Privacy Policy

1. Who we are

Synergy Partners (the "Fund", "we", "us" or "our") is an exempted company incorporated with limited liability in the Cayman Islands under registration number 420525, with its registered office at c/o Bell Rock Group Financial Services Limited, Centennial Towers, Suite 205c, 2454 West Bay Road, Grand Cayman KY1-1303, Cayman Islands.

The Fund is the data controller of the personal data described in this Privacy Policy for the purposes of the Data Protection Act (As Revised) of the Cayman Islands (the "DPA") and, where applicable, the EU General Data Protection Regulation (the "EU GDPR") and the UK General Data Protection Regulation (the "UK GDPR").

2. Scope of this Privacy Policy

This Privacy Policy explains how we collect, use, disclose and protect personal data in connection with:

• your use of our website, www.synergy.inc (the "Website"); and

• enquiries and correspondence with prospective investors, their representatives and other persons who contact us.

If you subscribe for shares in the Fund, your personal data will also be processed in accordance with the Fund's Investor Privacy Notice, which is provided with the Fund's subscription documents and is available on request from the Fund's administrator. In the event of any inconsistency in relation to your investment, the Investor Privacy Notice prevails.

3. Personal data we collect

Information you provide to us

• identity and contact details, such as your name, job title, organisation, email address, telephone number and country of residence;

• information about your investor status and eligibility, where you provide it;

• the content of your enquiries and correspondence with us.

Information collected automatically

• technical data, such as your IP address, browser type and version, device information, pages visited and the date and time of access, collected through server logs maintained by our website hosting provider;

• information stored in your browser by strictly necessary cookies, as described in our Cookie Policy.

Information from third parties

• publicly available information, and information from sanctions, politically exposed person and adverse media screening services, where we conduct due diligence on a prospective investor or counterparty;

• information provided by your professional advisers or by introducers acting on your behalf.

We do not intend to collect sensitive personal data through the Website. Please do not send us such data unless we specifically request it.

4. How we use personal data and our legal basis

We process personal data only where a lawful basis for processing applies. We use personal data:

• to respond to your enquiries and communicate with you, on the basis of our legitimate interests, or to take steps at your request before entering into a contract;

• to assess whether you are eligible to receive information about, or to invest in, the Fund, on the basis of our legitimate interests and to comply with our legal obligations;

• to carry out client due diligence, anti-money laundering, counter-terrorist financing, sanctions and other compliance checks, to comply with our legal and regulatory obligations;

• to operate, maintain and secure the Website and to detect and prevent fraud and misuse, on the basis of our legitimate interests;

• to comply with requests and requirements of regulatory, tax, law enforcement and judicial authorities, to comply with our legal obligations;

• to establish, exercise or defend legal claims, on the basis of our legitimate interests;

• for any other purpose for which you have given your consent.

Where we rely on consent, you may withdraw it at any time, without affecting the lawfulness of processing before withdrawal. Where we rely on legitimate interests, we have considered that those interests are not overridden by your rights and freedoms.

We do not sell personal data. We do not send unsolicited marketing communications, and we do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

5. Who we share personal data with

We may share personal data with the following, to the extent necessary for the purposes described above:

• the Fund's directors;

• the Fund's administrator, registrar and transfer agent, Amicorp Fund Services (Asia) Pte. Ltd.;

• the Fund's auditor, legal, tax and compliance advisers, including its anti-money laundering officers;

• the Fund's registered office provider;

• banks and other financial institutions with which the Fund maintains relationships;

• providers of website hosting, information technology and communications services;

• CIMA, the Cayman Islands Tax Information Authority, the Financial Reporting Authority and other regulatory, tax, law enforcement or judicial authorities, where required or permitted by law;

• any successor to all or part of the Fund's business, in connection with a restructuring or similar transaction.

Service providers acting as our data processors process personal data only on our instructions and under written terms that require appropriate security measures.

6. International transfers

Personal data may be transferred to, stored and processed in countries outside the Cayman Islands, the European Economic Area and the United Kingdom, including Singapore, the United Arab Emirates and the United States, which may not provide an equivalent level of data protection. We transfer personal data only in accordance with applicable data protection law, for example where the recipient country has been recognised as providing an adequate level of protection, where appropriate safeguards such as standard contractual clauses approved by the European Commission or the UK authorities are in place, or where another lawful transfer mechanism applies. You may request further information about the safeguards we use by contacting us.

7. Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, tax and accounting requirements. In particular:

• enquiry and correspondence data that does not lead to an investment is retained for up to 24 months after our last contact;

• records obtained in connection with client due diligence are retained for at least the period required by the Anti-Money Laundering Regulations (As Revised) of the Cayman Islands;

• server log data is retained for up to 90 days, unless required for longer for security investigations.

8. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. No transmission over the internet is completely secure, and we cannot guarantee the security of data sent to us electronically. Where required by applicable law, we will notify the competent supervisory authority and affected individuals of a personal data breach.

9. Your rights under the DPA

Subject to the DPA and to applicable exemptions, you have the right to:

• be informed about how your personal data is processed;

• request access to your personal data;

• request that inaccurate or incomplete personal data be corrected;

• require us to stop, or not to begin, processing your personal data, including for direct marketing purposes;

• object to decisions based solely on automated processing;

• withdraw consent, where processing is based on consent;

• complain to the Ombudsman of the Cayman Islands.

10. Additional rights for individuals in the EEA and the United Kingdom

If you are located in the European Economic Area or the United Kingdom, you also have, subject to the EU GDPR or the UK GDPR as applicable, the right to:

• request erasure of your personal data;

• request restriction of processing;

• receive your personal data in a structured, commonly used and machine-readable format and have it transmitted to another controller;

• object to processing based on our legitimate interests;

• lodge a complaint with the data protection supervisory authority in the country where you live or work, or where an alleged infringement took place. In the United Kingdom, this is the Information Commissioner's Office.

11. Exercising your rights

Certain rights may be limited where we are required to retain or process personal data to comply with our legal obligations, including anti-money laundering requirements. We will respond to a valid request within the period required by applicable law. We may need to verify your identity before responding.

12. Children

The Website is not directed at persons under the age of 18, and we do not knowingly collect personal data from them.

13. Third-party websites

The Website may contain links to third-party websites. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy notices.

14. Cookies

Information about the cookies and similar technologies used on the Website is set out in our Cookie Policy.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The current version will always be published on the Website, with the date of the latest update shown above.

16. Contact us

To exercise your rights or ask a question about this Privacy Policy, please contact:

Synergy Partners

Attention: Data Protection

c/o Bell Rock Group Financial Services Limited

Centennial Towers, Suite 205c, 2454 West Bay Road

Grand Cayman KY1-1303, Cayman Islands

Email: info [at] synergy.inc

Please include "Privacy" in the subject line.

If you are not satisfied with our response, you may complain to the Ombudsman of the Cayman Islands:

Office of the Ombudsman, PO Box 2252, Grand Cayman KY1-1107, Cayman Islands

Email: info@ombudsman.ky

Website: www.ombudsman.ky