PRIVACY POLICY

1. INTRODUCTION

At WIF AIFLNP V.C.I.C. LTD, we value your privacy and are committed to protecting your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This notice explains how we collect, use, store, and protect your personal data in relation to our activities as an Alternative Investment Fund for a limited number of persons.

2. What Personal Data We Collect

As part of operating the fund and fulfilling regulatory requirements, we may collect and process:

  • Identification data: name, date of birth, nationality, ID/passport numbers
  • Contact data: address, phone number, email
  • Financial data: investment amounts, bank account details, tax identification numbers
  • KYC/AML data: source of funds, investor classification, risk profile
  • Communication data: records of correspondence, meeting notes

3. Purpose and Legal Basis for Processing

We process your personal data for the following purposes:

  • Establishing and maintaining investor relationships (performance of contract)
  • Conducting anti-money laundering (AML), know your customer (KYC), and other regulatory checks (legal obligation)
  • Managing subscriptions, redemptions, distributions, and reporting (performance of contract)
  • Sending investor reports, notices, and updates (performance of contract / legitimate interest)
  • Complying with applicable laws and regulations (legal obligation)

4. Data Sharing

We may share your data with:

  • Fund administrators, custodians, auditors, and legal advisors
  • Regulators and tax authorities
  • IT and cloud service providers supporting our operations

All recipients are contractually required to process your data securely and only for specified purposes.

5. International Transfers

If personal data is transferred outside the European Economic Area (EEA), we ensure it is protected through:

  • Adequacy decisions by the European Commission
  • Standard contractual clauses approved by the European Commission
  • Other lawful transfer mechanisms under GDPR

6. Your Rights under GDPR

As an individual whose data we process, you have the right to:

  • Access your personal data
  • Request rectification of inaccurate or incomplete data
  • Request erasure (“right to be forgotten”) in certain cases
  • Restrict or object to processing under certain conditions
  • Data portability (receive your data in a structured format)
  • Withdraw consent where processing is based on consent
  • Lodge a complaint with the relevant supervisory authority

To exercise these rights, contact us at, 32 Kritis street, Papachristoforou Building, 4th Floor, 3087, Limassol, Cyprus, Tel:++357 25114000, email: rogiros@wifltd.com

7. Data Retention

We retain personal data as long as required:

  • To manage your investment
  • To comply with legal and regulatory obligations
  • For the establishment, exercise, or defense of legal claims

8. Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including encryption, access controls, and secure storage.

9. Updates to this Notice

This Privacy Policy may be updated periodically to reflect changes in law or our data practices. The latest version will always be available on request or on our website.

This Privacy Policy is governed under Cyprus Law.

Effective date: 29/07/2025