Privacy Policy

Commitment to Privacy

Excellar International SAC Ltd. (collectively “us” “our” and “we”) is committed to being a responsible custodian of the information you provide to us and the information we collect in the course of operating our business and providing legal services.

This Privacy Notice explains how we collect, use, disclose documents and our commitment to protecting your personal information. This policy is governed by the laws of Bermuda, Bermuda’s Personal Information Protection Act 2016, as amended (“PIPA”).

“Personal information” is defined in PIPA as any information that can be used to identify you or that we can link to you as an individual and may include:

• full name, date of birth, passport, driving licence or other photographic identity details;

• contact information including postal or residential address, email address and telephone number(s);

• information related to your financial position;

• information related to your employment status; and

• information related to your national origin and marital status.

We shall not use sensitive personal information relating to an individual’s place of origin, race, colour, national or ethnic origin, sex, sexual orientation, marital status, physical or mental disability, physical or mental health, family status, religious beliefs, political beliefs or opinions, trade union membership, biometric information or genetic information in order to discriminate against any person contrary to the provision of Part II of the Bermuda Human Rights Act 1981.

Responsibility

We are responsible for personal information in our possession or control. Ya Li is designated as our Privacy Officer and is responsible for compliance with this Privacy Policy, and may be contacted at [email protected]. We have implemented a procedure that protects personal information, handles complaints and inquiries, trains staff on policies and procedures and communicates our policies to you. We will continuously monitor developments in privacy legislation and update our Privacy Notice as required.

Purposes

We may come into the possession of personal information in order to provide professional services. Your personal information may be used for the following purposes:

• to meet our regulatory, legal and professional obligations, including undertaking appropriate anti-money laundering checks; • to establish and manage our relationship with you;

• to monitor and manage the performance of our business operations;

• to manage conflicts of interest and maintain our list of contacts;

• to engage in business transactions; and

• for any other purposes for which we have your consent.

Your personal information may be transferred between our servers and our services providers. We may, from time to time, use third parties in which event we will use reasonable efforts to confirm that the agreement with such vendor protects the privacy of information in accordance with this Privacy Notice and/or seek an agreement from third party vendors to be bound by the terms of this Privacy Notice or a similar policy.

Consent

You consent to us using your personal information for the purposes identified above and to making any necessary cross-border transfers of your personal information. Your personal information may be shared with third parties for the purposes described in this Privacy Notice.

Limits on Collection, Use, Retention and Disclosure of Personal Information

We collect and use only that personal information which is required by us to operate our business and as set out in this Privacy Notice.

We do not sell, rent, or otherwise share any information with unaffiliated entities except as expressly described in this Privacy notice or with your prior permission. We may share anonymised information that does not reasonably identify you or your organisation only as permitted by applicable law.

We do not retain any more of your personal information than we believe is necessary for any of the purposes set out in this Privacy Notice or which is dictated by legal or professional requirements. We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information or retention is no longer necessary for legal, business or professional purposes. We will take reasonable care when destroying personal information so as to prevent unauthorised access to the personal information.

Accuracy

You are required to advise us of any changes that may impact the services we are providing. From time to time, you may be asked to verify or update your personal information.

Safeguarding Personal Information

We protect the personal information in its custody or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification or disposal. We have developed, implemented and will maintain safeguards (including use of encryption where feasible) appropriate to our size, scope and business, our available resources, the amount of personal information that we own or maintain on behalf of others and the risks we have identified. We will regularly evaluate and test the effectiveness of those safeguards to ensure security of the data.

Confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. We will not be responsible for any loss or damage suffered as a result of a breach of security and/or confidentiality when information is transmitted by e-mail or wireless communication. We will take your use of a particular mode of communication to be implied consent for us to communicate with you using the same mode of communication unless otherwise instructed by you.

In case of a data breach likely to adversely affect an individual, we will promptly report it to relevant authorities and the affected individuals without undue delay.

Providing Access

You have a right to access your personal information held by us. Your information will be provided within a reasonable time upon written request and authentication of identity. We may charge a reasonable fee for providing information in response to a privacy access request and will provide an estimate of any such fee upon request.

Thank you for trusting us with your personal information. We are committed to protecting your privacy and ensuring your data is handled with care.

We reserve the right to amend this Privacy Notice from time to time without prior notice to you.

Excellar is committed to safeguarding your personal information. We do not sell users' non-public personal information to anyone and only share it as described in this notice.