1. Who we are and what this notice covers

Cadarn Capital EU A/S (“Cadarn Capital”, “we”, “us”, “our”) is a company incorporated in Denmark, registered with the Danish Business Authority (Erhvervsstyrelsen) under CVR no. 46216687, with its registered office at Flæsketorvet 68, 1 1711 København V, Denmark. We are authorised by the Danish Financial Supervisory Authority (Finanstilsynet) under ACOLIN Europe AG in respect of the distribution of units in collective investment undertakings and reception and transmission of orders in relation to one or more financial instruments.

This notice explains how we collect, use, share and protect personal data when you:

visit or interact with our website at www.cadarncapital.eu and any associated pages, portals or landing pages;
enquire about, subscribe for, hold or redeem an interest in a fund or investment product that we distribute or market;
act as, or on behalf of, an investor, prospective investor, distributor, introducer, adviser, service provider or counterparty;
attend our events, receive our marketing communications, or otherwise correspond with us.

It also explains the rights you have over your personal data and how to exercise them. Separate or supplementary privacy information may be provided to you at the point of collection — for example in a subscription document, an investor questionnaire or a distribution agreement. Where that supplementary information conflicts with this notice, the supplementary information prevails for the processing it describes.

The funds we distribute are separate legal entities and may act as data controllers in their own right. Where that is the case, the relevant fund’s own privacy notice — available in its offering documentation or from its administrator — governs that processing.

2. Data controller and contact details

Cadarn Capital EU A/S is the data controller for the processing described in this notice. Our contact details are:

Item	Detail
Controller	Cadarn Capital EU A/S
CVR no.	46216687
Registered address	Flæsketorvet 68, 1 1711 København V, Denmark.
General enquiries	info@cadarncapital.com
Privacy enquiries	info@cadarncapital.com
Data Protection Officer	Claude Mikkelsen, Managing Director – claude@cadarncapital.com

We have appointed a Data Protection Officer. If a DPO is appointed, you may contact them directly at claude@cadarncapital.com on any matter relating to our processing of your personal data.

If we have no establishment in a Member State where we market, and we are required to appoint an EU or Member State representative for a particular activity, their details are: Acolin .

3. The personal data we process

The categories of personal data we process depend on your relationship with us. They may include:

3.1 Identification and contact data

Full name, title, date and place of birth, nationality, gender, photograph or likeness from identity documents, passport or national identity card number, Danish CPR number or equivalent national identifier where legally required, residential and correspondence addresses, email addresses, telephone numbers, signature and specimen signature.

3.2 Professional and relationship data

Employer, job title, business contact details, role and authority within an investing entity, professional qualifications, regulatory status (for example whether you are classified as a retail, professional or eligible counterparty client), directorships, and details of your relationship with a fund, distributor or intermediary.

3.3 Financial, investment and suitability data

Bank account and payment details, tax residence and tax identification numbers, source of funds and source of wealth information, net worth and income indications, investment objectives, investment experience and knowledge, risk tolerance, holdings, subscription, redemption and transfer history, distributions and performance data.

3.4 Compliance, screening and due diligence data

Information gathered through customer due diligence and ongoing monitoring, including sanctions, politically exposed person (PEP) and adverse media screening results, records of enhanced due diligence, ultimate beneficial ownership information, and — where relevant and permitted — information relating to criminal convictions and offences or alleged offences, and records of suspicious activity assessments.

3.5 Communications and interaction data

Correspondence with us by any medium, meeting notes, records of telephone calls and electronic communications where these are recorded (including where recording is required under MiFID II), complaint records, event registrations and attendance, and your marketing preferences.

3.6 Technical and website data

IP address, device and browser type, operating system, referring pages, pages viewed, dates and times of access, approximate location derived from IP address, and information collected through cookies and similar technologies as described in section 11.

3.7 Special categories of personal data

We do not seek to process special categories of personal data (Article 9 GDPR). We may nonetheless incidentally receive such data — for example where an identity document reveals ethnic origin, or where screening results reference political exposure or allegations of criminal conduct. Where we process such data we do so only where a condition in Article 9(2) GDPR applies (typically substantial public interest under Article 9(2)(g) in combination with the applicable anti-money laundering rules), and, in the case of criminal offence data, in accordance with Article 10 GDPR and section 8 of the Danish Data Protection Act.

