We collect Personal Information in various ways and from different sources depending on how you interact with us and use the Services, and may include the following:

• Name, physical address, phone number, e-mail address, nationality, date of birth, username, password, government-issued identification (e.g., passport, Social Security numbers, driver’s license), tax identification numbers, investment activities, bank or financial information, your contact details and communications if you contact us by email, mail, or webforms regarding the Services (or support related to the Services)
• When you access the website, we automatically record and store certain information about your system by using cookies and other types of data collection technologies, such as your IP address, device and browser types and identifiers, and information about your access and use of the website.

We collect Personal Information directly from you, such as when you visit our website, platform, or mobile application, send us a message through the “Contact Us” feature of our website, interact with us when using the Services, via background checks, or otherwise communicate directly with us. We may collect your Personal Information from third parties, such as credit reporting agencies or financial institutions. We may obtain additional information from social media or professional networking websites based on your interactions with those publicly available social media or professional networking websites. When you access our Services through social media or professional networking websites, we collect, use, and store information, including Personal Information, in accordance with this Privacy Policy. The purposes for which we use your Personal Information vary depending upon the circumstances. We use your Personal Information for the following purposes:

• To verify and authenticate your identity, process and onboard you, and perform other activities that are part of our Services.
• To communicate with you, respond to your requests, offer products and services, or otherwise communicate with you relating to the Services or your interactions with the website or platform.
• To improve, operate, maintain, enhance, provide, create, or develop all of the features, functionality, and operability of the Services, including technical support and to maintain our databases.
• To detect fraud or misuse. For our internal, research, and analytical purposes.
• To enforce our Terms and Conditions of Use.
• To comply with legal obligations, including responding to a subpoena, court order, or other legal process, or producing relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings.

We disclose your Personal Information in the following circumstances:

• To companies under common ownership and control of Lionsoul, including our subsidiaries and affiliates.
• To companies who provide website and platform hosting, maintenance, and security services.
• To companies for identity verification and authentication, transaction processing, or to provide Services to you or on our behalf.
• In the event that some or all assets related to Lionsoul are acquired by or merged with a third-party entity or in connection with a change of ownership transaction. We reserve the right, in any of these circumstances, to transfer or assign the information, including Personal Information, collected through the Services as part of a merger, acquisition, sale, or other change of control event, dissolution, or liquidation of all or a portion of our assets, including in the course of any due diligence.
• With government entities, law enforcement agencies, regulators, or other third parties in order to respond to a subpoena, court order, governmental request, or other legal process; to produce relevant documents or information in connection with litigation, arbitration, mediation, government or internal investigation or other legal or administrative proceedings; or protect the rights, property, or interests of Lionsoul, our Clients, or others.
• With your consent or at your direction, such as sharing with your representatives or third parties for identity verification.

A cookie is a small text file placed on your computer. Cookies help us understand how our website is being used, to enhance your user experience, and to analyze and compile usage data. Personal information collected by cookies may include your device’s IP address, browser type, operating system, computer platform, web pages viewed, and/or the date and time of your visit. For example, we may use cookies to remember your preferences or settings, such as your language preference. Cookies may also securely identify or authenticate you as a Client. We (or third parties) may also place, view, and/or use cookies and other electronic tools to collect information about your use of the website. Most browsers include tools to manage or disable cookies. You can visit the help function on most browsers to modify how your browser handles cookies. However, if you disable cookies, certain features of this website may not function properly. We collect and use the following categories of cookies on our websites:

• Necessary Cookies. Necessary cookies make the website function and will be loaded onto your browser automatically. We use necessary cookies to perform the services you have requested, such as log-in to the website’s features, or to record that you have refused non-necessary cookies. Our website and platform service providers use this information to perform services for us.
• Performance Cookies. Performance cookies evaluate the performance of our websites, including the usage data and time you spend on a webpage, so that we can better understand our interactions with you. We use third-party analytics, such as Google Analytics, to better understand user engagement and metrics regarding the use of our websites. This can include the amount of time that you spent on a particular page and your movements on the website, and may also reveal information about your geographic location. You can opt-out of the use of Google Analytics cookies here.
• Functional Cookies. Functional cookies allow the website to remember the choices that you make and to provide enhanced, personalized features.
• Targeting Cookies. Targeting cookies are tracking technologies used to deliver advertisements relevant to the user. We also use targeting cookies to inform us as to whether you have viewed or interacted with such advertisement by clicking on it.

