Privacy Policy

Introduction

This Privacy Policy (hereinafter the ‘Privacy Policy’) applies to the Asset Class Website and Investor Portal (hereinafter the ‘Digital Platforms’) belonging to Explorer Investments, and has been created for the purpose of publicising Explorer Investments’ handling of the personal data of Users of said Platforms.

The availability of Users’ personal data implies the knowledge and acceptance of the conditions contained in this Privacy Policy. By using the Digital Platforms, you agree to the collection and use of your information as set out in this Privacy Policy.

The terms used here have the meaning given to them in this Privacy Policy, which is complemented by the Terms and Conditions of Use.

Responsible for the Processing of Personal Data

The entity responsible for processing the personal data collected through the Digital Platforms is Explorer Investments, legal 506454584, headquartered in Largo Jean Monnet, n.º 1 – 8.º, 1269-068, in Lisbon, with the telephone number (+351) 213 241820.

Users may contact Explorer Investments for any matter regarding the processing of their personal data referred to in this Privacy Policy, as well as the exercise of their rights mentioned therein, by e-mail to compliance@explorerinvestments.com or by letter to the address of Explorer Investments.

Personal Data Collected and Purpose

Access to and use of Digital Platforms does not imply the provision of personal data by the User. However, the use of certain features of the Website implies making available personal data by the User.

Such data will be treated by Explorer Investments to:

• Contact request: processed with your consent to manage the contact established and provide clarifications and information requested.
• Application: processed for pre-contractual due diligence and management of your application.

Legal Basis for Processing

• User’s consent, if based on a request for contact.
• Carrying out pre-contractual procedures at the request of the holder and recruitment process management, if based on the submission of an application.

Recipients of Personal Data

Explorer Investments may communicate the User’s personal data to contracted entities for service provision, maintenance of Digital Platforms, or to comply with legal obligations and court orders.

Maintenance of Personal Data

Data is retained only for the period necessary for the purposes collected, unless a specific legal requirement justifies longer storage.

User’s Rights

Users have the following rights:

• Right of access
• Right of rectification
• Right of deletion
• Right to limitation
• Right to portability
• Right of opposition
• Rights regarding automated decisions and profiling
• Right to lodge a complaint with the National Data Protection Commission

The exercise of these rights is free of charge, except in cases of manifestly unfounded or excessive claims.

Security

Explorer Investments applies its best efforts to protect the confidentiality of User’s personal information but cannot guarantee absolute protection against unauthorised access. Users are responsible for ensuring that devices used to access the Digital Platforms are secure.

Acceptance of These Terms

By using the Digital Platforms, you agree to this Privacy Policy. Changes will be posted on this website.

Updates and Changes

Explorer Investments may update or change this Privacy Policy. Please check regularly.

Law and Foro

This Privacy Policy is governed by Portuguese law, with disputes resolved by the courts of Lisbon.

Date: November 2024