PRIVACY POLICY

In the course of providing services to you or providing information to you through our website, Lyrium Venture Partners Limited ("Lyrium") may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Lyrium” refers to Lyrium Venture Partners Limited and other parties that may provide ancillary services to us to deliver our service to you worldwide.

The personal information we collect about you comes primarily from the client onboarding applications or other forms and materials you submit to Lyrium during the course of your relationship with us. We may also collect information about your transactions and experiences with Lyrium relating to the products and services we provide. In addition, depending on the products or services you require, Lyrium may obtain additional information about you, such as your financial information, business information, and/or other personal details about you.

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Finally, in the provision of consulting services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

If you deal with Lyrium in your individual capacity or as an owner or principal of a company, etc., the typical information we collect about you would include:

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• Your name, address and other contact details;

• Your age, occupation and marital status;

• Extensive financial information, including, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources; 

• A head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by laws and regulations addressing due diligence and related matters; and 

• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

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If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:​

• Your name and contact details;

• Your role/position/title and area of responsibility; and 

• Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

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Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to provide certain services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

We may use your personal information to:

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• Administer, operate, facilitate and manage your relationship and/or account with Lyrium. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;

• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account; 

• Provide you with information, recommendations, or advice concerning products and services offered by Lyrium; and 

• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

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If your relationship with Lyrium ends, Lyrium will continue to treat your personal information, to the extent we retain it, as described in this policy.

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Lyrium may be given, or given access to, your personal information. For example, one Lyrium entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services depending on your needs. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Lyrium is provided below, under Information Security: How We Protect Your Privacy.

Lyrium does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Lyrium, including those that provide professional, legal or accounting advice to Lyrium. Non-affiliated companies that assist Lyrium in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Lyrium dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.

You should know that Lyrium will not sell your personal information.

Lyrium is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Lyrium employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.

This policy provides a general statement of the ways in which Lyrium protects your personal information. You may, however, in connection with specific products or services offered by Lyrium, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective August 27, 2018.

(This section applies only if your information is processed by Lyrium in a Member State of the European Economic Area (EEA), Singapore, Switzerland, Hong Kong, Japan, Australia or New Zealand).

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You are entitled to access any personal data about you held by Lyrium by sending a written request to us at:

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Lyrium Venture Partners Limited

2302, Lee Garden Two

28 Yun Ping Road

Causeway Bay

Hong Kong

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You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have Lyrium modify or delete any information that you believe is incorrect or out of date.

Lyrium may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices in the above-referenced regions, please contact us at the mailing address above.

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Last Updated: December 29, 2021