4. Where we obtain your personal data

We obtain personal data:

From you directly — when you contact us, complete a subscription, onboarding or suitability questionnaire, register for an event, subscribe to our communications, or use our website.
From the entity you represent — where you are a director, officer, employee, authorised signatory, trustee, shareholder or beneficial owner of an investing entity, that entity typically provides your details to us.
From intermediaries and service providers — distributors, placement agents, financial advisers, fund administrators, transfer agents, custodians, depositaries, banks, auditors and legal advisers.
From public and commercial sources — company registers (including the Danish CVR register), land and insolvency registers, sanctions and PEP databases, credit reference and identity verification agencies, regulatory registers, press and internet searches.
Automatically — through cookies and similar technologies when you use our website, as described in section 11.

Where we obtain personal data from a source other than you, we provide this notice — or a link to it — within a reasonable period and in any event within one month, or at the point of first communication with you, in accordance with Article 14 GDPR.

5. Purposes of processing and legal bases

We process personal data only where we have a lawful basis to do so. The table below sets out our principal purposes and the corresponding basis under Article 6(1) GDPR.

Purpose	What this involves	Legal basis
Responding to enquiries and providing information about funds	Handling your enquiry, sending fund documentation, arranging meetings and calls.	Legitimate interests (Art. 6(1)(f)) — operating and developing our distribution business; steps prior to contract (Art. 6(1)(b)) where you are contracting personally.
Investor onboarding, subscription and account administration	Assessing eligibility, processing subscriptions, redemptions and transfers, maintaining the investor register, settling payments and distributions.	Performance of a contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f)) where you act for an investing entity.
Investor classification, appropriateness and suitability assessment	Classifying you as retail, professional or an eligible counterparty and, where applicable, assessing knowledge, experience, objectives and capacity for loss.	Legal obligation (Art. 6(1)(c)) under MiFID II and the Danish implementing rules; performance of a contract (Art. 6(1)(b)).
Anti-money laundering, counter-terrorist financing and sanctions compliance	Customer due diligence, identity verification, beneficial ownership checks, PEP, sanctions and adverse media screening, ongoing monitoring, transaction monitoring and, where required, reporting to the Money Laundering Secretariat (Hvidvasksekretariatet).	Legal obligation (Art. 6(1)(c)) under the Danish Anti-Money Laundering Act and EU sanctions regimes; substantial public interest (Art. 9(2)(g)) and Art. 10 GDPR for related special-category and criminal-offence data.
Tax reporting and withholding	Collecting and reporting information under FATCA, the Common Reporting Standard and DAC, and applying tax withholding where required.	Legal obligation (Art. 6(1)(c)).
Regulatory reporting, supervision and record-keeping	Maintaining records, responding to Finanstilsynet and other competent authorities, cross-border marketing notifications, and telephone and electronic communication recording where required.	Legal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f)) where the record exceeds the strict legal minimum.
Relationship management and reporting to investors	Producing statements, capital account reports, notices, meeting materials and periodic investor reporting.	Performance of a contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)).
Marketing and business development	Sending fund updates, market commentary, invitations to events, and maintaining our CRM records.	Consent (Art. 6(1)(a)) where required by section 10 of the Danish Marketing Practices Act; otherwise legitimate interests (Art. 6(1)(f)) in promoting our services to professional contacts.
Website operation, security and analytics	Delivering and securing the website, preventing fraud and abuse, and understanding how the site is used.	Legitimate interests (Art. 6(1)(f)) for strictly necessary and security processing; consent (Art. 6(1)(a)) for analytics and other non-essential cookies.
Establishing, exercising or defending legal claims	Handling complaints, disputes, litigation, audits and insurance matters.	Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)); Art. 9(2)(f) where special-category data is involved.
Corporate transactions	Due diligence and implementation in connection with a merger, acquisition, reorganisation or sale of all or part of our business.	Legitimate interests (Art. 6(1)(f)).

Where we rely on legitimate interests, we have carried out a balancing assessment to satisfy ourselves that our interests are not overridden by your interests or fundamental rights and freedoms. You may request a summary of that assessment using the contact details in section 2.

Where we rely on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Where we need personal data to comply with a legal obligation or to enter into a contract, and you do not provide it, we may be unable to accept your subscription, continue your investment or maintain our relationship with you. Under the Danish Anti-Money Laundering Act we are required to decline or terminate a business relationship where customer due diligence cannot be completed.

