Data Protection

Introduction
Belfund SICAV (hereinafter “we”, “us” or “Belfund”) respects the privacy of users and customers of its website
and has made it its top priority to protect them. This means we undertake to treat the information you provide
at all times with the greatest care and responsibility and in compliance with the relevant data protection
regulations and on the basis of this data protection declaration.
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This also and in particular applies to the cooperation with partners and third parties that we use to process the
contract. We will never give or sell your data to third parties unless you give your express consent.
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By agreeing to the following data protection declaration, you consent to Belfund to collect, process and use the
data in compliance with data protection laws and the following provisions. You can revoke your consent at any
time with effect for the future.
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Belfund guarantees the confidential treatment of all stored personal data of the users of our websites.
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As part of this data protection declaration, we would like to inform you how we guarantee the protection of
the data you have provided. We only collect, process and use personal data in accordance with the
requirements of applicable data protection law.
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Responsible body
Responsible or data processing:
Belfund SICAV
MRB Fund Partners AG
Fraumünsterstrasse 11, 8001 Zurich, Switzerland
Phone: +41 44 210 42 77
Email: info@mrbpartner.ch
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For any request in connection with the protection of your personal data, please contact the person responsible
for data protection in our company.
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Cookies
Based on our legitimate interests, we use cookies on our website. Cookies are small text files that are stored on
your computer. Cookies enable us to track your visit to our website in order to improve the user-friendliness of
our website, but they do not allow any conclusions to be drawn about your identity. They also serve to save
settings between your visits or to technically enable functionalities of the website.
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By using the Belfund website, you consent to the use of cookies for the purposes mentioned. You can decide
against the use of cookies at any time by deleting the cookies set by the website. This is possible via the
settings in your internet browser and by deleting all cookies.
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Personal data
Personal data is all information that relates to an identified or identifiable natural person; A natural person is
regarded as identifiable who, directly or indirectly, in particular by means of assignment to an identifier such as
a name, to an identification number, to location data, to an online identifier or to one or more special
characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social
identity of this natural person can be identified. This includes, for example, your name, your telephone
number, your address and all inventory data that you provide to us when you register or when you place an
order. This does not include statistical or anonymized data that we collect when you visit our website and that
cannot be directly linked to your person.
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Purposes of data processing
The collection and processing of personal data takes place - in addition to the purpose of fulfilling the contract -
for the purpose of enabling the use of our website (connection establishment), to guarantee system security
and stability over the long term and to enable the optimization of our website, as well as for internal statistical
purposes.
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We collect, store and process personal data exclusively in accordance with the applicable statutory provisions
and only insofar as this is necessary and necessary to fulfill the contractual performance obligations between
us and the user. This also includes the storage of data for possible warranty claims after the fulfillment of a
contract.
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In addition, we may use your data within the framework of applicable law for our own marketing purposes in
order to optimize our range of services, to meet your needs with us even more conveniently and individually
and to draw your attention to services and products in which you may be particularly interested.
In addition, personal data will only be processed if you have given your consent and not revoked it.
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Legal basis for the processing
We process your personal data primarily to fulfill contractual obligations as well as to fulfill legal obligations
imposed on us. In addition, by accepting this data protection declaration, you are giving your consent for all
processing operations mentioned in this data protection declaration. You can of course revoke your consent at
any time; a corresponding declaration to welcome@theBelfund.com is sufficient for this. However, the
processing operations carried out up to this point in time will not be affected by your revocation.
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In addition to the afore-mentioned legal basis for data processing, we also process data on the basis of
legitimate interests on our part. This applies in particular, but not only, to processing operations for marketing
and advertising purposes. We may pursue the following interests:
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 own marketing purposes
 Ensuring that the website can be used
 Fraud Prevention
 Ensuring the security and stability of IT systems
 internal statistical purposes
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Transfer of data
We only pass on your personal data if you have given your express consent, if there is a legal obligation to do
so or if this is necessary to enforce our rights, in particular to enforce claims from the contractual relationship.
In addition, we only pass on your data to third parties if this is necessary for the execution of a contract. These
service providers use your data exclusively for order processing and not for other purposes. Belfund is entitled
to transfer your personal data to third parties abroad if this is necessary to process a contract. They are
committed to data protection to the same extent as we are. If the level of data protection in a country does not
correspond to that in Luxembourg, we contractually ensure that the protection of your personal data
corresponds to that in Luxembourg at all times.
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Duration of retention
We keep your personal data for as long as we consider necessary or appropriate to comply with applicable laws
or for as long as it is necessary for the purposes for which it was collected. We delete your personal data as
soon as it is no longer needed and in any case after the statutory maximum retention period has expired. You
can request the deletion of your personal data yourself at any time by sending us a request towelcome@theBelfund.com.
We will comply with your request immediately, unless we are obliged to keep it for other reasons or need it to enforce claims.
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User rights
Right of withdrawal
If you have given us your consent to the processing of personal data while using the website, you can revoke
this consent at any time. The revocation can be sent by e-mail or in writing to the contact points mentioned
under Responsible Body. The effects of the revocation are limited to the processing of personal data that may
not already be processed without your consent due to legal permissions. The revocation also has no effect on
the previous processing operations that were carried out before the revocation.
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Further rights
a) information
Upon written request, we will provide you with information at any time about which personal data we have
stored about you. The request for information must be made in writing and with proof of identity (copy of ID,
passport or other official identification document). The exercise of this right is free of charge once a year; we
reserve the right to request an expense allowance for every further request.
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b) Correction, deletion, restriction of processing
You also have the option of having your personal data corrected, blocked or deleted by us at any time. For this
purpose, please contact the office named under Responsible Body. Only data that we need to process
outstanding tasks or to enforce existing rights and claims is excluded from deletion, as well as data that we
have to keep due to legal regulations. However, such data will be blocked for processes other than those
mentioned.
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c) Right to complain
We attach great importance to the protection of the rights of our customers and thus also to the protection of
your personal data. Should you nevertheless be of the opinion that we are processing your data unlawfully, you
can contact us at any time by e-mail at welcome@theBelfund.com. We will take care of your concerns to the
best of our knowledge and belief.
If, contrary to expectations, our data protection officer is unable to provide you with satisfactory assistance,
there is the option of submitting your request to the Federal Data Protection and Information Commissioner in
the form of a formal complaint.
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d) Data portability
Upon written request, you also have the right to receive your personal data in a structured, common, machine-
readable format for the purpose of transmission to a third party. We reserve the right to demand
compensation for this.
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Safety measures
We use technical and organizational security measures to adequately protect your personal data against
unauthorized access, misuse, accidental or intentional manipulation, loss or destruction. Technical security
measures to protect your personal data are regularly checked and, if necessary, adapted to the state of the art.
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Liability to links to Other Websites and or Content of Other Providers
We have no influence on the current and future design, content or authorship of the linked pages. We
therefore hereby expressly distance ourselves from all contents of all linked / connected pages that were
changed after the link was set. This statement applies to all links and references set within the company's own
website. For illegal, incorrect or incomplete content and in particular for damage resulting from the use or non-
use of information presented in this way, the provider of the page to which reference was made is solely liable,
not the person who merely refers to the respective publication via links.
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Changes
Belfund reserves the right to change this data protection declaration at any time. The data protection
declaration does not establish any contractual or other formal legal relationship with or on behalf of a party.
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Luxembourg, May 2024
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