We may need to collect your Personal Data as part of your investment into our Fund(s). We want you to understand how and why we use, store and otherwise Process your Personal Data when you deal with us or our relevant affiliates.

Your Personal Data will be Processed by us for the purposes of managing the Fund. Under the applicable laws of the Jurisdictions, you have rights, and we have obligations with respect to your Personal Data. The purpose of this Notice is to explain how and why we, and persons engaged by us or the Fund, will use, store, share and otherwise Process your Personal Data. This Notice also sets out your rights under the applicable personal data protection laws of the Jurisdictions, and how you may exercise them.

This Notice is provided by the Manager.

You have certain data protection rights, including:

1. the right to be informed about the purposes for which your Personal Data are Processed;

2. the right to access your Personal Data;

3. the right to stop direct marketing;

4. the right to restrict the Processing of your Personal Data;

5. the right to have incomplete or inaccurate Personal Data corrected;

6. the right to ask us to stop Processing your Personal Data;

7. the right to be informed of a Personal Data breach (unless the breach is unlikely to be prejudicial to you);

8. the right to complain to the relevant data protection authority of the respective Jurisdiction; and

9. the right to require us to delete your Personal Data in some limited circumstances.

This Notice shall be governed by, and construed in accordance with, the applicable laws of the Jurisdictions.

We act as a "data controller" in respect of your Personal Data. This means that we are the decision maker as to the purposes, conditions and manner in which your Personal Data are Processed, including:

how to use, store, and Process your Personal Data;

with whom to share your Personal Data;

when to modify or erase your Personal Data;

when to engage one or more third parties to Process your Personal Data; and

which such third parties to engage.

We will continue to be the data controller even where we or the Fund have engaged third parties, such as the Administrator, to perform certain Processing activities for the Fund.

We collect your Personal Data from a number of sources, (both foreign as well as domestic), including from you directly. These sources include:

from the forms and any associated documentation that you complete when subscribing for units in the Fund;

when you provide it to us or our service providers in correspondence and conversations (including by email);

when you make transactions with respect to the Fund;

when you provide remittance instructions;publicly available and accessible directories and sources, including websites;

bankruptcy registers;tax authorities;

governmental agencies and departments, and regulatory authorities, to whom we have regulatory obligations;

credit reference agencies; and fraud prevention and detection agencies and organisations, including law enforcement.

The principal purposes for which your Personal Data is Processed (collectively the “Purposes”) include (without limitation) the following:

1. The Processing is necessary for the performance of a contract, including: (a) administering or managing the Fund; (b) processing your subscription and investment in the Fund, such as entering your information in the register of unitholders; (c) sending you statements relating to your investment; (d) facilitating the continuation or termination of the contractual relationship between you and the Fund; and (e) facilitating the transfer of funds, and administering and facilitating any other transaction, between you and the Fund.

2. The Processing is necessary for compliance with applicable legal or regulatory obligations, including: (a) undertaking investor due diligence, and on-boarding checks; (b) carrying out know your client, anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors (and, where applicable, their beneficial owners); (c) complying with requests from regulatory, governmental, tax and law enforcement authorities; (d) surveillance and investigation activities; (e) carrying out audit checks, and instructing our auditors; (f) maintaining statutory registers; (g) preventing and detecting fraud; (h) complying with the United States Foreign Account Tax Compliance Act, the Organisation for Economic Co-Operation and Development Common Reporting Standard and other comparable legislation; and (i) complying with applicable sanctions and embargo legislation.

3. In pursuance of our legitimate interests, or those of a third party to whom your Personal Data are disclosed, including: (a) complying with any legal, tax, accounting or regulatory obligation to which we or the third party are subject; (b) assessing and processing requests you make; (c) sending updates, information and notices or otherwise corresponding with you in connection with your investment in the Fund; (d) investigating any complaints, or pursuing or defending any claims, proceedings or disputes (whether domestic or foreign); (e) providing you with, and informing you about, our investment products and services; (f) managing our risk and operations; (g) complying with audit requirements; (h) ensuring internal compliance with our policies and procedures, as applicable; (i) protecting our business against fraud, breach of confidence or theft of proprietary materials; (j) seeking professional advice, including legal advice; (k) facilitating business asset transactions involving the Fund or related entities; (l) monitoring communications to/from us (where permitted by law); and (m) protecting the security and integrity of our Information Technology systems, but in all cases only where we have considered that the Processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.

