NatureAlpha Privacy Notice and Policy and Cookie Policy

NatureAlpha Group Ltd (an English registered company with registered number 13300629)and any other companies in the NatureAlpha group of companies (“NatureAlpha”,“we”, “us”, “our” “affiliate”) are totally committed to protecting your personal data and respecting your privacy. We want to maintain the trust and confidence of every customer and other person dealing with us. This Privacy Notice should be read along with our terms and conditions of use found on our website, and this PrivacyNotice and website terms of use shall apply both to our website and any sub-domains unless such sub-domains expressly exclude the Privacy Notice or terms of use. This Privacy Notice and terms of use do not extend to or apply with respect to, any third party website which you access through any links on our website.

Reference in this Privacy Notice to “NatureAlpha”, “we”, “us”, “our”, means the applicable NatureAlpha company with whom you have an agreement or with whom you have provided your personal data to. Providing any data including your personal data to one of the NatureAlpha companies does not automatically mean that all other NatureAlpha companies have received it although NatureAlpha does share personal data with other affiliate companies as provided for below. More details about the NatureAlpha group of companies are outlined in section 1.1below, as may be updated from time to time.

The applicable NatureAlpha company that collects your data is the data controller for the purposes of this Privacy Notice. This Privacy Notice applies only to third parties using or accessing our website or sub-domains or otherwise by any other means and does not apply to employees or candidates for employment, which is covered by a separate Privacy Notice for such purposes.

This Privacy Notice gives you detailed information on when and why each applicable member of the NatureAlpha group of companies collects your personal data, what personal data we collect, how we use it, and how we keep it secure. It also sets out some information about your rights and how you can complain, either tous or to the Information Commissioner's Office in the United Kingdom.

1. Who are we and how can you contact us?

1.1 Nature Alpha Group Ltd is a private limited company incorporated in England andWales. We are a data controller in the United Kingdom. The whole of theNatureAlpha group of companies regard the UK Information Commissioner’s Officer as the Lead Authority for the purposes of data protection compliance.

Any questions regarding this Privacy Notice, our privacy practices, or any information we hold about you can be sent to us by:

• email: dataprivacy@naturealpha.ai;

or
• telephone: + (44) 2030267123

or by writing to:

Nature Alpha Group Ltd

33 St James’s Square, London SW1Y 4JS,

FAO Data Privacy

2. When do we collect information about you?

2.1 Some of the information we collect about you can be used to identify you. This type of information is defined as "Personal Data" under the UK DataProtection Act 2018 (and the UK implementation of GDPR) and/or the EU GeneralData Protection Regulation (EU) 2016/679 ("GDPR") as amended or replaced by legislation applicable in the country of domicile of the applicableNatureAlpha company (“Data Protection Laws”). In this Privacy Notice we use the words "Personal Information" to talk about your Personal Data.

2.2 We collect your Personal Information:

(a) when you email, call us, text us or write to us or provide us with information in any other way, including by interacting with us via social media such asFacebook, Twitter, WhatsApp, YouTube, Google, LinkedIn or otherwise;

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(b) when you visit, or make enquiries, register, send any messages and/or purchase or receive products or information or any data from us through the NatureAlpha website ("Website") and/or through or via any third party platform or website;

(d) when you use any of our data, products or services;

(e) when you visit and use our Website and if cookies are placed on your computer or other device, which cookies are subject to our cookie policy set out in section 12 of this Privacy Policy;

(f) when you provide information to us in connection with any provision by us of any data, information, products or services, through whatever means; and

(g) when you choose to receive any marketing communications from us or our selected partners.