6. Who we share personal data with

We disclose personal data only where we have a lawful basis and, where relevant, an appropriate contract in place. Recipients may include:

the funds we distribute, and their general partners, managers, AIFMs, management companies, boards and investment advisers;
fund administrators, transfer agents, registrars, depositaries, custodians and prime brokers;
other companies within the Cadarn Capital group, for the purposes described in this notice;
distributors, placement agents, introducers and financial advisers involved in your relationship with us;
banks and payment service providers, for the settlement of subscriptions, redemptions and distributions;
identity verification, sanctions screening, KYC and credit reference providers;
IT, cloud hosting, CRM, communications, document management, cybersecurity and data analytics providers acting as our processors;
professional advisers, including lawyers, auditors, tax advisers, insurers and consultants;
competent authorities and public bodies, including Finanstilsynet, the Danish Business Authority, the Danish Tax Agency (Skattestyrelsen), the Money Laundering Secretariat, courts, law enforcement and foreign tax and regulatory authorities where we are required or permitted to disclose;
acquirers, investors and their advisers in connection with an actual or proposed corporate transaction.

Where a recipient acts as our processor, we put in place a written agreement meeting the requirements of Article 28 GDPR. Where a recipient acts as an independent controller — for example a fund administrator carrying out its own statutory duties, or a regulator — that party is responsible for its own compliance and will normally provide its own privacy information.

We do not sell personal data, and we do not disclose it for the independent marketing purposes of third parties.

7. International transfers

We are established in Denmark and process personal data primarily within the European Economic Area. Some of our service providers, group companies or fund service providers are located outside the EEA, and some regulatory or tax disclosures require transfers to authorities in third countries.

Where we transfer personal data outside the EEA, we rely on one of the following safeguards under Chapter V GDPR:

An adequacy decision of the European Commission covering the receiving country, territory or certification framework.
Standard Contractual Clauses adopted by the European Commission, supplemented where our transfer risk assessment identifies the need for additional technical, organisational or contractual measures.
A derogation under Article 49 GDPR — for example where the transfer is necessary for the performance of a contract with you, or for the establishment, exercise or defence of legal claims. We rely on derogations only occasionally and not for routine transfers.

Our current transfers outside the EEA are to the United Kingdom (adequacy decision). You may request a copy of the safeguards we rely on, or details of where the data is transferred, by contacting us using the details in section 2.

8. How long we keep personal data

We keep personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, accounting and reporting requirements, and to establish, exercise or defend legal claims. Our principal retention periods are:

Category	Retention period	Basis
Customer due diligence records, identity documents and screening results	At least 5 years after the end of the business relationship or the completion of the single transaction	Danish Anti-Money Laundering Act (hvidvaskloven) — records must be deleted 5 years after the end of the relationship unless a longer period is justified and documented.
Transaction records, subscription and redemption documentation	At least 5 years after the transaction	Anti-money laundering and financial services record-keeping requirements.
Recorded telephone calls and electronic communications relating to transactions	5 years (or up to 7 years where required by a competent authority)	MiFID II and the Danish implementing rules.
Accounting records and supporting documentation	5 years from the end of the financial year to which they relate	Danish Bookkeeping Act (bogføringsloven).
Tax reporting records (FATCA / CRS)	5 years	Danish tax legislation and the applicable reporting regulations.
Investor relationship and correspondence records	Duration of the relationship plus 5 years	Legitimate interests and the general limitation period for contractual claims under Danish law.
Marketing contact data and consent records	Until you object or withdraw consent, and in any event 2 years after your last engagement with us; consent records kept for 2 years after withdrawal	Consent / legitimate interests, and the evidential requirements of the Danish Marketing Practices Act.
Unsuccessful enquiries and prospective investor records	24 months from the last contact	Legitimate interests.
Website and cookie data	As set out in our cookie policy; consent records for 12 months	Danish Cookie Order and GDPR.

Where a legal claim, investigation, audit or regulatory enquiry is pending or reasonably anticipated, we may retain relevant data until it is resolved. At the end of the applicable period we delete the data or anonymise it irreversibly.

