About Us:

Headquartered in Hamilton, Bermuda, Krypton Fund Services (“Krypton”) is a global firm comprised of various affiliated legal entities across multiple jurisdictions. We are a boutique fund services company with the sole aspiration of providing client service with distinction. We pride ourselves on a client-centric, holistic approach with a bespoke product offering and customized solutions which provide an alternative to the traditional cookie-cutter services solution.

The activities of Krypton, pertaining to the collection, use, sharing and retention of personal data, are governed by privacy and data protection laws and regulations in the jurisdictions in which we operate. Krypton is committed to protecting personal data and to ensuring data privacy as well as to adhering to the provisions of relevant privacy legislation including the European General Data Protection Regulation (GDPR), Bermuda’s Personal Information Protection Act, 2016 (PIPA) and the Cayman Islands Data Protection Law (DPL). Krypton intends to be fully transparent in how it collects, uses, processes and ultimately protects personal information.

This notice explains how Krypton handles personal data and provides details on how you can contact us with any questions you may have. It will be expressed in Question-Answer format.

For a full copy of our privacy policy, please contact us via email compliance@kryptonfs.com .

I) The Essential Questions

1. How does Krypton collect personal information from me?

Krypton processes personal data obtained or collected through various correspondence mediums (written, telegraphic or electronic) from the following primary sources:

• Personal data that we obtain directly from you, from someone acting on your behalf or from our clients to which you are a customer.
• Personal data that is provided to us by our clients, potential clients, suppliers or other business partners/affiliates.
• If Krypton has a business relationship with the organization you represent, we may be provided personal data about you including your contact information and representative capacity.
• Relevant Information captured from users visiting a Krypton website, including “cookies” (as the user, you have the option to turn cookies off on your browser software).
• Information submitted or processed via our online user portals, customer due diligence compliance forms (CDD), supporting documents and other forms and agreements.
• Information collected from other sources such as third-party data providers, publicly available data and public databases including sanctions lists.

Krypton may aggregate personal data collected on you from multiple sources, either online or offline.

2. Why does Krypton collect/process personal information about me?

Krypton stores, processes and uses personal data for lawful and legitimate purposes. These purposes include compliance with applicable legal, tax and regulatory obligations of both us, as a registered company, in the jurisdictions in which we operate, and as administrator on behalf of our clients, which are traditionally also regulated in their domicile of incorporation. We use this information to ensure our businesses are operating efficiently and lawfully with special focus on the prevention of money-laundering and terrorist financing, fraud and tax avoidance.

In some cases, we will have a legal obligation to collect and disclose certain information to relevant authorities under know-your-client (KYC) and anti-money laundering/anti-terrorist financing (AML/ATF) regulations and other legislation (including US FATCA and CRS) that applies in the various jurisdictions in which we and our clients do business.

3. What personal information does Krypton process about me?

In general, Krypton collect and process basic personal information as required by our clients for KYC/CDD purposes in addition to their reporting requirements. Some special information, such as any criminal history, may be collected for certain limited purposes through our data providers which we utilize for risk screening.

Examples of personal data Krypton collects can include, but is not limited to:

• Identity & Contact Information such as Name, Title, Date of Birth, Age, Gender, Nationality, Place of Birth, Picture, Picture Identification, Signature, Legal Domicile, Residential & Postal Addresses, Email Addresses, Telephone, Facsimile, Mobile Numbers, National Identification Number, Passport Number or Tax Identification number.
• Financial details/circumstances such as source of wealth & source of funds, personal assets, bank account numbers, bank account details, taxation details, financial and investment qualification details and income details.
• Family/Marital Status, where applicable, including family structure, siblings & offspring. Note that Krypton respects the protection of children’s privacy and does not intentionally collect or maintain any personal data on such persons unless required by law.
• Other data such as power of attorney information, job titles, employment history, employer details, personal data contained in emails, and data regarding preferences in connection with marketing communications.

4. How does Krypton use my personal information?

Your personal information may be processed by Krypton in respect of a legitimate interest in our capacity as administrator as appointed by our client and for ordinary business purposes. We use our information to satisfy our legal, regulatory and reporting obligations as well as those of our clients. The details of your email exchanges and other methods of communicating with our employees or staff may be stored on our information technology systems. We do not share or sell your personal data with third-parties for their direct marketing purposes.

Website statistics may be produced to enhance our services and conduct research and analysis by allowing us to track site usage, user preferences and referral sources.

5. Who can access my personal information?

Your information can be accessed by duly appointed and screened employees of Krypton, which has security protocols and required procedures in place regarding the processing of personal data. Krypton utilized dual authentication where appropriate and all staff undergo training with reference to the use and processing of personal data.

If you are an investor with a client that we provide administrative services to, we may also provide your personal data to that Client as required to complete their legal, regulatory, tax or reporting obligations.

Where necessary, we may also be required by law to provide your information to regulatory entities.

6. How does Krypton keep my personal information safe?

Krypton is committed to protecting your personal information that is in our possession. All companies within the Krypton Group are bound by our privacy policy which is set at the very highest standard.

We have an information security program which includes internal policies addressing the acceptable use of personal information which may be contained on one of Krypton’s information systems. We use industry standard security measures designed to protect your data and to prevent its loss, misuse, alteration or destruction.

Additionally, as a matter of course, Krypton Group retains several third-party service providers in order to promote the efficient operation of our businesses. This may result in your personal information being transferred outside your home jurisdiction. All third parties we deal with are contractually obliged to provide similar protections.

7. How long does Krypton store my information?

Krypton will keep your information only for as long as we need it, subject to the minimum time periods for data retention specified under the laws of the jurisdictions in which we operate.

II) Disclosure on International Transfer of Data

The legal entities comprising the Krypton Group are integrated in a group structure, and several essential functions are provided at the Group level to some or all our businesses. Accordingly, your personal information will likely be shared with Krypton Group entities located in jurisdictions other than where you have an associated service relationship (your “principal services office”). We may disclose or transfer personal data, where reasonably appropriate and for legitimate purposes to legal entities within the Krypton Group as necessary. Prior to undertaking any transfer, Krypton ensures it has adequate safeguards in place.

III) What are my rights?

Subject to the relevant laws and regulations, you have certain rights regarding the processing of your personal data. These rights include:

• The right to be informed as to how Krypton collects and use your personal data.
• The right of access to the personal data that we process on you and the names/types of persons to whom your information has been or is being disclosed.
• The right to have any error or omission in your personal data corrected.
• The right to require Krypton to delete your personal information in certain limited circumstances.
• The right to object to or restrict the use or processing of your personal data in certain circumstances and to withdraw consent for use.
• The right to stop any direct marketing.
• The right to be notified of a data breach.
• The right to lodge a complaint about our processing of your personal information with the relevant supervisory authority.

IV) Legal Disclosure

Krypton may disclose your personal information to law enforcement, regulatory or other government agencies or to third parties as required by and in accordance with applicable laws or regulations.

V) Amendments to Policy

Krypton’s Privacy Policy and Privacy Notice may be amended from time to time in line with new or changed regulations. Any changes we make in the future will be posted to our website and will be available to you upon contact.

VI) Who to contact?

Should you wish to exercise any of your rights, as listed above, or if you have any questions regarding our privacy policy and how we process your personal information, please contact us via email compliance@kryptonfs.com or via regular mail: