We collect personal information about you in connection with our providing advisory services to you. This information includes your National Identification Number, if you are a citizen of the Federal Republic of Nigeria, or standard identification method equivalent to bank account opening clearance, in the case of non-Nigerian citizens, and may include other information such as your:

1. Assets
2. Investment experience
3. Transaction history
4. Income
5. Bank account information
6. Wire transfer instructions

We collect this information from you through various means. For example, when you give us your contact information, enter into an advisory contract with us, buy securities arranged via advisory activities from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies.

Given the nature of our advisory practice which is at the intersection of finance, on certain occasion we may be required to share clients’ and investors’ personal information to run our everyday business. The personal information we collect from you enable us for example:

1. To provide advisory services to you
2. To process a transaction for your account
3. To market products and services to you
4. To respond to court orders, regulatory requests, and legal investigations

We may provide your personal information to our affiliates and to firms that assist us in servicing your advisory account and have a need for such information, such as an artist or art gallery or art dealer or auction house or art museum. We may also disclose such information to service providers and financial institutions with whom we have joint investment or marketing arrangements (i.e., a formal agreement between non-affiliated financial companies that together market or manage financial products or services to you, such as wealth managers or commercial bankers or insurers).

We require third-party service providers and financial institutions with which we have joint investment or marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Nigerian or most cross jurisdiction privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that most cross jurisdiction privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you).

To protect your personal information from unauthorized access and use, we use security measures that comply with Nigerian or most cross-jurisdiction privacy. These measures include computer safeguards and secured files and buildings.

The European Union’s General Data Protection Regulation (EU) 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of the law of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”), as supplemented by the Data Protection Act 2018, (together the “Applicable Data Protection Laws”) govern the use of personal data by Gouden Fara Limited where EU and UK citizens are advised by us outside their registered jurisdictions. Gouden Fara Limited recognizes the importance of protecting the privacy of clients and investors in its advisory business, in accordance with the Applicable Data Protection Laws, asks that you please read this privacy notice carefully to understand how we collect, share, and protect the personal information of clients and investors in our advisory offerings.

Our service providers and Gouden Fara Limited’s affiliates may process the following types of personal data in connection with our providing advisory services to you:

• Personal data provided by you to us including: your name, address, contact information, birthdate, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank and brokerage details, investment experience, tax residency, and tax identification information;
• Personal data collected or generated by us in the course of business and advisory activity including: information related to emails (and related data), correspondence, call recordings, and website usage data;
  and
• Personal data obtained by us from other sources, including: know your client (Know Your Client) / client due diligence procedures (anti-money laundering (“AML”), counter-terrorist financing (“CTF”), proliferation
  financing, sanctions, politically exposed persons), tax purposes (US Foreign Account Tax Compliance Act (“FATCA”), OECD Common Reporting Standard (“CRS”)), future regulatory, securities, and tax requirements, information from public websites, public sources of information, and information received from your advisors or intermediaries.

Given the nature of our advisory practice which is at the intersection of finance, on certain occasion we may be required to share clients’ and investors’ personal information to run our everyday business. The personal information we collect from you enable us for example:

Performance of a contract including:

• Where you subscribe for interests in any of the advisory services or investment offerings, your personal data will be processed in accordance with our internal investor assessment procedures to determine
  whether we may permit you to invest or participate and whether your subscription documents are
  acceptable. Such processing may be undertaken prior to entering into a contract at your request;
• Where we accept your subscription documents to subscribe to our advisory services or investment offerings and you provide to the appropriate parties all required documentation, your personal data will be entered into the books of the advisory or investment program; personal data will be processed in this regard;
• Where you are a client or an investor, processing your personal data is necessary for managing and administering your holdings in any related account as well as for distribution payments and for increased
  commitments to an investment; and
• Where circulating periodic reports in relation to any related services and account is required by relevant agreements or regulations.
  Compliance with a legal obligation including:
• Where it is necessary to comply with any applicable current or future legal, regulatory, or tax requirements imposed on the advisory services or investment offerings, we and/or any third party service provider, prior to your investment in any of the offerings, during your investment in any of the offerings, or after you have exited any or part of your investment in any of the offerings, will process your personal data in accordance with legal obligations under company law, tax law, AML, and CTF legislation, including:
• AML/CTF or Ultimate Beneficial Ownership legislation and regulations may require us to identify prospective, existing, or previous investors and, as such, certain information will be required at the time of application as set out in relevant agreements which will be processed accordingly; and
• FATCA/CRS regulations may require us to collect certain information about each prospective, existing, and/or previous investors’ tax arrangements. For FATCA/CRS reporting purposes, please note that in
  certain circumstances we may be legally required to share such information, and other financial information with respect to an investor’s interests with relevant tax authorities, and we may be legally restricted from disclosing to you that such processing is undertaken.

Legitimate interests, including:

• Carrying out the ordinary or reasonable business activities of any investment offerings (including marketing activities), or other activities previously disclosed to the investors or referred to in this Privacy Notice;
• Ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;
• Disclosing information to third parties as provided for in this Privacy Notice; and
• Recording, maintaining, storing, using written correspondence, emails, duplicates and/or telephone calls that you make to and receive from us, any third party service provider and their delegates or duly appointed agents and any of their respective, related, associated, or affiliated companies for processing and verification of instructions, management, and administration of your account(s), as well as any other matters related to the investment, dispute resolution, record keeping, security, and/or training purposes.

We may disclose your personal data to the following recipients:

• Affiliates and third party service providers who are engaged in connection with the investment management, oversight, legal obligations, administration, distribution, operation of the investment and its
  assets or for purposes of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this Privacy Notice;
• The advisory or investment vehicle‘s professional advisors, bankers and brokers, auditors, IT, and other service providers; and
• Competent authorities (including tax authorities), regulators, courts, law enforcement agencies, and other regulatory entities as required by applicable law, or as requested by such entities, our affiliates, or third party service providers for internal investigation and reporting purposes or in order to establish, exercise or defend our legal rights. Some of these parties will process your personal data in accordance with our instructions and others will themselves be responsible for their use of your personal data. These parties may be permitted to further disclose the personal data to other parties.

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data as under the Applicable Data Protection Laws. Where a personal data transfer is made to a jurisdiction which provides a level of data protection lower than that prescribed by the Applicable Data Protection Laws, we will take steps to ensure the security and confidentiality of your personal data in accordance with the Applicable Data Protection Laws.

You can obtain more details of the protection given to your personal data when it is transferred to different jurisdictions, including a copy of any standard data protection clauses entered into with recipients of your personal data, by contacting us on inquiries@goudenfara.com.

We will ensure that appropriate technical and organizational measures are taken to safeguard against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data.

How long we hold your personal data for will vary. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which we must keep your personal data).

You have a number of legal rights in relation to the personal data that the advisory or investment vehicle holds about you. These rights include the following:

• The right to obtain information regarding the processing of your personal data and access to the personal
  data that the advisory or investment vehicle holds about you;
• In some circumstances, the right to receive certain personal data and the right to request that the advisory or investment vehicle transmits that data to a third party;
• The right to request that the advisory or investment vehicle rectifies your personal data if it is inaccurate or incomplete;
• The right to request that the advisory or investment vehicle erases your personal data in certain
  circumstances provided that the advisory or investment vehicle is not legally entitled to retain it;
• The right to object to, and the right to request that advisory or investment vehicle restricts, its processing of your personal data in certain circumstances provided that the advisory or investment vehicle is not legally entitled to continue processing your personal data or to refuse that request; and
• The right to lodge a complaint with the data protection regulator if you think that any of your rights have been infringed by the advisory or investment vehicle.