9. Your rights

Subject to the conditions and exceptions in the GDPR and Danish law, you have the following rights:

Access — to be told whether we process your personal data and, if so, to receive a copy of it together with information about the processing (Art. 15).
Rectification — to have inaccurate personal data corrected and incomplete data completed (Art. 16).
Erasure — to have personal data deleted where one of the grounds in Article 17 applies. This right does not apply where we are required to retain the data, which is frequently the case for anti-money laundering and financial records.
Restriction — to have processing restricted in the circumstances set out in Article 18.
Data portability — to receive personal data you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller, where processing is based on consent or contract and carried out by automated means (Art. 20).
Objection — to object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests (Art. 21(1)); and to object at any time and without giving reasons to processing for direct marketing purposes (Art. 21(2)), which we will always honour.
Withdrawal of consent — where processing is based on consent, to withdraw it at any time (Art. 7(3)).
Automated decisions — not to be subject to a decision based solely on automated processing which produces legal or similarly significant effects (Art. 22). See section 10.

To exercise any of these rights, contact us at info@cadarncapital.com or write to us at the address in section 2. We may ask you for information to verify your identity. We respond without undue delay and in any event within one month of receipt, which may be extended by up to two further months where the request is complex or where we have received a number of requests; we will tell you if an extension applies. Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive.

10. Automated decision-making and profiling

We use automated screening tools as part of our anti-money laundering, sanctions and PEP checks. These tools generate alerts, but an alert does not by itself determine the outcome: every alert relevant to a decision about your relationship with us is reviewed by a member of our staff before any decision is taken.

We do not make decisions producing legal or similarly significant effects concerning you based solely on automated processing within the meaning of Article 22 GDPR. If this changes, we will inform you, explain the logic involved and the significance and consequences of the processing, and provide the safeguards Article 22(3) requires.

11. Cookies and similar technologies

Our website uses cookies and similar technologies (including pixels, local storage and software development kits). Their use is governed by the Danish Cookie Order (cookiebekendtgørelsen), which implements the ePrivacy Directive, alongside the GDPR.

We store information on, or access information stored on, your device only where:

the storage or access is strictly necessary to provide the service you have expressly requested — for example session management, load balancing and security cookies; or
you have given your prior, freely given, specific, informed and unambiguous consent.

The categories of cookies we use, their purposes, providers, durations and whether they are first- or third-party are set out in our cookie policy at cadarncapital.eu/cookies, which is updated whenever our cookie use changes.

12. Marketing communications

We send fund updates, market commentary and event invitations to contacts who have asked to receive them or where we are permitted to do so. Where the Danish Marketing Practices Act (markedsføringsloven) requires prior consent for electronic marketing, we obtain it before sending.

Every marketing email contains an unsubscribe link, and you can opt out at any time by contacting info@cadarncapital.com. Opting out of marketing does not stop us sending you information we are required or contractually obliged to send — for example investor reports, notices of meetings, and regulatory or tax communications.

Marketing material relating to funds is issued only to persons to whom it may lawfully be communicated in the relevant jurisdiction, and in accordance with Regulation (EU) 2019/1156 on cross-border distribution of collective investment undertakings.

13. Security

We implement appropriate technical and organisational measures under Article 32 GDPR to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include access controls and role-based permissions, encryption in transit and at rest, network and endpoint security, logging and monitoring, secure disposal, supplier due diligence, business continuity arrangements, staff training and confidentiality obligations.

No transmission over the internet is entirely secure. Where a personal data breach is likely to result in a risk to your rights and freedoms we notify Datatilsynet without undue delay and, where feasible, within 72 hours; where the risk is high, we also notify you directly.

14. Complaints

If you have a concern about how we handle your personal data, please contact us first at info@cadarncapital.com — we would like the opportunity to resolve it.

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement. The Danish supervisory authority is:

Supervisory authority	Contact details
Datatilsynet (the Danish Data Protection Agency)	Carl Jacobsens Vej 35, 2500 Valby, Denmark · Telephone +45 33 19 32 00 · Email dt@datatilsynet.dk · www.datatilsynet.dk

You may also pursue a judicial remedy against us or against a supervisory authority under Articles 78 and 79 GDPR.

15. Changes to this notice

We review this notice regularly and update it when our processing changes or when the law requires. The version and date at the top of the page indicate when it was last revised. Where a change is material, we bring it to your attention by a prominent notice on the website before it takes effect. Previous versions are available on request.

PART II

Website Legal Notice and Disclaimer

16. Important information — please read

By accessing www.cadarncapital.eu you acknowledge that you have read, understood and agreed to this legal notice. If you do not agree, please do not use the website.

