Privacy Notice

This Privacy Notice (the "Notice") and any agreement entered into by you and Mulvaney Capital sets out the basis on which Mulvaney Capital uses your personal information. For the purposes of the General Data Protection Regulation ("GDPR") the data controller is Mulvaney Capital Management Limited, 5th Floor, 3 Moorgate Place, London EC2R 6EA United Kingdom (collectively "Mulvaney Capital").

Mulvaney Capital is committed to protecting your personal information and respecting your privacy. Mulvaney Capital will use your personal information fairly and lawfully.

If you are viewing this Notice on www.mulvaney capital.com (the "Site"), you accept that your use of the Site indicates your consent to the practices described in this Notice.

Whose personal information is collected?

Mulvaney Capital collects and uses information about the following groups of individuals:

• Clients, investors and beneficiaries (current, prospective and former) and any of their directors, officers, employees, partners, shareholders or agents;
• Suppliers and service providers;
• Professional advisers and consultants;
• Individuals who contact Mulvaney Capital by email, phone or otherwise and any visitors to the Site; and
• Employees, contractors and other members of staff (current, prospective and former).

Types of personal information

Mulvaney Capital may collect and use personal information that is:

• Directly provided by you;
• Related to services provided to you by Mulvaney Capital;
• Received from your representatives or advisers;
• Received from third parties, including administrators of products advised by Mulvaney Capital;
• Collected using cookies and other technologies when visiting the Site; or
• Sourced from public sources.

Purposes for collection of personal information

Mulvaney Capital may use the information held about you to:

• Provide you with information about Mulvaney Capital?s products, services, research or events;
• Assess your suitability for products or services;
• Process your subscription or investment in Mulvaney Capital sponsored funds;
• Fulfil any contract between you and Mulvaney Capital;
• Fulfil any legal, regulatory or self-regulatory requirement that applies to Mulvaney Capital;
• Process your job application and assess your suitability for a vacancy with Mulvaney Capital;
• Ensure that the Site is effectively presented for you and for your computer or device;
• Administer the Site; and
• Respond to any enquiry or complaint raised by you.

Mulvaney Capital may also combine any information that you provide with the information received from other sources. This combined information may be used for the purposes set out above.

Sharing your information

Mulvaney Capital may share your personal information with any other company associated with Mulvaney Capital for the purposes set out above.

Mulvaney Capital may share your personal information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract Mulvaney Capital enters into with them or you;
• Your current, prospective and former employers;
• Marketing providers that assist with the delivery of information to you;
• Analytics providers that assist in the improvement of the Site; and
• Administrators, custodians, depositaries and directors of Mulvaney Capital sponsored funds in connection with your subscription or investment in such funds.

If applicable, where you have notified us of your adviser, information provided may be shared with such adviser. You must notify us in writing if you no longer wish us to share information with your adviser or of any change to your adviser. Your adviser should have its own arrangements with you about its use of your information.

Mulvaney Capital may also share your personal information with third parties in the following circumstances:

• If Mulvaney Capital sells or buys any business or assets, it may be necessary to share your personal information with the prospective seller or buyer;
• If Mulvaney Capital is acquired by a third party, the personal information held by Mulvaney Capital will be one of the transferred assets; or
• If there is a duty to share your personal information in order to fulfil any legal, regulatory or self-regulatory requirement that applies to Mulvaney Capital and/or any member of the Mulvaney Capital group of companies.

The security of your information

Mulvaney Capital is committed to protecting information that you provide. Physical, electronic and procedural safeguards are used to protect your information against unauthorised access, disclosure or loss. Authorised access to personal information is limited to only those employees, contractors and agents with a need to know, and is subject to strict confidentiality obligations.

Where Mulvaney Capital stores your personal information

The information that Mulvaney Capital collects from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by Mulvaney Capital or Mulvaney Capital?s suppliers operating outside of the EEA for the purposes set out above. By submitting your personal information to Mulvaney Capital, you agree to this transfer, storing or processing. Mulvaney Capital will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the Notice.

Your rights

The Act gives you the right to access information held about you and to request that such information is not used for any particular purpose (for example to provide you with information about Mulvaney Capital?s products, services, research or events). You can exercise these rights by writing to:

The Compliance Officer,
Mulvaney Capital Management Limited
5th Floor
3 Moorgate Place
London EC2R 6EA
United Kingdom

Changes to this Notice

Any changes Mulvaney Capital may make to this Notice will be posted on the Site. Please check back frequently to see any updates or changes to this Notice.

Issued: May 2018