Cookies can be categorized by how long they remain on your device. All cookies have expiration dates in them that determine how long they stay in your browser. There are two broad categories of duration:

• Session Cookies. Session cookies are temporary cookies that exist only during an online session and are not stored on your computer or mobile device. Session cookies are used as part of the login and authentication management flows of the platform or websites and to process your online requests. Certain session cookies are also used to understand if a user interacting with our company website is a new visitor or a visitor returning as part of the same browsing session. Session cookies remain on your device until you close your browser and then they are automatically deleted.
• Persistent Cookies. Persistent cookies are those placed on your computer or mobile device for a pre-determined length of time when you visit this website. We use persistent cookies that only the website can read and use to identify the fact that you are a customer or website visitor, to store user preference data, and to understand which areas of our websites and platform are most popular. Persistent cookies remain on your device until deleted manually or automatically.

To learn more about cookies and other tracking technologies, visit www.allaboutcookies.org. Please note that the data collection technologies we use may change from time to time.

Web Beacons and Pixels. Web beacons and pixels are graphic images placed on our webpages that allow us to understand behavior on our website and when users have performed a specific action on our websites. Web beacons and pixels help us to track user behavior and web traffic to deliver a better user experience.

Social Media Interactions. Our websites may also use web beacons or pixels from social media or professional networking companies and may provide the option for you to interact with us over certain social media networking websites. When you use social media or professional networking platforms, we may collect your Personal Information, in accordance with the social media or networking website’s privacy policies. Lionsoul uses this information from social media websites to supplement the information we collect in order to provide you with a better overall experience.

Your Choices Regarding Cookies. At any time, you may control the cookies installed on your device via CookiePro by One Trust. You may choose to accept or refuse the use of cookies here. If you choose to block all non-necessary cookies, please note that certain functionality or features of our website may not be available to you, such as those that require identification. To the extent that information collected through our data collection technologies (including any information that we may link to Personal Information that you provide through the websites) is considered Personal Information under applicable data protection law, we will treat it as Personal Information. For certain jurisdictions, we obtain consent from users and offer choices regarding cookie collection. In the European Economic Area and the United Kingdom, users have the right to reject the installation of all cookies but essential cookies on their devices.

Global Privacy Control. The Global Privacy Control (“GPC”) is a method for individuals to opt-out of the sale or sharing of their personal information, as such terms are described under applicable data protection laws, via a user-enabled privacy control that is available on certain internet browsers. We do not sell or share your Personal Information and as such, our systems are not configured to detect or respond to the GPC. You can learn more about the GPC here.

“Do Not Track” (DNT) Signals. DNT is a privacy preference that individuals can set in some web browsers and provides an individual with the opportunity to opt-out of tracking by websites and online services. However, third-party services that collect this type of information may permit you to opt out through a separate system. Currently, our website is not configured to respond to DNT signals. To learn more or to opt-out of this type of advertising from participating third parties’ providers, you can visit https://www.donottrack.us/.

If you are a resident of a country located in the EEA or the UK, you have rights under the General Data Protection Regulation (“GDPR”) or the UK General Data Protection Regulation (“UK GDPR”). We are required to comply with the GDPR, the UK GDPR, and applicable local laws (including, without limitation, the DPA) with respect to certain Personal Information we collect. For the purpose of this Privacy Policy, Personal Information also includes “personal data,” as such term is defined under the GDPR and the UK GDPR. Lionsoul is the “controller” with respect to the Personal Information that we collect from you.