16.1 No offer or solicitation

The information on this website is provided for general information only. It does not constitute, and must not be relied on as, an offer to sell or a solicitation of an offer to buy any security, fund interest or investment product, nor an invitation or inducement to engage in investment activity, in any jurisdiction where such an offer, solicitation, invitation or inducement would be unlawful or where the person making it is not qualified to do so.

Any offer of interests in a fund is made solely on the basis of that fund’s final offering documentation — including its prospectus or information memorandum, key information document, constitutional documents and subscription agreement — which contains the full terms, risks, fees and conflicts of interest, and which prevails over anything on this website in the event of inconsistency.

16.2 No investment, legal or tax advice

Nothing on this website constitutes investment, legal, tax, accounting or other professional advice, or a personal recommendation. Cadarn Capital EU A/S does not take account of your individual objectives, financial situation or needs when publishing this website. You should obtain independent professional advice before making any investment decision.

16.3 Intended audience and jurisdictional restrictions

This website is directed only at persons in jurisdictions where it may lawfully be accessed, and in respect of fund-specific pages only at professional investors, per se professional clients and eligible counterparties as defined in MiFID II, and equivalent categories under the AIFMD national private placement regimes. It is not directed at retail investors except where a fund is expressly registered for retail distribution in your jurisdiction.

The interests described are not, and will not be, registered under the U.S. Securities Act of 1933, as amended, or with any securities regulatory authority of any state of the United States. Subject to certain exceptions, they may not be offered, sold or delivered, directly or indirectly, in the United States or to or for the account or benefit of any U.S. Person.

It is your responsibility to be aware of and to observe all applicable laws and regulations of your jurisdiction.

16.4 Investment risk

The value of investments and the income from them can fall as well as rise, and investors may not get back the amount originally invested. Past performance is not a reliable indicator of, and is no guarantee of, future results. Where an investment is denominated in a currency other than your own, changes in exchange rates may cause its value to rise or fall. Certain funds may be illiquid, may use leverage, and may involve a risk of total loss of capital. Forward-looking statements, targets and projections are inherently uncertain and are not guarantees of future performance.

16.5 Accuracy and availability

While we take reasonable care to ensure the information on this website is accurate at the date of publication, we give no representation or warranty, express or implied, as to its accuracy, completeness, timeliness or fitness for any purpose, and it may be changed without notice. To the fullest extent permitted by law, Cadarn Capital EU A/S, its group companies and their respective directors, officers, employees and agents accept no liability for any loss or damage arising from the use of, or reliance on, this website or its content, or from any inability to access it. Nothing in this notice excludes or limits liability which cannot lawfully be excluded or limited, including liability for fraud, or for death or personal injury caused by negligence.

16.6 Third-party links and content

This website may contain links to third-party websites. Such links are provided for convenience only. We do not control, endorse or accept responsibility for the content, availability or privacy practices of any third-party website, and your use of them is at your own risk and subject to their own terms.

16.7 Intellectual property

All content on this website — including text, graphics, logos, trade marks, images, data and software — is owned by or licensed to Cadarn Capital EU A/S and is protected by copyright, trade mark and other intellectual property laws. You may view, download and print content for your own personal, non-commercial use. Any other reproduction, distribution, transmission, adaptation or commercial exploitation requires our prior written consent.

16.8 Regulatory status

Cadarn Capital EU A/S is a company registered in Denmark under CVR no. 46216687, with its registered office at Flæsketorvet 68, 1 1711 København V, Denmark. It is authorised and supervised by Finanstilsynet (the Danish Financial Supervisory Authority), under ACOLIN Europe AG. Details are available on the Finanstilsynet register at www.finanstilsynet.dk.

16.9 Complaints

If you wish to make a complaint about our services, please contact info@cadarncapital.com. Our complaints handling procedure is available at cadarncapital.eu/complaints. If you are dissatisfied with our response you may be entitled to refer the matter to Det finansielle ankenævn or to Finanstilsynet.

16.10 Governing law

This legal notice, and any non-contractual obligations arising out of or in connection with it, are governed by Danish law. The courts of Denmark have exclusive jurisdiction over any dispute arising from or in connection with this website, save that this does not deprive a consumer of the protection of the mandatory rules of the law of their country of residence.

Data Privacy