Privacy Notice

1. Introduction

Nordlink Capital Limited ("Nordlink Capital", "we", "us" or "our") is committed to protecting personal data and respecting the privacy of individuals with whom we conduct business.

This Privacy Notice explains how we collect, use, share and protect personal information in connection with our institutional investor introduction and placement agent services.

We process personal data in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 ("PECR"), as amended. Where applicable, we also comply with the EU General Data Protection Regulation ("EU GDPR").

Nordlink Capital Limited is the data controller of personal data processed for its own business purposes.

2. Personal Data We Collect

We may collect and process the following categories of personal information:

• Professional identification: Names, job titles, employers, professional contact details and business affiliations.
• Investment-related information: Institutional investment mandates, investment preferences, asset allocation interests, investment responsibilities and professional experience.
• Business communications: Correspondence, meeting records, investor introductions, roadshow participation and related professional communications.
• Client and contractual information: Information necessary to establish, manage and administer business relationships and client engagements.
• Website information: Technical information, including IP addresses, browser information and website usage data where collected.

We obtain personal data directly from individuals, their employers or representatives, professional relationships, business correspondence and publicly available sources, including corporate websites and professional directories.

We generally do not seek to collect special category personal data unless necessary for a specific lawful purpose.

3. How We Use Personal Data

We process personal data for the following purposes:

• Maintaining relationships with institutional investors, investment managers, fund managers, investment sponsors and other professional counterparties.
• Identifying relevant investment strategies and facilitating institutional investor introductions.
• Organising institutional roadshows, meetings and investment presentations.
• Communicating investment strategy, market, portfolio and fund updates.
• Managing client engagements, commercial agreements and business relationships.
• Conducting institutional marketing and business development activities.
• Maintaining and securing our website, systems and business records.
• Complying with applicable legal, regulatory and contractual obligations.

4. Lawful Basis for Processing

Under the UK GDPR, we rely on one or more of the following lawful bases, as appropriate:

• Legitimate Interests: To develop and maintain professional relationships, identify appropriate institutional counterparties, facilitate introductions, communicate relevant business opportunities and operate our business, provided such interests are not overridden by individuals' rights and freedoms.
• Contractual Necessity: Where processing is necessary to perform a contract with an individual or take steps at their request before entering into a contract.
• Legal Obligation: Where processing is necessary to comply with applicable legal or regulatory requirements.
• Consent: Where we specifically request consent for particular processing activities, including certain electronic communications or website technologies.

Where the relevant individual is a representative of a corporate client, processing their professional contact information will generally be based on legitimate interests rather than contractual necessity.

5. Institutional Communications and Marketing

Nordlink Capital may contact institutional investors and professional business contacts regarding relevant investment strategies, fund launches, institutional roadshows, market updates and other business opportunities.

Such communications are directed at institutional and professional business relationships and are conducted in accordance with applicable data protection and electronic marketing requirements.

Individuals may object to direct marketing at any time by contacting us at linda@nordlinkcapital.com or by using an unsubscribe facility where provided.

We will respect objections to direct marketing and maintain appropriate suppression records to prevent further unwanted communications.

6. Sharing Personal Data

We may share relevant professional information with:

• Investment managers, fund managers, sponsors and institutional investors where appropriate to facilitate introductions and business relationships.
• Service providers supporting our IT systems, communications, website hosting and business administration.
• Professional advisers, including legal advisers, accountants and auditors.
• Regulators, public authorities and other parties where disclosure is required by law.

We limit personal data sharing to information reasonably necessary for the relevant purpose and apply appropriate safeguards.

We do not sell personal data to third parties.

7. International Data Transfers

Our activities involve institutional investors and investment managers in the United Kingdom, the Nordic countries and other international markets.

Where personal data is transferred internationally, we comply with applicable UK and, where relevant, EU data protection requirements.

Where required, we rely on applicable adequacy regulations or decisions, recognised contractual safeguards, including the UK International Data Transfer Agreement or UK Addendum to EU Standard Contractual Clauses, or another lawful transfer mechanism.

Information about applicable transfer safeguards may be requested using the contact details below.

8. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including maintaining relevant professional relationships, administering client engagements, complying with legal obligations and establishing or defending legal claims.

Retention periods are determined by the nature of the information, the purpose of processing, applicable legal requirements and the continuing relevance of professional relationships.

We periodically review the personal data we hold and delete, anonymise or update information that is no longer necessary.

Individuals may request further information about applicable retention periods using the contact details below.

9. Data Security

We maintain appropriate technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, misuse, alteration or disclosure.

Access to personal information is restricted to authorised persons with a legitimate business need.

10. Your Data Protection Rights

Subject to applicable law, individuals have the right to:

• Request access to personal data held about them.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal data in applicable circumstances.
• Request restriction of certain processing activities.
• Object to processing based on legitimate interests.
• Object to direct marketing at any time.
• Request data portability where applicable.
• Withdraw consent where processing is based on consent.

We do not intend to make solely automated decisions about individuals that produce legal or similarly significant effects.

To exercise your rights, please contact linda@nordlinkcapital.com.

You may also raise a complaint with the UK Information Commissioner's Office (ICO) at www.ico.org.uk. Where EU GDPR applies, you may have the right to complain to a relevant EEA supervisory authority.

11. Cookies and Website Technologies

Our website may use cookies and similar technologies for essential website operation, security, functionality and website analytics.

Where consent is legally required, non-essential cookies and similar technologies will not be used unless appropriate consent has been obtained.

Information about cookies in use, their purposes, providers and applicable retention periods will be made available through our website's cookie information and controls.

12. Changes to This Notice

We may update this Privacy Notice periodically to reflect changes in our activities, applicable legislation or data protection practices.

The latest version will be published on our website, and material changes will be communicated where required by law.

13. Contact Information

For any questions regarding this Privacy Notice, the processing of personal data or the exercise of your data protection rights, please contact:

Nordlink Capital Limited
Office 140, 128 Aldersgate Street
London EC1A 4AE
United Kingdom
Email: linda@nordlinkcapital.com
Website: www.nordlinkcapital.com