Twenty Seven Miles Capital DWC-LLCand/or its affiliates (collectively “27 Miles Capital”, “we” or “us”) value your security and privacy. 27 Miles Capitalis subject to the Personal Data Protection Law, Federal Decree Law No. 45 of2021 regarding the Protection of Personal Data (the “UAE’s PDP Law” or “UAE’s PDPL”), and may for certain types of personaldata processing, be subject to laws from other jurisdictions, including but notlimited to Regulation (EU) 2016/679 of the European Parliament and of theCouncil of 27 April 2016 on the protection of natural persons with regard tothe processing of personal data and on the free movement of such data, andrepealing Directive 95/46/EC (the “General Data Protection Regulation” or “GDPR”).

As such, it is the policy of 27 MilesCapital to respect the privacy of our 27 Miles Capital website users. In accordance with the UAE’s PDPL and asapplicable in our terms of use, 27 Miles Capital collects information about youwhen you use or access our websites, use 27 Miles Capital email addresses forcontact purposes (collectively, the “Website Services”) as well as through otherinteractions and communications you have with us.

This online data protection policy (the “Policy")sets out the basis on which any information, including any personal data, we collect from you, or you provide to us, will be processed by 27 Miles Capital.Each time you access or use the Website Services or provide us with information, by doing so you acknowledge the practices described in thisPolicy.

This Policy applies to persons anywherein the world who access or use 27 Miles Capital’s Website Services (“Users”).

This is personal data you give us by providing information or filling in forms on any 27 Miles Capital-owned WebsiteServices, or by corresponding with us (for example, by telephone, e-mail or any other digital or electronic form). It includes for example information you provide when you use our Website Services or report a problem with our WebsiteServices. If you contact us, we will keep at least an electronic record of such correspondence, including personal information shared at that time, in order to reply or process it as per your request. The personal information you give us may include your name, address, e-mail address and phone number, certain device information and other information you choose to provide (“Personal Information” or “Personal Data”).

The Website Services collects and processes Personal Data for specific, lawful purposes only, or for the performance of tasks carried out in your interests.The Website Services is not targeted, intended or expected to be of use to children. Apart from providing information for specific services or purposes, as directed by the 27 Miles Capital processes, user-provided contributions of content or contact information regarding or about children are expressly prohibited.

Each time you use our Website Services, we may and often will automatically collect the following information:

•          Technical information, including the type of mobile device you use, a unique deviceidentifier (for example, mobile network information, your mobile operating system, the type of mobile browser you use, device token, device type, timezone setting (“Device Information”).

•          Details of your use of our Website Services, including but not limited to traffic data, weblogs and other communication data, and the resources that you access (“LogInformation”).

•          Location information if the Website Services uses GPS technology to determine your current location. If you wish to use the particular feature, you may be asked to opt-in to your data being used for this purpose.

If you do not wish to share certain data with us or do not want us to use / share it for certain purposes (to the extent possible, in accordance with applicable laws and information in this notice),you can alter your preferences at any time. Where applicable, please check with your device provider's instructions for further information about how to do this.

When you use any Website Services, we may collect Personal Data, including demographic information, for example information that you submit, or that we collect, which may include, but is not limited to, post code, age/birth date, current residence, hometown, gender, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, business activities and services / distribution locations, browsing history information, search history information and registration history information (“Demographic Information”).

We may use Personal Data which youprovide to us or we collect from you to:

•          Provide, maintain and improve our Website Services, including, for example, to provide products and services you request (and send related information about them), develop new features that will enhance your user experience and our efficiency, provide customer support to Users, authenticate users and send administrative messages, whether information-only or required by applicable law;

•          Perform internal regulatory, administrative and operational requirements, including, for example, to prevent fraud or abuse of our Website Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing and research; to ensure you and 27 Miles Capital are complying with internal or external legal requirements, including those that necessitate use of digital systems; and to monitor and analyse usage and activity trends;

•          Send you communications we think will be of interest to you based on your previous interactions with us, including information about products, services, promotions, news, and 27 Miles Capital events, where permissible under DubaiAviation City Corporation Laws and according to any other applicable laws;

•          Notify you about changes to this Policy or our Website Services;

•          Allow you to participate in any interactive features of our Website Services;

•          Keep our Website Services safe and secure; or

•          Personalise and improve the Website Services, including to provide or recommend features, content, social connections, referrals and advertisements, in accordance with your preferences, to the extent permissible by law.

