#### Privacy-policy

## Data Privacy Notice

Last updated: 06/2020

As a data controller, prosperi Investment (“prosperi Investment or “we”, Seidlstr. 24-24a, 80335 Munich, Germany) would like to thank you for visiting our website (“website”) and for your interest in our services and products.

Your privacy is important to us and we want you to feel comfortable when visiting our site. We take steps to ensure that your personal data, (i.e. any items of information concerning the personal or material circumstances of an identified or identifiable natural person) collected, processed and used in connection with your visit to our website will be protected. Unless you have received a personal email from us, we permit the anonymous use of the website, or the use of the site under a pseudonym as far as technically possible and reasonable.

This Data Privacy Notice may be updated from time to time. We therefore ask you to consult it regularly.

We have created this Data Privacy Notice to explain how and why specific types of personal data are collected from users of this website, are processed and used. This Data Privacy Notice also provides an overview of the use of data that is publicly available on other websites and sources and of the appropriate protection measures taken to safeguard your personal data.

### What is the purpose and scope of this Data Privacy Notice?

This Data Privacy Notice applies to all personal data collected, processed and used by prosperi Investment when you visit the website and for the use of data that is publicly available on other websites and sources. It does not apply to websites controlled by third parties to which the website may contain links (“third-party websites").

Please check the data privacy notices of third-party sites, as prosperi Investment is not responsible for the content or privacy measures of third-party sites and has no control over them.

The content of this Data Privacy Notice may also be subject to any additional conditions or disclaimers or other contractual terms that you have entered with prosperi Investment , as well as any applicable and binding laws and regulations.

### What information do we collect from you and for what purposes?

When you visit the website, our web server automatically records details of your visit, so-called "Usage Data” (for example your IP address, the website from which you linked to our website, the type of browser software used, the individual sub-pages of the website that you actually accessed, the date and duration of your visit.

We also collect, process and use personal data that you provide through the website, such as personal details (i.e. name, gender, address, email address, telephone/fax number) that you enter on a login page or when you subscribe to an email newsletter or when you apply for a job at prosperi Investment online ("User Data").

We also receive certain data from our affiliate prosperi Investment of America LLC ("prosperi Investment of America") that stems from publicly available sources (e.g. freely available on the Internet) ("Analytical Data"), inter alia to evaluate and prepare investment decisions as well as client meetings. Analytical Data regularly do not contain personal data, but this cannot be excluded for all Analysis Data.

prosperi Investment collects, processes and uses Usage Data and User Data for:

- the purposes of technical administration and research and development of the website;
- customer and user management;
- marketing, to inform you about our services and products;
- online application processes

### On what legal basis do we process the data, and for how long do we store your personal data?

Your Usage Data and User Data is processed in accordance with the above-mentioned purposes for the completion of (pre-)contractual measures (Article 6(1)(b) GDPR) and to pursue our legitimate interests (Article 6(1)(f) GDPR), such as the further development of the website or marketing.

As far as Analysis Data contain personal data, we process such data to pursue our legitimate interests (Art. 6(1)(f) GDPR). We want to better prepare investment decisions as well as client meetings and can carry out more precise assessments in advance of these decisions/meetings based on the Analysis Data to improve our services provided to you. If we intend to process Analysis Data for other purposes, in particular for the performance of a contractual relationship, we will inform the data subjects separately if necessary.

We store your personal data for as long as we need it to achieve these objectives. As soon as we no longer need your personal data for the purposes mentioned, we will delete the data from our systems, unless we are legally obliged to store it.

### How do we use tracking technologies?

prosperi Investment uses tracking technologies such as cookies and tags. For details on how we use cookies and similar technologies, especially for the purposes of marketing, market and opinion research, please refer to our Cookie Policy.

### Who do we share your information with?

For the purposes of providing services to prosperi Investment , and for the other purposes set out above, prosperi Investment may share your information with affiliates and representatives of prosperi Investment , and third parties such as marketing agencies or web analytics service providers within and outside of your country of residence.

Our affiliates, representatives and third parties who have access to the personal data collected, processed and used via the website are obliged to observe data protection regulations.

Your personal data may be transferred to recipients in countries outside the European Union or the European Economic Area, which may have a lower level of data protection. Unless the EU Commission has already established an adequate level of data protection for such a recipient country, we ensure that the recipients of your personal data comply with such an appropriate level, in particular, by implementing contractual safeguards such as standard contractual clauses for data transfers which are approved by the European Commission and can be accessed here.

Whenever we transfer your Personal Data within the prosperi Investment Group to an OE outside of the EU / EEA, we will do so on the basis of prosperi Investment’ approved binding corporate rules known as the prosperi Investment Privacy Standard (“prosperi Investment’ BCR”) which establish adequate protection for Personal Data and are legally binding on all prosperi Investment Group companies. prosperi Investment’ BCR and the list of prosperi Investment Group companies that comply with them can be accessed here: https://www.prosperi Investment.com/en/info/privacy-statement/.

We may also share your information with government agencies and institutions, regulators, etc. in accordance with the applicable laws, regulations, a court order or an official request, or in accordance with and for the purposes of official (regulatory) policies or similar procedures as required or permitted by applicable law.

### What security measures have we implemented to protect your information we collected through our website?

prosperi Investment has implemented appropriate technical and organisational security measures to protect your personal data that prosperi Investment has collected from unauthorised access, misuse, loss and destruction.

