Memorandum on Privacy

The following information is confidential, private and subject to intangible property rights. All rights to its use, rights, obligations and incomes stipulated by existing contracts, claims, and works in progress also belong to the Anders Capital GMbH (Austria) (hereinafter referred to as the Company).

The Recipient of this document hereby understands and acknowledges that the confidential Information has been developed or obtained by the Company through an investment of considerable time, effort and expense. The Recipient of this document shall keep secret any confidential Information and the very fact of its existence and shall not disclose, copy, deliver it via e-mail, voice or other means of communications or make use of it in behalf of third persons without the prior written consent of the Company.

Prior to further examination of the details, terms and conditions of the sale of mentioned herein business and/or purchase of the ownership rights to real estate sites, plants, shares specified in the present document, the Recipient must take into account the high risk of this development. The risk is influenced by the factors which are beyond the control of the Company’s management and include but are not limited to inflation, political crisis, unpredictable rates of economic development of the region, or unpredictable changes in the tax regulations and financial laws.

The assumptions contained herein may not prove to be correct and therefore no assurance can be made that any goals, financial results and the market position of the Company are attainable or will be realized. The Company’s management believes that the Recipient is competent, experienced and well informed to analyze all risks specific to the Company’s operations and obtain support from his legal, financial, audit and other professional advisers.

This document has been prepared by the Company solely for information purposes and is not a solicitation, or an offer, to buy or sell any securities, rights or property. The document does not purport to be a complete description of the rights, assets, markets or developments referred herein.

The information upon which the document is based has been obtained from sources, which are believed to be reliable and adequate, but the information has not been verified.

The Recipient should verify the information presented in this document. Recipient and/or its subsidiaries may make use of any of the information presented in this document and/or any of the information upon which it is based prior to its publication. The recipient of its own judgment should not regard the document as a substitute for the exercise. Additional information with respect to the projects referred to herein is available on the Recipient’s request.

Privacy Policy

1.  Name and contact details of the controller

This data protection information applies to data processing by:

FINHUB CAPITAL FUND S.C.Sp.
(Luxembourg) Company nr. B246268

26, Boulevard Royal Luxembourg,

2449 Luxembourg

Phone: +352 20331445

E-Mail: info@finhubfund.com

2. Collection and storage of personal data as well as the nature and purpose of their use

a) When the website is visited

When you visit our website www.finhubfund.com, the browser used on your end device

automatically sends information to our website server, where it is stored temporarily in a log file. The

following information is collected as part of this, without any action on your part, and stored until

automatic deletion:

• The IP address of the computer accessing the website,
• The date and time of access,
• The name and URL of the retrieved file,
• The website from which access was made (referrer URL),
• The browser used and, where applicable, your computer’s operating system as well as the

name of your access provider.

We process the mentioned data for the following purposes:

• To ensure the straightforward establishment of a connection to the website,
• To ensure ease-of-use of our website,
• To evaluate system security and stability and
• For other administrative purposes.

The legal basis for the data processing is Article 6, paragraph 1, sentence 1, lit. f GDPR. Our

legitimate interest is derived from the purposes for collecting data listed above. We never use the

collected data to draw conclusions about your person.

We also use cookies in relation to visits to our website. For more information on this, please refer to

point 4 of this Privacy Policy.

b) When contacting us via our website

If you contact us by e-mail via our website, your e-mail address and, if you provide it, your name

and telephone number will be stored by us in order to answer your enquiry.

Data processing for the purpose of making contact with us is carried out in accordance with Article

6, paragraph 1, sentence 1, lit. a GDPR on the basis of your voluntarily given consent.

The personal data we collect when you contact us are automatically deleted once your query has

been dealt with.

3. Transfer of data

Your personal data are not transmitted to third parties other than for the purposes listed below.

We only disclose your personal data to third parties:

• If you have expressly consented to this pursuant to Article 6, paragraph 1, sentence 1, lit.

a GDPR,

• If the disclosure is necessary pursuant to Article 6, paragraph 1, sentence 1, lit. f GDPR for

the establishment, exercise or defence of legal claims and there is no reason to assume

that you have an overriding legitimate interest in your data not being disclosed,

• In the event that there is a legal obligation to disclose the data pursuant to Article 6,

paragraph 1, sentence 1, lit. c GDPR and

• If this is legally permitted and required pursuant to Article 6, paragraph 1, sentence 1, lit. b

GDPR for the handling of contractual relationships with you.

To some extent, we use external service providers to process your data. We have carefully selected

these and commissioned them in writing. They are bound by our instructions and are regularly

checked by us. These service providers will not pass this data on to third parties. All our service

providers are located within the EU/EEA, data transfer to third countries does not take place.