We will take all steps reasonably necessary to ensure your data is processed fairly and lawfully, in accordance with the UAE’s PDPL, other applicable laws and this Policy. By submitting yourPersonal Data (including Log, Device and / or Demographic Information), we expect you to understand that such transfer, storing or processing in order for27 Miles Capital to provide its services is necessary and will be done in a proportionate, lawful manner, including but not limited to, responding to enquiries you raise via the Website Services and maintaining contacts for future informational or promotional activities. Unless otherwise notified, 27Miles Capital does not ordinarily rely solely on automated decision making when processing your Personal Data.

In order to conduct our operations or fulfil regulatory obligations, we must transfer thePersonal Data described in this Policy to and from, and process and store it in the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. In all such cases, and generally for any processing operations, we take appropriate security measures to protect your Personal Data in accordance with this Policy.

To preserve the integrity of our databases, to carry out ongoing Website Services, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users fora reasonable length of time unless otherwise prescribed by applicable law.

27 Miles Capital is not responsible for the accuracy of the information you provide and will modify or update your Personal Data in our databases when you provide updated information or ad hoc upon your request, as further outlined below. We will erase or put beyond active use your Personal Data upon request, unless we are required to retain it in accordance with UAE’s PDPL or other applicable laws or to perform agreed services, in which case, we align with applicable principles, such as purpose specification and data minimization.

If it is not disproportionate or prejudicial, and required beyond this policy’s notices, we’ll contact you to let you knowwe are processing your personal information.

By accessing or using the Website Services to which this Policy applies, we can reasonably expect that you understand that all information submitted by you through theWebsite Services or otherwise to 27 Miles Capital may be used by 27 MilesCapital to support these processing operations, in accordance with applicable laws and its policies.

We may sharePersonal Data that we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

We may share yourPersonal Data:
•          With third parties to provide you a service you requested; or
•          With third parties with whom you choose to let us share your PersonalData, for example, other apps or websites.

We may share yourPersonal Data:
•          With 27 Miles Capital subsidiaries and affiliated entities, to the extent permissible by law;
•          With vendors, consultants, marketing and advertising partners, and other service providers who need access to such Personal Data to carry out work on our behalf or to perform a contract we enter into with them;
•          If we otherwise notify you and you provide your affirmative opt-in to share your data, where needed;
•          In response to a request for information by a competent authority or government entities if we determine that such disclosure is in accordance with or is otherwise required by any applicable law, regulation or legal process;
•          With law enforcement officials, government entities or authorities, or other third parties as required by applicable law;
•          With third parties in connection with or during negotiations of any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company; or
•          With third parties in an aggregated and/or anonymized or pseudonymized form that cannot reasonably be used to identify you.

In some circumstances we are legally obliged to share information with public authorities or law enforcement. For example, we may be required to provide information related to a court order.

We might also share information with regulatory bodies in order to further their objectives.In any scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information, document our decision making and satisfy ourselves that we have a legal basis on which to share the information.

We may also share information in the event of the non-payment of a service fee. If the debt remains outstanding after the specified timeframe for payment, no payment plan is in place or an agreed payment plan is not being adhered to, we may initiate formal proceedings to recover the full amount of the unpaid fee.

As a result, the relevant 27 Miles Capital officer will share Personal Data with the litigation and recovery specialists it instructs in order for them to identify assets and undertake recovery action through the courts.

We may sharePersonal Data that we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

27 Miles Capital supports Users’ legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You have the option to ask us not to process your PersonalData for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our Website Services.

Please note that we may continue to send you service-related e-mails despite your desire to not receive promotional or marketing e-mail messages.

Additionally, please note that while we may remove your individual contact information fromour professional contacts database, if such information is in a different, third party's marketing directory through your request or election, you willneed to request removal with such third party directly.

You have the right to access information held about you. Your right of access can be exercised for any reason, at any time, in accordance with UAE’s PDPL and other applicable laws.

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

You may also request that we restrict the processing of, erase, transfer the information you gave us from one organisation to another, or otherwise process your PersonalData in line with the relevant articles providing for such rights set out in the UAE’s PDPL or other applicable laws.