3. What types of PersonalInformation do we collect and process?

3.1 We process the following kinds of Personal Information if provided to us:

(a)Information about you, including your name, title, postal address, telephone number(s) and email/IP address/URL, gender, age, location, occupation, computer or device information, location, use of our data, services or other products, including why it was used and the benefits of use to you or others by you on their behalf;

(b) Information you provide as part of using any of our data, services or any products or relating to us or any service or product that we provide including from our chosen partners;

(c) Information you provide to us during communications you have with us and with our staff and agents, whether by email, social media, push notification, post, telephone, in person or through our Website, for example comments or queries or other information concerning the data, products and services we provide;

(d) financial and payment information if relevant to the services or products that we provide including if applicable, payment details;

(e) Credit and anti-fraud data including credit history, credit score, sanctions and any information to ensure that a crime is not committed, and information received from various anti-fraud databases relating to you or the company you represent;

(f) Information about your use of our Website or any other website including any information concerning the websites of third parties that you visit as from ourWebsite and all information about your browser and device usage;

(g) details of any other means of communication you use to contact us.

3.2 We automatically collect data from you when you access our Website, for example information about your visit to our Website so that we can make improvements to it and your experience, including how often you visit our Website, your IP address, location, the date, times and the way you interact with the Website and its content. Such data is also collected by cookies under our cookie policy which can be found at section 12of this Privacy Notice.

4. Why do we collect your Personal Information, how do we use it, and what are our lawful grounds for collection and use?

4.1 We collect and use your Personal Information for the following purposes:

(a) To provide our data, products and services in accordance with our contractual obligations (and/or in anticipation of them or for marketing purposes), for market research and also to keep you updated with your account and/or purchase of any products or services or where it is in our legitimate interest to do so in order to provide either products or other services, including:

(i)to provide quotes or prices to you and to set you up as a client or administrator of a client; and

(ii) to process and to manage orders or your use of our data, services, products or systems; and

(iii) to provide other services to you which you or the entity you represent have agreed to receive under any contract that we both enter into together or with our chosen partners.

(b) To communicate with you via email, post, text, push notification, social media, web chat or web message or any other communication method and to answer your questions and enquiries, in accordance with our legitimate interest to provide our products and services and manage any account.

(d) To prevent or detect fraud, in accordance with our legitimate interest to provide products and/or other services.

(e) Where legally required or where it is in our legitimate interests to provide products, marketing and/or other services and also to comply with requests froml aw enforcement and regulatory authorities.

(f) as part of your use of our Website and to improve our Website and systems and understand how to enhance your use and experience of it.

If you do not provide your Personal Information to us, we may be unable to provide you with our data, products and/or services or other information.

5. How do we share your Personal Information?

5.1 For the purposes specified above, the Personal Information that you provide to us (including any sensitive personal data as appropriate) may be shared with:

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(a) our officers, directors, contractors, consultants, employees, workers, agents and professional advisors (and those of our affiliate companies);

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(b) our chosen selected partners;

(d) credit agencies and payment providers who process payments and refunds;

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(e) our other service providers, including hosting providers;

(f) organisations such as any regulatory body with whom we have any responsibility to for the purposes of regulatory compliance, collection of or reporting of taxes and/or duties or imposts and the investigation, detection of, or prevention of, crime;

(g) prospective buyers or investors or providers of finance in the eventNatureAlpha wishes to attract investment, funding or to sell all or part of its business;

(h) any accounting or audit provider, marketing or communications provider and any analytical firm; and

(i) other companies within the NatureAlpha group of companies as an affiliate, for the purposes of (i) developing our data, products and services and enhancing them; (ii) reporting, management control, audit, administration and accounting purposes and (iii) for corporate governance, legal and regulatory purposes.

6. Where do we store your Personal information?

6.1 We store your Personal Information on our servers, which are managed by us or provided to us under an enforceable contract and are located within the UK and/or EEA. However, we reserve the right to process your Personal Information outside of the UK and/or EEA but will only do so, where we have in place adequate legal measures to protect that Personal Information, as provided for at section 8.3 below.

7. How long do we retain yourPersonal Information?

7.1 We will keep your Personal Information only for so long as is necessary and for the purpose for which it was collected or processed. In particular, we will keep your Personal Information for so long as there is any possibility that either you or we may wish to bring a legal claim under a supply agreement or under any other agreement with you or under which agreement we have collected your Personal Information, or where we are required to keep your PersonalInformation due to legal or regulatory reasons and have a lawful basis to do so.