We may share your Personal Data with:

1. The Administrator and their respective affiliates for the Purposes set out in this Notice, in particular: (a) managing our relationship with you; (b) delivering the services you require; (c) managing your investment; (d) supporting and administering investment-related activities; (e) complying with applicable investment laws and regulations; (f) delivering and facilitating the services needed to support our business relationship with you; (g) supporting and administering investment-related activities; (h) tax authorities; (i) to comply with applicable laws and regulations; and (j) where required by tax authorities (who, in turn, may share your Personal Data with other tax authorities),

2. our lawyers, auditors, banking service providers and other professional advisors for the Purposes of: (a) providing you with investment-related services; (b) enabling us to meet legal and regulatory obligations in obtaining services; and (c) seeking advice on, and complying with, legal and regulatory requirements or legal rights and obligations,

3. any of our directors, officers, employees, representatives, agents or delegates,

4. any of our shareholders or related corporations, and any of their successors or assigns, and their directors, officers, employees, representatives, agents or delegates,

5. any service providers, agents, contractors, delegates, suppliers or third parties which we may appoint from time to time to provide us with services in connection with the Fund, and their directors, officers, employees, representatives, agents or delegates,

6. any sub-contractors which any of our service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the Fund, and their directors, officers, employees, representatives, agents or delegates,

7. anyone who takes over or may take over all or part of our rights or obligations under any agreement we have with you (or any part thereof),

8. any relevant governmental or regulatory authority, in order to comply with any applicable laws, or which we in good faith believe that we should comply with,

9. pursuant to a request by any relevant governmental or regulatory authority (regardless of the reason for such request and whether such request is exercised under a court order or otherwise),

10. any parties in litigation (whether pending or threatened) in any jurisdiction,

11. parties which assist us in carrying out the Purposes set out herein, and

12. any person to whom we in good faith believe we are under an obligation to make the disclosure as required by any applicable laws.

We will not sell your Personal Data.

Some of the Personal Data we request must be supplied for an investment in the Fund to be made, and for that investment in the Fund to continue. Some Personal Data must be supplied to us to enable the investment to be redeemed. If you do not wish to provide us with this Personal Data, you will not be able to invest in the Fund as it will affect our ability to provide our services to you and manage your investment.

You may at any time withdraw your consent given for any or all of the Purposes in writing to our Data Protection Officer at the contact details set out herein. If you withdraw consent for any or all of the Purposes and depending on the nature of your request, we may not be in a position to allow your investment in the Fund to continue. In certain circumstances, your withdrawal may be considered a termination by you of any contractual relationship with us, and may result in a breach of your contractual obligations or undertakings, and our legal rights and remedies in such an event are expressly reserved.

If you supply to us Personal Data on behalf of another individual, you shall ensure that you have notified such individual of the Purposes for which we require that individual’s Personal Data and obtained that individual’s consent to his/her Personal Data being supplied by you to us for the Purposes set out in this Notice.

As we rely on your Personal Data provided for the Purposes set out herein, by supplying your Personal Data to us and/or continuing your investment in the Fund you agree to ensure that at all times the Personal Data provided is correct, accurate and complete. You shall update us in a timely manner of any change to the Personal Data provided.

The provisions set out in this Notice do not derogate from any terms of any agreement that governs a specific relationship we have with you, which may include terms relating to personal data protection. Our rights as set out in this Notice shall also be without prejudice to other rights of collection, use and/or disclosure of your Personal Data pursuant to any agreement we have with you or under any applicable law.

We may transfer, store, process and/or deal with your Personal Data outside the Jurisdictions. Not all countries have data protection and privacy laws that provide you with the same or a comparable degree of protection as the Jurisdictions. Where we transfer your Personal Data to our service providers, including the Administrator, we have made best endeavours to ensure that appropriate arrangements are in place so as to provide your Personal Data with the same protections that exist under the applicable laws of the Jurisdictions.

We will keep your Personal Data for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will generally retain your Personal Data throughout the lifecycle of the investment you are involved in. Some Personal Data will be retained after your relationship with us ends. We expect to delete your Personal Data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your Personal Data.

You may request access to your Personal Data that we hold, or request for the rectification of any inaccurate data. If you would like to do so, please contact our Data Protection Officer via the contact details set out herein.

We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated Processing of your Personal Data, unless we have considered the proposed Processing in a particular case and concluded in writing that it meets the requirements of the applicable laws of the Jurisdictions.

Our website may use cookies. A cookie is a small text file placed on your computer, system or mobile device when you visit a website. Cookies collect information about users and their visit to the website or use of the website, such as their IP address, how they arrived at the website (for example, through a search engine or a link from another web site) and how they navigate within the website. We may use cookies and other technologies to facilitate your internet sessions and use of our website, offer you products and/or services according to your preferred settings, track use of our website and to compile statistics about activities carried out on our website.

You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our website.

Our website may contain links to other websites which are not maintained by us. This Notice only applies to our website and our services. When visiting these third party websites, you should read their privacy policies which will apply to your use of their websites.

We are committed to Processing your Personal Data lawfully and to respecting your data protection rights. Please contact our Data Protection Officer at the contact details set out below (and mark your communication “Data Protection Enquiry”) if you have any questions about this Notice or the Personal Data we hold in relation to you.

FOUR SEASONS ASIA INVESTMENT PTE. LTD. MAS Capital Markets Services Licence: CMS100269-1

163 Penang Road, #04-02 Winsland House II Singapore 238463

Tel: 65-6235-1534 Fax: 65-6235-2865 Email: fsaicomp@fourseasons-invest.com

This notice will be kept under regular review. Should there be any material changes to this Notice, we will post the updated version on this page and you will be notified. If you continue to use our services, continue your investment in the Fund and/or continue to provide your Personal Data to us, you are deemed to have agreed to such changes without reservation.