Any access request generally comes at no cost to you, and we must respond within one month unless provided otherwise by the UAE’s PDPL or other applicable laws.

When you contact us about a potential Personal Data error or query, we will endeavour to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavour to send a correction notice to businesses or others whom we know to have received the inaccurate data, where required and / or appropriate. However, some third parties and third-party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files.

27 Miles Capital makes every effort to ensure that your Personal Data is secure on its system.Unfortunately, no data transmission over the internet can be guaranteed to be100 per cent secure. As a result, 27 Miles Capital cannot warrant or guarantee the security of any Personal Data you transmit to us, and you do so at your own risk.

27 Miles Capital has established policies and procedures for securely managing information and protecting Personal Data against un authorised access. We continually assess our data privacy, information management and security practices. We do this in the following ways:
•          Establishing policies and procedures for securely managing information;
•          Limiting employee access to viewing only necessary information in order to perform his or her duties;
•          Protecting against un authorised access to Personal Data by using data encryption, authentication and virus detection technology, as required;
•          Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements; and
•          Monitoring our websites through recognised online privacy and security organisations;

If you have any further questions about our security and processing activities, please contact our team or refer to our terms of use. To the extent permitted by applicable law, 27 Miles Capital expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit through fraud or otherwise where it is no fault of 27 Miles Capital.

A cookie is a small text file that is unique to the web browser on your computer or mobile device, which is used to retain user preferences and enhance browsing experience ("Cookie"). 27 Miles Capital uses Cookies to track overall site usage and enables us to provide a better user experience. We do not use Cookies to “see” other data on your computer or determine your email address.

Types of cookies we drop and the information collected using them include, but are not necessarily limited to:

‍Essential
‍Google TagManager: helps make tag management simple, easy and reliable by allowing marketers and webmasters to deploy website tags all in one place.

‍Site Analytics
‍Google Analytics:gives website owners the digital analytics tools needed to analyse data from all touchpoints in one place, for a deeper understanding of the customer experience.

‍Advertising
‍•          DoubleClick: a subsidiary of Google that develops and provides internet ad serving services.
•          Twitter advertising: enables website owners to track and measure the actions users take after viewing or engaging with ads on Twitter.
•          Facebook advertising: lets website owners measure, optimise and buildaudiences for advertising campaigns.
•          LinkedIn analytics: enables website owners to promote their company updates to targeted audiences on desktop, mobile, and tablet.

Most browsers accept and maintain Cookies by default. Check the ‘Help’ or ‘Settings’ menu of your browser to learn how to change your Cookie preferences. You can choose to alter Cookies settings related to the use of our Website Services, but this may limit your ability to access certain areas of the Website. For information on how to do this on the browser of your mobile phone, you will need to refer to your handset manual or network operator for advice.

The Website maycontain links to other websites on the Internet that are owned and operated bythird parties (the "External Sites"). These links are provided solelyas a convenience to you and not as an endorsement by 27 Miles Capital of the contentsor reliability of such External Sites. You acknowledge that 27 Miles Capital isnot responsible for the availability of, or the information and contents of anyExternal Site. You should contact the site administrator or webmaster for thoseExternal Sites if you have any concerns regarding such links or the contentlocated on such External Sites.

If you decide to access the linked third-party websites, you do so at your own risk. 27 MilesCapital does not accept liability and shall not be liable to you for any loss or damage arising from or as a result of your acting upon the contents of another website to which you may link from the Website Services.

We may change this Policy from time to time and without notice. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavour to provide you notice through the Website Services or by some other means, such as email. Your continued use of the Website Services after such notice constitutes your understanding of the changes. We encourage you to periodically review thisPolicy for the latest information on our privacy practices. We provide links to it through:
•          The Website Services;
•          Referencing it in our Terms of Use; and
•          Incorporating it into our contracts, agreements and other documents as necessary or appropriate.

If you have any questions, comments and requests related to this Policy, or if you have any complaints related to how 27 Miles Capital processes your personal data, please contact our Office at: UAE, Dubai, Dubai South Area, Business Park - A2, Floor Number 4, Premises No. 401, +971 52 155 4109, aleksandra@27milescapital.com