### How do we handle electronic messages sent to and from prosperi Investment ?

All electronic messages sent to and from prosperi Investment are protected by appropriate technical and organisational measures within our systems, and may only be accessed by individuals not directly involved in the communication in specific, justified cases according to the applicable laws and regulations (e.g. a court ruling, suspected criminal behaviour, breach of supervisory obligations); they are only accessed by certain individuals in defined functions (e.g. legal, compliance, risk). Each part of the procedure and the search criteria used are logged.

### What should you bear in mind when sending data over the internet?

The internet is generally not considered to be a secure environment, and information sent via the internet (such as to or from the website, or as an electronic message) may be intercepted by unauthorised third parties, which may lead to divulging information, changes to content or technical failure. Even if both the sender and the recipient are located in the same country, data sent via the internet may be transmitted across international borders and forwarded to a country where the level of privacy is lower than in your country of residence.

Please note that we do not accept any responsibility or liability for the security of your data while it is being transmitted via the internet to prosperi Investment . To protect your privacy, we remind you that you can use other means of communication with prosperi Investment where appropriate.

### How can you exercise your rights as a user?

Where permitted by law, you have the right to:

- Request information about your personal data, including information such as the source and categories of data, reasons for processing, recipients (or categories of recipients) and the retention period;
- Update or correct your personal data so that it is always correct;
- Have your personal data supplied in an electronic format, to you or to a third party specified by you;
- Request that your personal data be deleted from our systems, once it is no longer required for the above-mentioned purposes;
- Restrict the processing of your personal data under certain circumstances, e.g. if you dispute the accuracy of your personal data, until we have verified its accuracy;
- Withdraw your consent at any time, if your personal data is being processed with your consent, without this affecting the lawfulness of the processing that took place before your consent was withdrawn;
- File a complaint with us or the relevant data protection authority.

In addition, you have the right to object to the processing of your personal data on grounds relating to your particular situation, which prevail over our legitimate reasons for processing. In such cases, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.

You may object to the use of your personal data for the purposes of marketing and market research or opinion polling.

Please contact us if you have any questions or comments regarding privacy or to exercise your aforementioned rights:

or send an email to:
support@prosperi-invests.com

## prosperi Investment Cookie Policy

Last Updated: 06/2020

Through this Cookie Policy we, prosperi Investment , Seidlstr. 24-24a, 80335 Munich, Germany (“prosperi Investment ” or “we”), inform you about how we use cookies and similar technologies on our website (“website”). For more information on how we collect, process and use personal data, please see our Data Privacy Notice.

### Cookies and Similar Technologies

We use cookies to make our website function smoothly and optimally for our users and to continuously improve its operation. Cookies are small text files that contain a sequence of alphanumeric characters, which are stored on your device. We use both session cookies and persistent cookies. A session cookie is deleted when you close your internet browser. A persistent cookie remains stored even after the internet browser has been closed and can be used by your internet browser on subsequent visits to our website. Your internet browser may well offer settings for cookies. Please note that you may not be able to make full use of the features in the services offered on our website if you either delete cookies or choose not to allow them. We also use third-party cookies in connection with the services provided through our website. For example, we use Google Analytics to collect and process certain analytical data. We may not process or react to “Do not track” signals from internet browsers or similar processes that indicate that a user visiting our website or using the services provided through our website does not want to be tracked online. A list of the cookies used on our website, including their purpose and the data stored in each case, can be found in the table below. Your consent to the intended use is required before placing and using cookies on your device. This consent can be given by the cookie preference center or / and adjusting your browser settings accordingly.

Clear GIFs/Web Beacons. Clear GIFs (also known as web beacons) are typically very small transparent graphics (typically 1 pixel x 1 pixel) used on a website which can be used within the scope of the services we offer on our website and are typically used in conjunction with cookies to track our users and their usage patterns.

### How we use cookies and similar technologies

We use cookies and collect information in order to: (1) personalise our website and the services we offer on our website, e.g. to save data related to you so that you do not need to re-enter this data while using our website, or on your next visit to our website or when you use services provided on the website; (2) provide you with customised advertising, content and information; (3) monitor and analyse the effectiveness of our website and the services provided on our website, as well as third party promotional activities; (4) produce aggregate usage statistics, such as total number of visitors and page views; and (5) track your entries and the status of promotions or other activities and services offered via our website. Tracking technologies also help us to maintain and improve the usability of the website (1) by determining whether there has been any contact between your computer and us in the past, and (2) by identifying the most popular areas of our website.

## prosperi Investment Privacy Standard (APS)

The prosperi Investment Privacy Standard constitutes prosperi Investment’ Binding Corporate Rules (BCRs) and provides you with information on the rules governing the international transfer of personal data between prosperi Investment Group companies operating in the European Economic Area (EEA) and prosperi Investment Group companies outside that area.

The prosperi Investment Privacy Standard also describes your rights in respect of such transfers, what to do if you want to exercise your rights or complain about such transfers, and how to contact us.

### prosperi Investment Privacy Standard (APS) Companies

prosperi Investment Group companies are required to implement the prosperi Investment Privacy Standard. An up-to-date list of prosperi Investment Group companies who have committed to comply with the prosperi Investment Privacy Standard is available here: