Important legal information (Disclaimer) and data privacy policy of Serafin Asset Management Ltd

Important legal information concerning investment instruments, products, and services («Financial Products»)

The website of Serafin Asset Management Ltd (hereinafter called "SAMCH") contains information and opinions about investment instruments, products, and services (hereinafter called "financial products"). By visiting the SAMCH website (www.serafin-am.com) you confirm that you have carefully read and understood the following important legal information for financial products.

Local legal restrictions

The content of this website is not intended for persons who are subject to a jurisdiction that prohibits the publication or accessing of this content (on the basis of the nationality of the respective person, their place of residence, or for other reasons). Persons who obtain the aforementioned publications must inform themselves about any possible restrictions, and must adhere to these.

Units of SAMCH may be distributed only in the following countries:

• Switzerland (private and professional clients): all Funds
• Germany (private and professional clients): AMG Europe Fund, AMG Schweizer Perlen Fund, ALPORA Innovation Europe Fund, and Innovation World Large Caps by AMG Fund, AMG Gold Mines & Metals
• Singapore (accredited investors only): ALPORA Innovation Europe Fund

The fund-specific information on this website qualifies as advertising and an offer pursuant to the FIDLEG, but not a financial service.

This website is intended for investors domiciled in Switzerland.

Investment performance

Falls in the value of investments and yields cannot be ruled out. Results achieved in the past provide no guarantee of future performance. We do not offer you or third parties any investment or other consultancy on this website. You may not make reference to information or material on this website to make or broker investments or to make or forward other decisions.

Not a recommendation

The information and expressed opinions contained on this website do not represent an invitation, offer, or recommendation to buy, sell or alienate an investment or to participate in a transaction or to render a consultancy or investment service.

Waiver of additional duty to provide information

Before investing in a financial product, the investor should carefully read the available current legal documents as well as all other documents that may be required pursuant to local statutory and regulatory provisions (e.g. the prospectus, the key information document - PRIIP as well as the annual and interim reports of an investment fund). Detailed examination of the legal notices and risk information contained therein is particularly important. Before making an investment decision, it is also recommended that the investor should consult a specialist. The visitor to this website herewith waives additional information from SAMCH.

Risk notice

As a general rule, the higher the risk (price fluctuations), the longer the investment period should be, and the higher the potential returns. The value of the invested capital as well as the income flowing from it (e.g. distributions in connection with collective capital investments) are subject to fluctuations or may cease altogether.

Investments in foreign currencies are directly and indirectly subject to exchange rate fluctuations. Individual financial products are generally subject to higher risks (e.g. collective investment schemes that invest primarily in emerging markets and/or in shares of low-capitalized companies and/or in high-yield bonds).

The main risks are described in detail in the respective current fund documents, which should be read carefully before investing.

Links to other websites

Links exist to this website that leads to third-party websites. These links are completely beyond the control of SAMCH. For this reason, SAMCH accepts no responsibility whatsoever for the accuracy, completeness, and lawfulness of the content of such websites, or for any possible offers and services contained therein.

No warranty and no guarantee

All information has been compiled by SAMCH with the greatest care. The published information and opinions derive from sources that we consider to be reliable. We do not warrant, however, that the information contained in this publication is accurate, complete, and up to date. Its content may change at any time on account of certain circumstances, whereby we are under no obligation to update information that has already been published.

Disclaimer

To the extent permitted by law, SAMCH and its contracting partners reject any liability (including negligence and liability vis-à-vis third parties) for any possible losses arising out of direct, indirect, or consequential damages of any nature whatsoever that are linked to the use of the website and its content or with financial market risks.

Information about Copyright and reproduction rights

The entire content of this website is subject to copyright and all rights to this are reserved. In the absence of the prior written consent of SAMCH, you are not permitted to reproduce, forward (by electronic means or otherwise), amend, link, or use the SAMCH website (wholly or in part) for a public or commercial purpose.

Applicable law/place of jurisdiction

Accessing and use of this website as well as the present important legal information for financial products are governed by Swiss law. The place of jurisdiction is Zug.

Data Privacy Policy of Serafin Asset Management Ltd

1. General points

This Privacy Policy describes the collection and processing of personal data at SAMCH and specifies how we use your personal data in connection with your activities on our website, mobile app, and social media presence. As the operator of the website, SAMCH is responsible for handling your personal data and upholding the rights of the individuals concerned.

‘Personal data’ is defined as all information relating to specific or identifiable natural or legal entities (e.g. name, date of birth, address, email address, app usage).

‘Processing’ is defined as any handling of personal data, irrespective of the means and processes applied, especially the procurement, storage, use, modification, publication, archiving, deletion, and destruction of personal data.