We process Personal Information for the purposes described in the How We Collect and Use Your Personal Information section. If we use or process Personal Information in ways other than described in this Privacy Policy, we will provide you with specific notice at the time of collection. Please note that we do not knowingly collect special categories of Personal Information, which includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, and data concerning health, sex life, and sexual orientation.

Legal Bases for Processing. We collect your Personal Information, as detailed in the Personal Information We Collect section, and rely on the following legal bases to process your Personal Information: (i) your valid consent; (ii) as necessary for the performance of a contract; (iii) compliance with a legal or regulatory obligation; and (iv) to fulfill our legitimate interests, unless your fundamental rights and freedoms override those interests.

Data Subject Rights. Subject to certain conditions, if you are a resident of the EEA or UK and have submitted Personal Information to us, you have the following rights regarding your Personal Information:

• Access. You have the right to access certain information about how we process your Personal Information, including the categories of Personal Information that we process, our purposes for processing, and with whom we have shared your Personal Information.
• Correction. You have the right to rectify inaccurate Personal Information concerning you and, in certain circumstances, the right to rectify incomplete Personal Information.
• Erasure. You have the right to erasure of your Personal Information in certain circumstances, including when the Personal Information is no longer necessary for the purposes for which we collected it.
• Portability. Where processing is based on your consent or on a contract, you have the right to obtain a copy of the data concerning you in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from us.
• Object to Processing. You have the right to object to our processing (including our automated processing) of your Personal Information based on our legitimate interests, in certain circumstances.
• Restrict Processing. You have the right to request that we restrict processing (including our automated processing) of your Personal Information in certain circumstances.
• Complaints. You have the right to lodge a complaint with your local competent supervisory authority.

Withdrawal of Consent. Where you have given us explicit and valid consent to collect, use, and process your Personal Information, we will rely on your valid consent. In instances in which we have based our processing of your Personal Information on your consent, you have the right to withdraw your consent. To withdraw such consent, please contact us through the methods listed below. Please note that when you withdraw your consent, we might not be able to provide you with Services. In certain situations, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a basis to do so. For example, we may retain certain information if we need to do so to comply with a legal obligation or if it is necessary to do so to pursue our legitimate interest in keeping the Services safe and secure.

Submitting GDPR, UK GDPR or DPA Requests. You may submit a GDPR, UK GDPR or DPA request regarding your Personal Information by email at [email protected]. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to applicable laws.

Subsidiaries and Affiliates. Lionsoul is part of the Lionsoul group of entities which includes our parent, Lionsoul Global Inc., and its subsidiaries. Each of these entities may process your Personal Information in order to provide you with the Services. If more than one of the Lionsoul group entities jointly determines the means and purposes of processing your Personal Information, these entities will process such Personal Information as “joint controllers” for the purposes of the GDPR, UK GDPR and the DPA. We adhere to the requirements imposed by the GDPR, UK GDPR and DPA in relation to the establishment of “joint controller” relationships between Lionsoul group entities. If you wish to know more or exercise your rights under the GDPR, UK GDPR or DPA in relation to the processing of your Personal Information by Lionsoul group entities operating on a “joint controller” basis, please contact us using the channels that can be found at the bottom of this Privacy Policy.

We retain your Personal Information for as long as reasonably necessary for the purpose for which the information was collected, or as may be required by applicable law. The precise length of time will depend on the type of Personal Information, our legitimate business needs and other legal requirements that may require us to retain it for certain minimum periods. In determining the appropriate retention period for different types of Personal Information, we always consider the amount, nature and sensitivity of the Personal Information in question, the potential risk of harm from unauthorized use or disclosure of that Personal Information, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition to ensuring that we comply with our obligations under applicable law). Where we no longer need your Personal Information, we will anonymize or securely destroy it. We use reasonable administrative, technical, and physical safeguards and measures to prevent unauthorized access, use, or disclosure of your Personal Information. Although we exercise reasonable care in providing secure transmission and storage of information you provide to us through the Services, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information that you transmit to the Services.

