SIERA Impact Growth Fund is committed to protecting your privacy and processing your personal data securely and responsibly. This Privacy Policy explains how we collect, use, store and disclose personal data when you visit our website [website URL] or use our services. This declaration is made in accordance with the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG).

1. information collected

a) Personal data:

This is information that can be used to identify you personally, e.g:

• Name
• E-mail address
• Postal address
• Phone number
• Investment preferences
• All other information that you provide to us voluntarily (e.g. via forms, inquiries or emails)

b) Non-personal data:

This information does not allow any conclusions to be drawn about your identity, e.g:

• Browser type
• IP address
• Date and time of access
• Referring website or search engine
• Website usage statistics

2. intended use of the data

We use your personal data in particular for the following purposes:

• Provision of information, offers and updates on investments
• Answering inquiries and contact forms
• Processing transactions and managing your investments
• Personalization of your user experience
• Fulfillment of legal and regulatory obligations

Non-personal data is also used to optimize the functionality, performance and user-friendliness of our website.

3. legal bases according to GDPR

In accordance with the General Data Protection Regulation (GDPR), we process your personal data on the basis of the following legal principles

• Consent (Art. 6 para. 1 lit. a GDPR): For example, when registering for a newsletter or when voluntarily submitting your data.
• Performance of a contract (Art. 6 para. 1 lit. b GDPR): If the processing is necessary for the performance of a contract or pre-contractual measures.
• Legal obligation (Art. 6 para. 1 lit. c GDPR): For example, to fulfill tax or regulatory requirements.
• Legitimate interests (Art. 6 para. 1 lit. f GDPR): If our legitimate business interests do not outweigh your fundamental rights and freedoms.

4. cookies and tracking technologies

We use cookies and similar tracking technologies to improve your user experience on our website. Cookies are small files that are stored on your end device and help us to better understand your usage behavior on our website. You have the option of deactivating cookies via your browser settings - however, this may restrict the use of certain functions of the website.

We may also use third-party services, such as Google Analytics, to analyze visitor behavior on our website. These third-party providers may also use cookies to collect information about your interactions with our website.

Use of cookies

In addition to the data mentioned above, cookies are stored on your end device when you use our website. Cookies are small text files that are stored on your hard disk and assigned to the browser you are using. They contain information that enables your device to be recognized and makes the use of our website more efficient overall.

Cookies are not able to execute programs or transfer viruses to your device. They are used exclusively to make our online services more user-friendly and more effective overall.

aa) Use of cookies

This website uses the following types of cookies, which are explained in more detail below with regard to their scope and functionality:

• i) Temporary cookies (so-called session cookies):
  • Are automatically deleted when the browser is closed
  • Contains session IDs
  • Allow you to recognize your device within a session
• ii) Persistent cookies (also: permanent cookies):
  • Remain after the session
  • Are automatically deleted after a defined period of time
  • Can be removed manually via your browser settings
• iii) Cookies from third-party providers:

  In addition, data is processed in connection with the following third-party tools:

Google

i) Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

• If you do not give your consent when you first visit our website, no personal data will be processed by this tool.
• Google Analytics uses cookies to analyze and statistically evaluate the use of the website.
• The information collected can be transferred to a Google server in the USA and stored there.
• We have activated IP anonymization. This means that your IP address will be truncated within the European Union or the European Economic Area (EEA) before it is transmitted to Google.
• The data stored by Google is retained for a period of 14 months.
• Google processes the data as a processor in accordance with Art. 46 para. 2 lit. c GDPR on the basis of the standard contractual clauses approved by the European Commission.

Further information:

• Google Analytics terms of use
• Google Privacy Policy

ii) Google Tag Manager

We use Google Tag Manager, a tool for managing website tags.

• This tool does not process any personal data, but is used exclusively to control other tracking tools.
• If you deactivate tracking at domain or cookie level, this setting applies to all tags integrated via Google Tag Manager.

Cookie settings and opt-out options

You can customize your browser settings to:

• block third-party cookies or all cookies,
• delete stored cookies manually,
• deactivate tracking tools via our cookie management tool.

Please note that deactivating certain cookies may restrict the functionality of individual areas of our website.

5. data security

We use appropriate technical and organizational measures to protect your data from unauthorized access, manipulation or disclosure. Please note, however, that no Internet transmission is completely secure. We endeavor to provide the greatest possible protection, but cannot guarantee absolute security.

6. disclosure of your data

Your data will not be sold or rented. Your data will only be passed on:

• To service providers: For example, for hosting, payment processing, marketing. These are contractually bound to confidentiality.
• To fulfill legal obligations: For example, for court orders or requests from authorities.
• In the context of company transfers: In the case of mergers or sales with prior information.

7. your rights under the GDPR and BDSG

In particular, you have the following rights:

• Information: About the personal data stored about you
• Rectification: Incorrect or incomplete data
• Erasure ("right to be forgotten"): You have the right to request the erasure of your personal data - especially if it is no longer necessary for the purposes for which it was collected.
• Restriction of processing: You have the right to request the restriction of the processing of your personal data under certain conditions, e.g. if the accuracy of the data is disputed by you or the processing is unlawful.
• Data portability: In machine-readable format
• Objection: to processing, in particular for direct marketing purposes
• Revocation of consent: At any time with effect for the future

To exercise these rights, please contact us using the details below.

8. storage periods

Your data will be stored for as long as is necessary to fulfill the purpose or for legal retention. Please send a request for deletion to the contact address below.

9. data protection of minors

Our offer is not aimed at persons under the age of 18. Should we nevertheless become aware of such persons' data, it will be deleted immediately.

10 Cross-border data transfers

Your personal data may be transferred to countries outside the European Economic Area (EEA) where a lower level of data protection may apply than in the European Union. In such cases, we will ensure that appropriate safeguards are in place - in particular through the use of standard contractual clauses approved by the European Commission to ensure an adequate level of data protection.

11. changes to this privacy policy

We reserve the right to revise this privacy policy if necessary in order to adapt it to changes in the legal framework, technical developments or adjustments to our service offerings. The currently valid version can be accessed at any time on our website and is provided with the current status (date). We recommend that you inform yourself regularly about the content of the privacy policy in order to always be aware of the processing and protection of your personal data.

12. contact

If you have any questions or wish to assert your rights, please contact us at:

• [Name of the investment fund]
• [Address]
• [e-mail address]
• [Telephone number]

If you are not satisfied with our data processing, you have the right to contact the Federal Commissioner for Data Protection and Freedom of Information (BfDI) or a competent supervisory authority in your country of residence.

Important notes:

• The GDPR and the BDSG impose strict requirements on the collection, storage and processing of personal data. It is therefore essential to have robust technical and organizational measures in place to ensure data protection compliance.
• Additional protective measures are required by law when processing sensitive personal data - especially data with increased protection requirements such as financial or health data.
• It is expressly recommended that expert legal advice be sought to ensure the legally compliant implementation of data protection requirements and to take account of current regulatory developments in the EU and Germany.