
5. other purposes which we may notify you of from time to time, and obtaining your consent where necessary.

Other Client-Connected People: Advisers and Regulators

If you are a person that is connected with a client or a potential client by reason of being the accountant, auditor, lawyer, banker or other adviser to that client (or potential client) or if you are a person that carries out any supervisory or regulatory function in any jurisdiction in connection with any member of the Carlisle Group or a client (or potential client) of any member of the Carlisle Group, we may process Personal Data about you and those connected with you for the purpose of our legitimate interest in carrying out our business including in providing services to the client (or potential client) with which you are connected.

Suppliers (and potential suppliers)

As a potential supplier, we will process Personal Data about you and those connected with you, for the purpose of entering into and receiving services under a contract with you relevant to carrying out our business and in order to:

1. respond to your enquiries about supplying goods or services to us;
2. conduct checks concerning standing and reputation;
3. enter into an agreement with you regarding the provision of services; and
4. correspond with you concerning your present and future goods or services.

If you do become a supplier, we will need to process Personal Data in order to:

1. administer and manage our relationship with you;
2. respond to enquiries made by you;
3. carry out on-going checks in accordance with legal or regulatory obligations and our own risk management procedures;
4. conduct and verify ongoing standing and reputation checks;
5. pay for goods and services received;
6. comply with legal or regulatory obligations, for example with regard to a regulator's outsourcing policy; and
7. for other purposes which we may notify you of from time to time, and obtaining your consent where necessary.

Potential employees

If you are an applicant for a job with us (a potential employee), we will process Personal Data about you in order, in our legitimate interests, to assess your application and to advance that application through our recruitment processes, including by making details of your application, including Personal Data, to relevant members of our management and of our HR group, and to comply with policies and procedures under applicable professional regulation, guidelines or notices and/or that may have been put in place by us, relation to staff and recruitment.

Enquirers and visitors to our website

If you have completed a form on our website, making a new business enquiry or asking a general question, indicating the services and/or jurisdictions then we will process Personal Data about you for the purpose of our legitimate interest in responding to your enquiries and/or request for information.

Likewise, if you have contacted our public relations team by email, either via the website or independently, or otherwise with a media enquiry, we will process Personal Data about you on the same grounds in order to respond to your enquiries and/or request for information.

If you or someone who works for you has given us a business card at a conference or a business meeting, we will use the contact details on the card in connection with the specific purpose it was provided. Where the card is provided for the specific purpose of requesting our promotional update communications we may first, where permitted by Applicable Data Protection Law, send an email promptly after receiving the business card, to confirm the request, clarify its scope and provide for you to complete contact preferences.

We use information about visitors to our website in our legitimate interests for internal operations, to ensure that content is presented in the most effective manner for you and your computer and to keep our website safe and secure.

Who we share Personal Data with

We may share Personal Data with:

1. Any counterpart that supports our processing of Personal Data under this policy.
2. business partners, suppliers, affiliates, agents and/or sub-contractors for the performance of any agreement we enter into with you. They may assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing IT and other support services or in other tasks, from time to time. These third parties will only use your information to the extent necessary to perform their functions.
3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Carlisle, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

Security and data retention

We have taken steps to apply appropriate technical and organisational measures to prevent the unauthorised or unlawful processing of Personal Data, and/or the accidental loss or destruction of, or damage to, Personal Data. This includes but is not limited to using properly configured and maintained firewalls and anti-virus /malware protection on servers and PCs with emails scanned for viruses and spam. As a general rule, Carlisle's IT tools and applications such as the e-mail system and the data/client/document management systems are controlled by the management but are administered by a third party IT service provider regulated by the Luxembourg regulator, the CSSF.

Carlisle has retention policies in place to meet regulatory requirements and client obligations. We retain Personal Data for the duration of the services that we provide as necessary to meet our obligations under our contractual obligations to you, to identify issues or to issue and resolve legal proceedings. We also retain Personal Data beyond the duration of the services that we provide as necessary to meet our legal and regulatory obligations to retain such information under applicable law. We may also retain aggregate information beyond this time for statistical analysis and research purposes and to help us improve our services. Old media (PC and server disks, tapes, etc.) are stored and then destroyed using a reputable specialist organisation.

