Privacy Policy

About This Privacy Policy

Zuba Capital Management Limited ("Zuba", "we", "us" or "our") respects your privacy and is committed to handling personal information responsibly and in accordance with applicable data protection and privacy laws.

This Privacy Policy explains how we collect, use, disclose, transfer, retain and protect personal information when you visit our website, create or use an account, participate in investor onboarding or verification, communicate with us, receive information from us or otherwise use our website, investor portal, applications or related digital services (together, the "Services").

This Privacy Policy is a transparency notice. It does not form part of any investment contract and does not replace any offering, subscription or other investment document.

Who We Are

Zuba Capital Management Limited is a company incorporated in the British Virgin Islands and is licensed and regulated by the British Virgin Islands Financial Services Commission.

Zuba Capital Management Limited is the controller of personal information collected through the Services except where another entity is expressly identified as the controller in connection with a particular investment, service or activity. Where another Zuba entity, investment vehicle, manager, administrator or other person acts as a separate or joint controller, additional privacy information may be provided where required.

Scope

This Privacy Policy applies to personal information relating to website visitors, prospective and existing investors, account holders, representatives of investors, beneficial owners, directors, officers, partners, trustees, employees of institutional investors and other individuals whose personal information is processed in connection with the Services.

Third-party websites and services linked from the Services are governed by their own privacy practices and are not covered by this Privacy Policy.

Personal Information We Collect

Depending on your relationship with us and the Services you use, we may collect: identity and verification information, including name, date and place of birth, nationality, citizenship, residential address, identification numbers and copies of identity documents; contact information; professional and organisational information; investor eligibility and profile information, including jurisdiction, residence, investor classification, investment experience, knowledge, objectives, financial circumstances and risk profile; financial and investment information, including assets, income or wealth information where relevant, source of funds, source of wealth, bank or payment information, holdings, subscriptions, redemptions and transaction history; compliance information used for KYC, AML, fraud prevention, sanctions, politically exposed person screening and beneficial ownership verification; information about directors, officers, partners, trustees, beneficial owners, authorised representatives and controlling persons; technical, security and usage information, including IP address, device and browser information, login records, authentication information, cookie identifiers, website interactions and security logs; communications and preferences; and other information we are required or permitted to obtain in connection with the Services or an investment relationship.

Sources of Personal Information

We may obtain personal information directly from you and, where applicable, from persons acting on your behalf, associated organisations, intermediaries, professional advisers, administrators, identity-verification and compliance providers, sanctions and screening databases, public registers, regulatory or governmental authorities and publicly available sources.

We may also generate information through your use of the Services, including account, authentication, security and usage records.

How We Use Personal Information

We may use personal information to operate, secure, maintain and improve the Services; create and administer accounts; determine jurisdictional access and investor eligibility; administer investor classification and risk-profile processes; conduct identity verification, KYC, AML, sanctions, source-of-funds, source-of-wealth and fraud-prevention checks; provide controlled access to investment-related information; manage prospective and existing investor relationships; administer subscriptions, investments, transfers, distributions and redemptions where applicable; maintain records; comply with legal, regulatory, tax, accounting, audit, reporting and recordkeeping requirements; prevent and investigate fraud or security incidents; respond to inquiries, complaints and disputes; establish or defend legal rights; send service, legal, security and administrative communications; send permitted marketing communications; and support corporate transactions and legitimate business administration.

Legal Bases for Processing

Where applicable law requires a lawful basis, we rely as appropriate on: performance of a contract or steps requested before a contract; compliance with legal or regulatory obligations; our legitimate interests or those of another person, including operating and securing our business, administering investor relationships, preventing fraud, managing risk and protecting legal rights, provided those interests are not overridden by rights requiring protection; consent where required for a particular activity, such as certain marketing communications or non-essential cookies; and other lawful grounds recognised by applicable law.

Where processing is based on consent, you may withdraw consent as permitted by applicable law. Withdrawal does not affect processing already lawfully carried out. We do not rely on marketing or cookie consent for processing independently required for KYC, AML, sanctions, regulatory recordkeeping or other legal or compliance purposes.

Investor Onboarding and Compliance

Before providing access to certain investment-related information or accepting an investment, we may process personal information to assess jurisdictional access, investor status and other eligibility requirements and to conduct regulatory and compliance checks.

Completion of an account, questionnaire or risk-profile assessment does not itself establish investment eligibility. Information supplied through those processes may be combined with information from compliance providers, public sources and other lawful sources to determine whether access or further onboarding is permitted. We may be required to retain or disclose compliance information even if you do not proceed with an investment or later close your account.

Marketing Communications

Where permitted by applicable law, we may use your contact information to send communications about Zuba, our activities, events or services that we believe may be relevant to you.

You may opt out of marketing communications at any time using the unsubscribe mechanism in the communication or by contacting us. Opting out does not prevent non-marketing communications concerning your account, the Services, legal or regulatory matters, security or an existing investment relationship.

