This privacy notice aims to give you information on how Sequoia collects and processes your personal data through your use of this website and through any subscriptions, including any data you may provide through this website when you sign up to our materials. This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Sequoia Investment Management Company Limited is the controller and responsible for your personal data (collectively referred to as ”Sequoia”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Full name of legal entity: Sequoia Investment Management Company Limited

Name or title of data privacy manager: Dolf Kohnhorst

Email address: d.kohnhorst@seqimco.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Any changes to this privacy policy will be posted on this site and where appropriate notified to you in writing.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password.
• Usage Data includes information about how you use our website

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

We use different methods to collect data from and about you including through:

2. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   1. create an account on our website;
   2. subscribe to our service or publications;
   3. request marketing to be sent to you;

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

3. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   1. Where we need to perform the contract we are about to enter into or have entered into with you.
   2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   3. Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data but where we do, you have the right to withdraw consent at any time by Contacting us.

3.3 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

3.4 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie policy.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties who will be members of Sequoia.
• External Third Parties including Alternative Investment Fund Managers; website developers; and legal counsel, who may receive personal data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

Under certain circumstances, you have rights under data protection laws in relation to your personal data which are:

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Cookies and IP Addresses

When you visit our website, we may send you a cookie. A cookie is a small file which is placed on your computer or device.

1. Essential Cookies

These cookies are essential for the running of our website. Without the use of these cookies parts of our websites would not function.

2. Analytical Performance Cookies

We use these types of cookies to monitor our website’s performance and how their users may use it. These cookies provide us with information that helps us improve our users experience on site. This allows us to provide a better service and also to identify any areas that may need maintenance.

3. Functional Cookies

Functional cookies are used to remember your preferences on our websites. This can be anything from remembering what products or options you have selected to saving your username.

4. Third Party Cookies

This site may use Third Party Cookies which are provided by our advertisers.

We cannot control nor do we have access to any cookies placed on your computer by third party advertisers and sponsors. Please see information under ‘How to control the use of cookies’, for more information on how to disable these cookies.

How to control the use of cookies

You are not obliged to accept cookies and may modify your browser so that it will not accept cookies. The browser you use to surf the web not only allows you to see the cookies that you have got but also allows you to control their use.

You can control them by allowing them, deleting them individually or deleting all of them. You can also set your browser to not accept cookies altogether. If this option is selected, you should be aware that many websites will not function properly or at all. It may be possible to set your browser to not accept cookies and ask for your consent before each cookie is set on your device. This gives you control over what is set on your device, however has the drawback of slowing down your browsing experience.

There are different levels of control too. You are able to prevent just third party cookies being deployed, effectively opting out of behavioural advertising, and some even allow you to block specific companies you do not wish to deploy a cookie, instead of selecting all companies.

In order to manage your cookies, please select your browser from the list below and follow the instructions:

• Internet Explorer
• Chrome
• Safari
• Firefox
• Opera

Mobile devices:

• Android
• Safari
• Windows Phone
• Blackberry

Flash Cookies

When you use a website that uses Macromedia Flash Player, a small Flash Cookie may be used. The purpose of using these cookies is to store your flash player preferences and enhance your browsing experience.

Flash Cookies are stored on your computer in a similar way to standard cookies, except they are stored in a different location. Due to this, it is not possible to block or manage Flash Cookies directly from your browser.

In order to manage or delete Flash Cookies, please visit Adobe’s website, which provides full information by clicking here.

Useful information about Cookies

Further information about cookies can be found on the following websites:

• All About Cookies
• Your Online Choices
• Information Commissioners Office
• Direct Marketing Association

Web Beacons and URL tracking

As part of our email communications and website analyses, we may use web beacons and track URL’s.

Web beacons are electronic files that count users who access a website or page and can also allow us to see if a cookie has been activated. Web beacons on web pages or email communications allow us to see how successful a webpage may be or that an email message was successfully delivered and read.

Tracked URLs will count the amount of clicks on a web page. This allows us to edit the site according to the popularity of these web pages.

You can’t decline web beacons, however by preventing cookies being used on your computer; you can prevent web beacons from tracking your activity. For information about managing your cookie options, please click here.

Please be aware that if you disable cookies, certain services on our website will not be available to you, particularly those sections that contain personalised content.

Google Analytics

This website does use Google Analytics. Google Analytics provides us with information to improve our users experience on site. This allows us to provide a better service and also to identify any areas that may need maintenance.

For more information on the Cookies which Google’s tracking tool uses please see below.

• Cookies and Google Analytics