Introduction

Global Return Equity and Trading (GREAT) SPC ("The Company" or "GREAT Funds") is incorporated in Cayman Islands and is regulated as an administered fund authorized to market to retail investors by the Cayman Islands Monetary Authority ("CIMA"). The Company's registered office is at 4th Floor, Harbour Place, 103 South Church Street, PO Box 10240, Grand Cayman, KY1-1102, Cayman Islands.

Each segregated portfolio or series thereof marketed by the Company is referred to as a Portfolio and the relevant documentation for such a Portfolio is referred to as Portfolio Supplement.

The appointed investment manager for each Portfolio is referred to as the Investment Manager in this privacy policy.

The protection and security of your personal data are important to us. The purpose of this privacy policy ("Policy") is to outline how we deal with personal data when you interact with us, including visiting this website www.greatfunds.com ("Website"). This policy also tells you about your privacy rights.

The Company is a data controller in respect of your personal data for the purposes of the Cayman Islands Data Protection Act (Revised). The Company is responsible for ensuring that it uses your personal data in compliance with Cayman Islands Data Protection Act.

Appreciate Platform Private Limited, the Company's registrar and transfer agent, along with the appointed Investment Manager for each portfolio, will generally process personal data provided to it in connection with an investment in the Company in accordance with the Company's instructions, and the Company will generally act as the data controller of any such personal data.

This privacy policy applies to you if (i) you are an applicant for Shares in the Company, (ii) your personal data has been provided to the Company in connection with an application for shares in the Company by another person (such as where you are a director, partner, trustee, employee, agent or direct or indirect owner of an applicant) or (iii) the Company otherwise uses your personal data including your visit to the website. This privacy policy sets out the basis on which personal data about you will be processed by the Company. Please take the time to read and understand this privacy policy.

Uses of Your Personal Data

Your personal data may be stored and processed by the Company for the following purposes:

  1. Assessing and processing applications for shares in the Company and other share dealings, including performing know-your-client procedures, issuing and redeeming shares, receiving payments from and making payments to the applicant, calculating net asset value, and overseeing these processes.
  2. General business administration, including communicating with investors, communicating with service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products.
  3. Compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information and legal judgments.
  4. In respect of information shared with the Investment Manager and its affiliates, their business activities relating to the Company, such as investor relations, discussions with the Company's service providers and counterparties, decision-making in relation to the Company, and business strategy, development and marketing.

The Company is entitled to process your personal data in these ways for the following reasons:

  1. If you are the applicant, you may enter into an investment contract with the Company and some processing will be necessary for the performance of that contract, or will be done at your request prior to entering into that contract.
  2. Processing may be necessary to discharge a relevant legal or regulatory obligation.
  3. The processing will, in all cases, be necessary for the legitimate business interests of the Company, the Investment Manager, the Company's registrar and transfer agent or another person, such as:
    1. carrying out the ordinary or reasonable business activities of the Company, the Investment Manager, the Company's registrar and transfer agent or other persons, or other activities previously disclosed to the Company's investors or referred to in this privacy notice;
    2. ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;
    3. establishing, exercising or defending legal rights or for other purposes relating to legal proceedings; and
    4. ensuring the security of information systems.
  4. You have given your explicit consent (this basis is used only exceptionally).
  5. In respect of any processing of sensitive personal data falling within special categories, such as any personal data relating to the political opinions of a politically exposed person, the processing will be subject to additional safeguards.

Personal Data that the Company Might Use

The Company might process the following personal data about you:

  1. Information provided to the Company by you or (if different) the applicant which might include your name and address (including proofs of name and address), contact details, date of birth, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank details, investment history, tax residency and tax identification information. Such information might be provided in an application form or in other documents (as part of an application process or at other times), face-to-face, by telephone, by email or otherwise;
  2. Information that the Company collects or generates which might include information relating to your (or an applicant's) investment in the Company, emails (and related data), call recordings and website usage data and messages submitted through the Company's registrar and transfer agent website; and
  3. Information that the Company obtains from other sources which might include information obtained for the purpose of the Company's know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from public websites and other public sources and information received from the applicant's advisers or from intermediaries.

Disclosure of Your Personal Data to Third Parties

The Company may from time to time, in accordance with the purposes described above, disclose your personal data to other parties, including the Investment Manager and its affiliates, the Company's registrar and transfer agent and its affiliates, professional advisers such as law firms and accountancy firms, other service providers of the Company, the Investment Manager and the Company's registrar and transfer agent, including technology service providers, counterparties and courts and regulatory, tax and governmental authorities. Some of these persons will process your personal data in accordance with the Company's instructions and others will themselves be responsible for their use of your personal data. These persons may be permitted to further disclose the personal data to other parties.

Transfers of Your Personal Data Outside the Cayman Islands

Your personal data may be transferred to and stored by persons outside the Cayman Islands, and in particular may be transferred to and stored by affiliates or service providers of the Company or the Company's registrar and transfer agent outside the Cayman Islands.

Where personal data is transferred outside the Cayman Islands, the Company will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law. For example, in the context of personal data transferred outside the Cayman Islands, the country to which the personal data is transferred may be a European Economic Area member, a country approved by the European Commission or the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the personal data.

You can obtain more details of the protection given to your personal data when it is transferred outside the Cayman Islands or the European Economic Area, including a copy of any standard data protection clauses entered into with recipients of your personal data, by contacting the Company using the details set out under "Contacting the Company" below.

Necessity of Personal Data for an Investment in the Fund

The provision of certain personal data is necessary for shares in the Company to be issued to any applicant and for compliance by the Company and its service providers with certain legal and regulatory obligations. Accordingly, if certain personal data is not provided when requested, an application for shares might not be accepted or shares might be compulsorily redeemed.

Retention of Personal Data

How long the Company holds your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which the Company is using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which the Company has to keep your personal data).

Your Rights

You have a number of legal rights in relation to the personal data that the Company holds about you. These rights include the following:

  1. The right to obtain information regarding the processing of your personal data and access to the personal data that the Company holds about you.
  2. The right to request that the Company rectifies your personal data if it is inaccurate or incomplete.
  3. The right to object to, and the right to request that the Company restricts, its processing of your personal data in certain circumstances. There may be circumstances where you object to, or ask the Company to restrict, its processing of your personal data but the Company is legally entitled to continue processing your personal data or to refuse that request.
  4. The right to ask the Company not to subject you to automated decision making that uses your personal data.
  5. The right to object to the Company using your personal data for direct marketing purposes.
  6. The right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by the Company.

You can exercise your rights by contacting the Company using the details set out under "Contacting the Company" below. You can also find out more information about your rights under applicable Cayman Islands data protection law by contacting the Cayman Islands Ombudsman, the data regulator in the Cayman Islands, or by searching its website at www.ombudsman.ky.

Contacting the Company

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions and requests to the Investment Manager at the address set out in the relevant Portfolio Supplement or by email to:

Email: support@greatfunds.com