Data Protection

In accordance with the provisions of any data protection law applicable in Luxembourg (including but not limited to the law of 1st August 2018 on the organization of the National Commission for Data Protection and the general regime on data protection, as may be amended or replaced) and the EU Regulation n°2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR") (collectively hereinafter the "Data Protection Law"), Glacies Biome, the Company, acting as data controller (the "Data Controller") collects, stores and processes, by electronic or other means, the data supplied by individuals and/or prospective participants.

Personal Data We Collect

Such personal data includes:

• For individuals: name, address (including postal and/or e-mail address), banking details
• For corporate entities: name and address (including postal and/or e-mail address) of the natural person related to the entity
• Regulatory compliance data: any personal data required to comply with regulatory requirements, including tax law and foreign laws
• Health and research data: sensitive information regarding personal and health data, DNA material collection/handling/processing, image consent, and all data for research and publication purposes

Data Subjects may, at their discretion, refuse to communicate Personal Data to the Data Controller. However, in this event the Data Controller or its agents may reject subscription requests if the relevant Personal Data is necessary for the subscription process.

Purpose of Data Processing

Personal Data is processed for the following purposes:

• Maintaining the register of participants
• Processing subscriptions, redemptions and conversions of data
• Complying with applicable anti-money laundering rules and other legal obligations
• Account administration and client relationship management
• Tax identification as may be required under Luxembourg or foreign laws and regulations
• Research and publication activities related to our services

Legal Basis for Processing

The legitimate interests of the Data Controller include:

• Client relationship management and service provision
• Providing proof of transactions or commercial communications in case of disputes
• Exercising the business of the Company in accordance with reasonable market standards

Data Recipients and Transfers

The Data Controller may delegate the processing of Personal Data to other recipients, including:

• Universities and colleges
• Shareholders and partners
• Investment advisors and fund managers
• Depositaries, paying agents, and transfer agents
• Other authorized entities necessary for our operations

Recipients may be located inside or outside the European Economic Area (EEA). Where recipients are located outside the EEA in countries that do not ensure adequate protection for Personal Data, we enter into legally binding transfer agreements using EU Commission approved model clauses.

Your Rights

In accordance with Data Protection Law, you have the right to:

• Request access to your Personal Data
• Request correction of your Personal Data where it is inaccurate or incomplete
• Object to the processing of your Personal Data
• Request erasure of your Personal Data
• Request restriction of the use of your Personal Data
• Request Personal Data portability

You may exercise these rights by contacting us at:contact@glaciesbiome.lu

Filing Complaints

You have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD) at: 1, Avenue du Rock'n'Roll, L-4361 Esch-sur-Alzette, Grand-Duchy of Luxembourg, or with any competent data protection supervisory authority in your EU Member State of residence.

Data Retention

Personal Data will not be retained for a period longer than necessary for the purpose of data processing, subject to any statutory limitation periods.

Corporate Participants

Participants who are legal persons undertake and guarantee to process Personal Data and supply such Personal Data to the Company in compliance with Data Protection Law, including informing Data Subjects of the contents of this privacy policy in accordance with Articles 13 and 14 of the GDPR.

Contact Us

If you have any questions about this Privacy Policy or our data processing practices, please contact us at:contact@glaciesbiome.lu