2. Scope and purpose of data processing

In general, the use of our website does not require you to disclose any personal data. We do not process personal data unless you contact us via the contact form or register for an event via our website and thus provide us with your personal data yourself.

The personal data we process may include the first name, surname, postal address, email address, phone number, job title, and business address of the enquirer. We process personal data for communication and administration purposes.

Monthly and annual reports will not be sent out unless you consent to the respective processing of your personal data.

3. Security and confidentiality

SAMCH undertakes to protect personal data and privacy in compliance with the applicable laws, specifically the data privacy laws. When handling your personal data, SAMCH will take all appropriate measures suitable to protect your data against loss, misuse, unauthorized access, transfer, modification, or destruction.

All personal data will be processed in Switzerland and stored on servers based in Frankfurt or Paris.

We will not make your personal data available to third parties. Nevertheless, some of our service providers may have access to certain personal data, especially during the repair and maintenance of our IT systems.

We hereby point out that security gaps may exist in the transfer of data via the internet (e.g. email communications). Complete protection of data against access by third parties is not possible.

4. Disclosure of personal data

We are entitled to transfer your personal data to third parties in the context of the applicable legal and statutory requirements or based on decisions by official authorities or for purposes of law enforcement.

5. Cookies

Cookies consist of text files placed on your device according to our specifications which allow us to analyze your use of the website. After your visit, most of the cookies placed by SAMCH are automatically deleted (session cookies). Other cookies (permanent cookies) will be stored and allow us to recognize you when you next visit the site. This places SAMCH in a better position to provide you with suitable information and support your access and use of our website. You may prevent the placement of cookies by deactivating them in your browser. Please note that the deactivation of cookies may restrict the use of your browser.

Google Analytics

Our website uses Google Analytics, a web analysis service offered by Google Inc. (‘Google’). Google Analytics uses so-called ‘cookies’, which are text files placed on your computer to help the website analyze how you use the site. The information generated by the cookies about your use of the website, such as

• browser type/version,
• operating system,
• referrer URL (page last visited),
• host name of the accessing computer (IP address),
• time of server request,

will usually be transmitted to and stored by Google on servers in the USA. Google will not associate the IP address transferred by your browser in the Google Analytics context with any other data held by Google. Moreover, IP anonymity will be guaranteed on this website. This ensures that your IP address is masked and all data are collected anonymously. Your full IP address will be transferred to US Google servers and shortened in the USA in exceptional cases only.

On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for the website operator, and providing other services relating to website activity and internet usage. You may prevent the storage of cookies by selecting the appropriate settings on your browser; however, in this case, you may not be able to use the full functionality of this website.

You may prevent the collection of cookie-generated personal data which relate to your use of the website for Google (including your IP address), and the processing of these data by Google, by downloading and installing the browser plug-in available through the following link: tools.google.com/dlpage/gaoptout. Especially in the case of browsers on mobile devices, instead of using the browser add-on, you may also prevent data collection by Google Analytics by clicking [this link]. An opt-out cookie will be set that prevents the collection of your data during future visits to this website. The opt-out cookie, which applies only to this browser and only to our website, will be stored on your device. If you delete the cookies in this browser, you must reset the opt-out cookie.

Vimeo

We use the service of Vimeo for the display of videos: The operator of the site is Vimeo.com, Inc., 555 West 18th Street, New York, New York 10011, USA. When you visit our site equipped with a Vimeo plugin, a connection to the Vimeo servers is established. In doing so, the Vimeo server is informed that you have visited our website. If you are logged into your Vimeo account, you enable Vimeo to assign the visit to our site to your user account. You can prevent this by logging out of your Vimeo account. For more information on the handling of user data, please see Vimeo's privacy policy at https://vimeo.com/privacy.

6. Your rights

You have the right to request information about your stored personal data or withdraw your consent regarding our processing activities at any time. Furthermore, you have the right to request the correction of any incorrect data, restriction of access, or deletion of all of your personal data.

SAMCH will delete all of your personal data as soon as all processing purposes have been concluded and any obligation to retain the data has expired.

If you are under the impression that your rights under the data privacy laws have been violated, you may address a complaint to the responsible data protection authority.

7. Amendments

SAMCH will review this Privacy Policy at regular intervals and will occasionally amend the policy as appropriate. In this sense, your continued use of this site will pass for your agreement with such amendments. We shall inform you of any amendments in a suitable form.

8. Contact

If you have any questions or requests, please do not hesitate to contact us at: fonds@serafin-am.com, stating ‘privacy policy’ in the subject line, or write to Serafin Asset Management Ltd, Bahnhofstrasse 29, 6300 Zug, Switzerland.

Zug, September 15, 2023