Our Services are operated and administered by us in the United States. If you use our Services, or contact us from outside the United States, please be advised that (i) any Personal Information you provide to us or that we automatically collect will be transferred to the United States; and (ii) by using or submitting Personal Information through our Services, you acknowledge that we may transfer and subsequently process your Personal Information in the United States, and other countries in which we operate, in accordance with this Privacy Policy. Please be advised that the United States and other countries may not offer the same privacy protections as the laws of the jurisdiction where you reside or those of the Cayman Islands, although appropriate safeguards will be implemented in accordance with the DPA. If you are a resident of a country located in the EEA or the UK and the GDPR or UK GDPR applies to our processing of your Personal Information, we will comply with our obligations under the GDPR and UK GDPR when carrying out restricted transfers of your Personal Information, including by implementing adequate safeguards in respect of any such transfers.

Our websites are not intended for children under 13 years of age. If you are under 13 years of age, please do not use or provide any information through the websites or on or through any of its features. If we learn we have collected or received Personal Information from a child under 13 years of age without authorization, verification, or parental consent, we will promptly delete that information.

Our Services are operated and administered by us in the United States. If you use our Services, or contact us from outside the United States, please be advised that (i) any Personal Information you provide to us or that we automatically collect will be transferred to the United States; and (ii) by using or submitting Personal Information through our Services, you acknowledge that we may transfer and subsequently process your Personal Information in the United States, and other countries in which we operate, in accordance with this Privacy Policy. Please be advised that the United States and other countries may not offer the same privacy protections as the laws of the jurisdiction where you reside or those of the Cayman Islands, although appropriate safeguards will be implemented in accordance with the DPA. If you are a resident of a country located in the EEA or the UK and the GDPR or UK GDPR applies to our processing of your Personal Information, we will comply with our obligations under the GDPR and UK GDPR when carrying out restricted transfers of your Personal Information, including by implementing adequate safeguards in respect of any such transfers.

Under California Civil Code Section 1798.83, California residents are entitled to request and obtain from Lionsoul once per calendar year information about when we share your Personal Information with third parties for those third parties’ own direct marketing purposes. To request this information, please contact us through one of the methods in the Contact Us section below and indicate “California Shine the Light” in the subject line. In the past year, Lionsoul has not shared Personal Information with third parties for those third parties’ own direct marketing purposes.

We reserve the right to change, modify, add, or remove sections of this Privacy Policy at any time. Please review this Privacy Policy periodically for updates. If we make a material change to the way we intend to use your Personal Information, we will notify you by modifying the date updated at the beginning of this Privacy Policy.

If you have questions regarding this Privacy Policy, please contact us through one of the methods listed below. Please include “Privacy Inquiry/Request” in the subject line of your inquiry. Additionally, if you have complaints about our processing of your Personal Information, you may have the right to lodge a complaint with the applicable supervisory authority in the jurisdiction where you reside. By mail: Lionsoul Global Advisors 106 E. 6th St, Suite 900-160 Austin, TX 78701 By email: [email protected]

This Section 21 (Notice Regarding Apple) only applies to the extent you are using our mobile application on an iOS device. You acknowledge that these Terms are between you and Lionsoul only, not with Apple Inc. (“Apple”), and Apple is not responsible for the Services or the content of it. Apple has no obligation to furnish any maintenance and support services with respect to the Services. If the Services fails to conform to any applicable warranty, you may notify Apple, and Apple will refund any applicable purchase price for the mobile application to you. To the maximum extent permitted by applicable law, Apple has no other warranty obligation with respect to the Services. Apple is not responsible for addressing any claims by you or any third party relating to the Services or your possession and/or use of the Services, including: (1) product liability claims; (2) any claim that the Services fails to conform to any applicable legal or regulatory requirement; or (3) claims arising under consumer protection or similar legislation. Apple is not responsible for the investigation, defense, settlement, and discharge of any third-party claim that the Services and/or your possession and use of the Services infringe a third party’s intellectual property rights. You agree to comply with any applicable third-party terms when using the Services. Apple and Apple’s subsidiaries are third-party beneficiaries of these Terms, and upon your acceptance of these Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as a third-party beneficiary of these Terms.