Retention periods are kept under review. There may be some cases in which we are obliged to delete Personal Data we process, such as the data having been processed in breach of the Applicable Data Protection Law or to comply with a legal obligation to delete it. In other cases, there may be no specific time limit applicable to the retention of particular Personal Data and, in determining how long particular Personal Data will be retained for, we will use criteria including whether:

a- the data is no longer necessary for the purpose in relation to which it was collected; b- the data can, if required, be collected again without undue delay or difficulty.

We will not, as a general rule, seek or rely on your consent to process Personal Data about you. However, to the extent that we do on occasion rely on your consent in respect of particular Personal Data, we will cease processing that Personal Data by deleting it if you withdraw that consent at any time.

You do have the right to object to the processing of Personal Data by us on the grounds of performance of a legal task or our legitimate interest, but that objection must be on grounds relating to your particular situation. In such circumstance, we will stop processing the Personal Data in question unless: a- we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms of the individual; or b- the processing is for the establishment, exercise or defence of legal claims.

If you do object to the processing of your Personal Data by us and, as a result, we stop processing it, we may not be able to continue to provide services to you in a particular manner or at all and we may, as a result, need to terminate our service agreement with you.

Where, for example, we process your Personal Data with your consent in order to send you promotional update communications about us or our services, if you withdraw that consent, we will not be able to send you such communications.

If, as an unsuccessful job applicant you ask us to retain your Personal Data being the 6.month period for which we would normally retain it, but you later change your mind and ask us to delete it, we will not be able to refer to your original application should a potentially suitable vacancy subsequently occur.

We will delete any Personal Data no longer required, and will do so in an appropriate and secure manner.

Data Location

Carlisle stores data in on servers located in Luxembourg provided by a third party IT service provider regulated by the Luxembourg regulator, the CSSF.

Your rights

You have a number of rights under the GDPR in relation to your Personal Data.

You have the right under certain circumstances to:

1. have access to your Personal Data by making a "subject access request";
2. have your Personal Data corrected if it is wrong or, in certain circumstances, to have it deleted;
3. have the processing of your Personal Data restricted (while we verify or investigate your concerns with this information for example);
4. object to the further processing in certain circumstances of your Personal Data including the right to object to marketing;
5. request we move your provided Personal Data elsewhere (data portability);
6. to withdraw any consent that you have given us if we are processing your Personal Data only because you have given that consent; and
7. not have your Personal Data automatically processed.

Carlisle contact details

If:

1. you wish to exercise any of you rights in relation to your Personal Data;
2. you have any complaint about the way in which we process Personal Data; or
3. you require any further information about this Privacy Statement or its contents,

please contact us by email: info@cmclux.com.

Should you experience any issue, or would like to make a specific enquiry to ourselves, please contact the person responsible for the management of the Data Privacy Policy.

The contact details for the person responsible for our data protection policy are as follow:

• Carlisle Management - Attn: The Compliance Officer 9 Rue Sainte Zithe, 1st Floor, L-2763 Luxembourg. Tel. +352 268 453 59 42 - Fax. +352 268 453 59 59 Email: compliance@cmclux.com

Data protection regulator contact details

If your request or concern is not satisfactorily resolved by us you may approach your local data protection data protection authority in the jurisdiction in which we provide services to you.

The contact details for the data protection regulators Luxembourg are as follow:

• National Commission for Data Protection, 1, avenue du Rock 'n' Roll, L-4361 Esch-sur-Alzette, Luxembourg. Tel. +352 (0) 26 10 60-1. Online: https://cnpd.public.lu/en/support/contact.html

Updates

We review our policies and procedures regularly and we reserve the right to amend the terms of this Privacy Statement from time to time at our absolute discretion. Any amended Privacy Statement will be posted on our website and you are encouraged to visit our website from time to time to ensure that you are aware of our latest policies in relation to the protection of Personal Data.

Whenever you supply personal data to Carlisle concerning a third party you must ensure that the supply is in accordance with the applicable data protection laws, that where necessary, you have that persons consent to supply the information, and that this Policy has been brought to their attention.

By agreeing to these Terms and Conditions, you consent to the processing of the personal data you supply Carlisle with in accordance with our data protection policy.

Applicable Law

The website you will enter in after accepting the following conditions is subject to Luxembourg law. Any disputes arising from the website shall be submitted to the courts Luxembourg-city (Grand Duchy of Luxembourg).