Cookies and Similar Technologies

We may use cookies and similar technologies to operate and secure the website, remember preferences, understand use of the Services and, where applicable, support analytics or other functions.

Further information is provided in our Cookie Notice or consent mechanism. Where applicable law requires consent before use of non-essential technologies, we will request that consent using the relevant mechanism.

How We Share Personal Information

We may disclose personal information where reasonably necessary to members of the Zuba group; investment vehicles, general partners, managers, advisers, administrators, custodians, depositaries and other parties involved in an investment; banks and payment providers; KYC, AML, sanctions and fraud-prevention providers; technology, cloud-hosting, cybersecurity, communications and analytics providers; auditors, accountants, lawyers, tax advisers and consultants; regulators, tax authorities, courts, law-enforcement bodies and governmental agencies; counterparties and advisers in corporate transactions subject to appropriate confidentiality arrangements where applicable; and other persons where you direct or authorise disclosure or disclosure is otherwise lawful.

We do not sell personal information for monetary consideration. If applicable law treats particular disclosures or advertising technologies as a sale, sharing or similar regulated activity, we will provide notices and choices required by that law.

International Transfers

Zuba operates internationally. Personal information may therefore be accessed, processed or stored outside the country in which it was collected, including in the British Virgin Islands and jurisdictions in which Zuba group entities, investment vehicles, service providers, advisers or regulatory authorities are located. Data protection laws in those countries may differ from those in your jurisdiction.

Where applicable law requires safeguards for an international transfer, we use an appropriate lawful transfer mechanism or other permitted safeguard. Depending on the circumstances, this may include recognised contractual protections, an adequacy or comparable decision, a legally permitted derogation or another recognised mechanism. Further information about applicable transfer safeguards may be requested using the contact details below, subject to legal, confidentiality and security restrictions.

Data Security

We maintain technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Those measures are reviewed having regard to the nature of the information and relevant risks. Access is restricted according to legitimate business and compliance needs, and relevant service providers are required to protect personal information in accordance with applicable contractual and legal requirements.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Data Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including to provide the Services, administer investor relationships and meet legal, regulatory, tax, accounting, audit, reporting and recordkeeping requirements.

The applicable period may depend on the nature of the information, our relationship with you, whether an investment was made, applicable limitation periods, disputes and requirements imposed by law, regulation or regulatory authorities. When information is no longer required, we will delete, anonymise or otherwise dispose of it in accordance with our applicable retention procedures, subject to preservation requirements.

Automated Processing

We may use automated tools to support identity verification, compliance screening, risk profiling, fraud prevention, security monitoring and administration of access controls. Automated tools may generate alerts, scores or indicators that assist our processes. Where applicable law gives you rights in relation to a decision based solely on automated processing that produces legal or similarly significant effects, we will provide the information and protections required by that law.

Your Privacy Rights

Your privacy rights depend on the law applicable to you and the circumstances of our processing. Subject to applicable conditions, exemptions and limitations, rights may include access, correction, deletion, restriction, objection, portability, withdrawal of consent, rights concerning qualifying automated decision-making and the right to complain to a competent authority.

These rights are not absolute. We may be required or permitted to retain information to comply with legal, regulatory, AML, sanctions, tax, reporting, recordkeeping or legal-claims requirements.

Exercising Your Rights

To exercise a privacy right or ask a question about our processing, contact us using the details in Section 23. We may need to verify your identity and authority before responding. Where a request is made through an authorised representative, we may require evidence of that authority.

We will respond in accordance with the timeframe and other requirements imposed by applicable law. Where legally permitted, we may decline or limit a request and will provide an explanation where required.

Children's Privacy

The Services are intended for adults and are not directed to children. We do not knowingly collect personal information directly from children through the Services. If you believe a child has provided personal information to us inappropriately, please contact us.

Third-Party Websites and Services

The Services may contain links to websites or services operated by third parties. We are not responsible for their privacy practices. You should review the privacy information provided by the relevant third party before providing personal information to it.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, processing activities, legal or regulatory requirements or business practices. The current version will be made available through our website and will identify its effective date. Where required by applicable law, we will provide additional notice of material changes.

Complaints

If you have concerns about our handling of personal information, please contact us so that we can consider and respond to the issue. Depending on where you are located and the law applicable to our processing, you may also have the right to complain to the data protection authority or other competent supervisory authority in your jurisdiction. Nothing in this Privacy Policy limits that right.

Jurisdiction-Specific Rights

Additional or different privacy requirements may apply depending on your location, the relevant Zuba entity, the investment concerned and the law governing the processing. Where required, we may provide a supplemental privacy notice or additional disclosures for a particular jurisdiction or activity.

Any jurisdiction-specific supplement should be read together with this Privacy Policy. If a mandatory provision of applicable privacy law conflicts with this Privacy Policy, the mandatory provision applies to the extent of that conflict.