4. Cookies

We use cookies on our website. Cookies are small files automatically created by your browser and

stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do

not cause any damage to your end device and do not contain viruses, Trojans or other malware.

Cookies contain information created in each case in connection with the specific end device used.

However, this does not mean that we can thereby identify you directly.

On the one hand, cookies are used to make our website more user friendly for you. That is why we

use “session cookies” to recognise that you have already previously visited certain pages of our

website. These are automatically deleted after you leave our website.

In addition to this, we use temporary cookies that are stored on your end device for a particular

period of time, also with the aim of making the website more user friendly. If you return to our website

in order to avail of our services, it is automatically recognised that you have visited us before and

your inputs and settings are remembered so that you do not need to enter these again.

The data processed through cookies are necessary for the specified purposes of the legitimate

interests pursued by ourselves and third parties pursuant to Article 6, paragraph 1, sentence 1, lit. f

GDPR.

Most browsers automatically accept cookies. However, you can configure your browser to not store

cookies on your computer or always inform you before a new cookie is placed. If you fully disable

cookies, however, you may not be able to use all of the features of our website.

5. Links to social media sites

We have our own social media pages with third-party providers that can be accessed via links from

this website. By using these links, you are taken to the respective websites of the third-party

providers (Twitter, LinkedIn) and can also share our content. No data are transferred in this

connection when you access our website. As soon as you access the site of a third-party provider,

you are within the area of responsibility of the respective third-party provider, which means their

Privacy Policy and declarations on data use apply. We have no control over these, however we

recommend in order to avoid any unnecessary data disclosure that you log out from the respective

third-party provider before using such a link so that the third-party provider cannot potentially create

usage profiles simply from the use of the link. We have deliberately used links only and not additional

plug-ins from the third-party providers in order to protect your data.

6. Rights of data subjects

You have the right:

• pursuant to Article 15 GDPR to request information about the personal data concerning

you being processed by us. In particular, you may request information about the purposes

of the processing, the category of personal data concerned, the categories of recipients to

whom your data have been or will be disclosed, the envisaged period for which the data

will be stored, the existence of the right to request rectification, erasure or restriction of

processing or to object to it, the right to lodge a complaint and the source of your data,

where it was not collected by us, as well as the existence of automated decision-making,

including profiling, and any other meaningful information about such details;

• pursuant to Article 16 GDPR to request without undue delay the rectification of inaccurate

personal data concerning you stored by us or to have incomplete personal data completed;

• pursuant to Article 17 GDPR to request erasure of personal data concerning you stored by

us unless the processing is necessary for exercising the right of freedom of expression and

information, for compliance with a legal obligation, for reasons of public interest or for the

establishment, exercise or defence of legal claims;

• pursuant to Article 18 GDPR to request restriction of processing of personal data

concerning you in cases where you contest the accuracy of the data, where the processing

is unlawful but you oppose the erasure and where we no longer need the data but you still

require them to establish, exercise or defend legal claims or where you have objected to

processing pursuant to Article 21 GDPR;

• pursuant to Article 20 GDPR to obtain personal data concerning you which you have

provided to us in a structured, commonly used and machine-readable format or to request

that it be transmitted to another controller;

• pursuant to Article 7, paragraph 3 GDPR to withdraw your consent at any time. As a result

of this, we will no longer be able to carry out the data processing that was based upon this

consent in the future and

• pursuant to Article 77 GDPR to lodge a complaint with a supervisory authority. Generally,

you can contact the supervisory authority for your habitual residence, place of work or our

registered office in this regard.

7. Right to object

If your personal data are processed on the basis of legitimate interests pursuant to Article 6,

paragraph 1, sentence 1, lit. f GDPR, you have the right pursuant to Article 21 GDPR to object to

personal data concerning you being processed on grounds relating to your particular situation or if

the objection relates to direct marketing. In the case of the latter, you have a general right to object

which will be implemented by us without any reference to a particular situation.

If you wish to exercise your right to withdraw or object, simply email us at info@finhubfund.com .

8. Data security

We use suitable technical and organizational security measures to protect your data against

accidental or intentional manipulation, partial or complete loss, destruction and unauthorized third party access. We continuously improve our security measures in line with technological advancements.

9. Topicality of and amendments to this Privacy Policy

This Privacy Policy is currently applicable and dates from May 2020.

We may be required to amend this Privacy Policy as we further develop our website and offerings

thereon or if statutory or regulatory requirements change. The Privacy Policy in place at any moment

in time can always be accessed on the website at www.finhubfund.com and printed.