Our Commitment to Your Privacy

At Roxygen Global Investment, we prioritize the protection of your personal information. This Privacy Policy outlines how we collect, use, store, and share your data—demonstrating our commitment to safeguarding your privacy in compliance with applicable data protection laws.

We have developed this policy specifically for investors, and unless explicitly stated otherwise, we do not disclose personal information about current or former clients to third parties.

Why You’re Seeing This Policy

As an investor in one or more of our funds or managed accounts, you’ve provided us with personal information—either directly or through a representative. This may relate to you personally or, in the case of legal entities, to designated individuals such as contact persons, trustees, or beneficial owners.

This policy explains:

• How we collect, use, and protect your personal data
• The legal basis for our data processing
• Your rights under data protection laws (including GDPR)

Scope and Applicability

This policy applies to Roxygen Global Investment, its affiliated entities, and the general partners of any managed funds. When you provide your data to us, the respective fund or investment manager acts as a data controller. In some cases, other Roxygen entities may serve as data processors.

Key roles:

• Data Controllers: Determine how and why your personal data is used.
• Data Processors: Handle data on behalf of data controllers, following strict legal guidelines.

Types of Personal Information We Collect

The data we collect depends on your investor type and the specific investment involved. Common examples include:

• Contact Information: Full name, residential address, phone number, email address, and tax details.
• Identity Verification: Passport, national ID, driver’s license, date of birth, and nationality.
• Financial Details: Income, investment history, transaction records, and risk tolerance.
• Communication Records: Emails, calls, and other interactions with our team.
• Sensitive Data (as required by law): Criminal history or offenses (e.g., for AML/KYC compliance).

Sources of Information

We collect your personal data from:

1. Direct Sources: Forms, subscription documents, emails, bank details, and conversations with you.
2. Third Parties: Public databases, credit bureaus, regulators, tax authorities, compliance services, and background check providers.

Why We Collect and Process Your Data

We process personal data to:

• Fulfill contracts: Set up and manage investments, enable transactions, and deliver advisory services.
• Meet legal obligations: Perform KYC/AML checks, CRS/FATCA reporting, fraud prevention, and regulatory audits.
• Enhance client service: Customize offerings and maintain effective communication.

Your Privacy Rights

Under GDPR and similar data protection laws, you have the right to:

• Access your personal data
• Request correction or deletion
• Restrict or object to processing
• Withdraw consent (where applicable)
• Lodge a complaint with a data protection authority

You also have the right to opt out of direct marketing communications.

Who We Share Your Data With

We only share personal data with third parties when necessary for legal or operational reasons, including:

• Affiliates, advisers, and investment managers within Roxygen Global Investment
• Fund administrators, custodians, and depositories
• Legal, tax, and compliance professionals
• Financial counterparties, service providers, and banks
• Regulatory bodies, tax authorities, and enforcement agencies (when required)

International Transfers of Data

Your personal data may be transferred outside your country of residence, including to jurisdictions that may not have the same data protection standards. In such cases, we apply appropriate safeguards, such as:

• Standard contractual clauses
• Data processing agreements
• Local regulatory compliance

Security and Confidentiality

We employ physical, technical, and procedural safeguards to protect your data, including:

• Restricted access to personal data
• Encrypted storage and secure data centers
• Staff training and internal compliance procedures

We believe these measures are sufficient to prevent unauthorized access or disclosure.

Data Retention

We retain your data only as long as necessary to:

• Fulfill legal and regulatory obligations
• Manage our business relationship with you
• Meet contractual requirements

When data is no longer required, we securely dispose of it.

Providing Your Information

In most cases, providing your personal data is required for us to deliver services. If you choose not to provide requested information, we may be unable to process your investment or provide services.

Updates to This Policy

This policy is reviewed regularly. Any updates will be posted on this page and communicated directly where appropriate.