7.2 Depending on the record types and our relationship with you, retention periods range from a short period which may be days or weeks or months but up to seven years or for the period during which we provide our services/have a lawful basis to do so, or as we are required under applicable law and regulation, whichever is the longer period of time.

7.3If you would like more detailed information about our retention policy, pleaseemail us at dataprivacy@naturealpha.ai

8. How do we protect your data?

8.1 We aim to keep your Personal Information secure. In order to prevent unauthorised access or disclosure, we use appropriate technical and organisational measures to keep the Personal Information we collect secure. Our service providers are required to do the same.

8.2 Unfortunately, transmission of information via the internet or other means is not completely secure. Although we will do our best to protect your PersonalInformation once we receive it, we cannot guarantee the security of yourPersonal Information transmitted to our Website, any other website linked by ours or through other electronic media; any transmission is at your own risk.Once we have received your Personal Information, we will use strict procedures and security features to try to prevent unauthorised access or loss in accordance with Data Protection Laws.

8.3We may need to transfer your data to other NatureAlpha group affiliates or oursuppliers, sub-contractors, credit check agencies, accountants, legal serviceproviders and providers of hosting services, and to other websites which arelocated inside or outside of the European Economic Area (EEA) and/or UK. Thosetransfers would always be made in compliance with the relevant legislation. Ifyou would like further details of how your personal data would be protected iftransferred outside the UK/EEA, please email us at dataprivacy@naturealpha.ai[2]

9. Your rights

9.1 You have a right to access your Personal Information to check that the information we hold about you is accurate and that it is being processed lawfully, and to request that it is corrected if you think it is inaccurate(see "How you can access and update your Personal Information"below).

9.2 You have the following rights:

(a) to request us to restrict the processing of your data (meaning that we could store it but not use it);

(b) to object to how we use your data; and

Our response will depend on the circumstances and our legal obligations and rights, including our obligations and rights under Data Protection Laws.

9.3 You also have the right to ask us to "port" (transfer in an electronic format) personal data to another provider if it is stored electronically, we received it from you, and if we are processing it on the grounds of your consent and not for the performance of a contract or other legitimate use basis.

For more information about your rights please see:https://ico.org.uk/your-data-matters/ or enquire of your local SupervisoryAuthority.

10. How can you access and update yourPersonal Information?

10.1 The accuracy of your Personal Information is important to us. You have the right to get information held about you by us corrected or removed, if it is inaccurate.

10.2 If you have any concerns about the accuracy of your Personal Information, or if you would like us to remove the Personal Information we hold about you, please let us know using the below contact details at section 10.3.

10.3 You can request full details of Personal Information we hold about you, including a copy of it by contacting dataprivacy@naturealpha.ai Please include a description of the information you would like to see, and in order for us to verify your identity, we may request proof of identity before we deal with your request.

11. Complaints to the ICO or other Supervisory Authority

11.1 If you are unhappy with the way that we treat your Personal Information please contact us and we will work with you to resolve your issue. You also have the right to contact the UK data protection authority, the Information Commissioner's Office ("ICO"). You can contact the ICO through its website: https://ico.org.uk/global/contact-us/. You can also call the ICO helpline from the UK on 0303 123 1113, or +44 1625 545 700 if calling from outside of the UK.

12. CookiePolicy

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

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A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or other electronic device. Cookies contain information that is transferred to your computer's or other electronic device’s hard drive.

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We use the following cookies:

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· Strictly necessary cookies.These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of ourWebsite, We use cookies only to auto-fill user name and your password of the user’s login process (credentials).

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· Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way ourWebsite works, for example, by ensuring that users are finding what they are looking for easily.

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· Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you

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· Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising or links displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

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You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

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*Table to be inserted

Except for essential cookies, all cookies will expire after XXXhours/days/months/years

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13. GoverningLaw and Changes to this Privacy Notice

13.1 This Privacy Notice is governed by the laws of England and the parties submit to the exclusive jurisdiction of the English Courts in respect of any of it. Any changes we may make to our Privacy Notice in the future will be posted on our Website.

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