EU Privacy Policy

EU PRIVACY POLICY

Davis Investment Ventures, LLC and their affiliates (“DIV” or the “Firm”) are committed to protecting your  privacy and maintaining the confidentiality and security of your personal information. Any personal  information processed by the Firm is controlled by the Firm and the Firm is the data controller of your  personal information. Where your details are provided to the Firm through your investment (or potential  investment) in a private investment fund for which the Firm serves as investment advisor (each a “Fund”),  then the Firm, acting as a data controller, may itself (or through a third party (the “Administrator”) acting in  its capacity as the Fund’s administrator) process your personal information or, if you are an entity, that of  your (i) beneficial owner(s) and (ii) directors, officers, trustees, general partners, managers, or other persons  serving in a similar capacity (collectively, “Your Personal Information”). When processing Your Personal  Information, there may also be times when the Administrator will act as a data controller.  

This policy (the “EU Privacy Policy”) explains the manner in which the Firm collects, utilizes and maintains  non-public personal information about investors and potential investors (“Investors”) based in the European  Union (“EU”) or the European Economic Area (“EEA”), as required under the General Data Protection  Regulation (EU) 2016/679 (“GDPR”). This EU Privacy Policy applies to your investment or potential  investment in the Fund.  

Collection of Your Personal Information  

The Firm collects Your Personal Information from the following sources, as applicable:  

  1. Subscription documents and other information provided by the Investor in writing, verbally,  electronically or by other means (this information includes (i) name, address, income, financial and  investment qualifications, and tax-related information, birth date, nationality, passport or other  identification number, and employment information);  
  2. Transactions within the Fund, including account balances, investments, redemptions and  management fees and performance allocations; and  
  3. Other interactions with the Firm (for example, discussions with our staff).  

Why We Use Your Personal Information  

Your Personal Information may be processed by the Firm (or its affiliates, agents, or employees) for the  following purposes, as applicable:  

  1. to facilitate your investment in the Fund and the management and administration of your investment  in the Fund on an ongoing basis (the “Services”) which are necessary to fulfill all contractual and  regulatory obligations related to your investment in the Fund, including without limitation the  acceptance and processing of subscription documents and redemption and transfer requests;  
  2. in order to carry out anti-money laundering checks and actions which the Firm and/or Administrator  considers appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with  respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery,  corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to  persons who may be subject to economic or trade sanctions, all in accordance with the Firm’s and  the Administrator’s anti-money laundering policies and procedures;  
  3. to comply with their legal obligations and, in particular, to report tax-related information to tax  authorities;  
  4. to disclose information to other third parties such as service providers of the Fund, the Firm and/or  Administrator (including, for example, attorneys, accountants, auditors, or other professionals),  regulatory authorities and technology providers in order to comply with any legal obligation imposed 

on the Fund, the Firm and/or Administrator or in order to pursue the legitimate interests of the Fund,  the Firm and/or Administrator; and/or  

  1. to monitor and record electronic communications for any of the purposes specified herein  

Countries Having Access to Your Personal Information 

The Firm’s servers, which store and keep Your Personal Information, are located in the United States of  America. The Firm also engages with service providers whose personnel will have access to Your Personal  Information and that are located in other jurisdictions. Transfers to these service providers are necessary for the  performance of the contract between the Fund and the Investor. These jurisdictions either (i) afford an adequate  level of protection for Your Personal Information (as declared by the European Commission) or, (ii) if they do  not, then the Firm and/or the Fund has entered into an agreement with these service providers incorporating  clauses the same or substantially similar to the standard contractual clauses, as well as other relevant provisions  contained in the GDPR, and obligations no less onerous than those contained in this EU Privacy Policy.  

  

Collecting Investor Information Legally 

The Firm and the Administrator are able to legally collect and use Your Personal Information either because:  

  1. you have consented to their doing so; and/or  
  2. collecting and using Your Personal Information is necessary for the Firm and/or the Administrator to  fulfill their legitimate business interests; and/ or  
  3. it is necessary to comply with any applicable regulatory, judicial or other legal obligations applicable  to the Firm and the Administrator.  

Retention of Investor Information 

The Firm and the Administrator will retain Your Personal Information for the purposes described in (1), (2), and  (3) in the immediately preceding paragraph as long as required for the purposes described above.  

In particular, and without limitation to the foregoing, the Firm and the Administrator have legal obligations  imposed on them under applicable legal systems which requires them to retain Your Personal Information for  certain minimum time periods  

Your Rights 

You have the right to:  

  1. be informed about Your Personal Information that the Firm and/or the Administrator collects from  you, uses, and retains, which this EU Privacy Policy seeks to do;  
  2. obtain confirmation from the Firm that Your Personal Information is being collected, used, and  retained as described above and to access Your Personal Information held by the Firm;  3. have Your Personal Information corrected if it is inaccurate or incomplete at any time;  4. erasure, or the right to be forgotten, which means you can request deletion or removal of any of Your  Personal Information the Firm holds about you at any time, subject to the Firm’s or the  Administrator’s rights to retain Your Personal Information as provided for under the GDPR;  5. block or suppress the Firm collecting and using Your Personal Information, which means the Firm  can continue to store Your Personal Information but cannot further collect or use it in any way;  6. obtain and reuse any of Your Personal Information that the Firm holds about you for your own  purposes across different services, which allows you to move, copy or transfer Your Personal  Information easily from the Firm to another place identified by you to the Firm in a safe and secure  way without hindrance to the usability of Your Personal Information;  
  3. object to the Firm collecting, using or retaining Your Personal Information where this is based on:  a. your legitimate interest or the performance of a task in the public interest; or  
  4. direct marketing even if otherwise legally permitted; and 
  5. withdraw your consent to the use of Your Personal Information at any time, as described below.  

To make any requests as listed above, please contact the Firm at the following:  davisinvestorrelations@TheDavisCompanies.com.  

The Firm will respond to requests relating to your rights above within one month of receipt of your request, or  within two months of receipt of your request where this request is more complex.  

Withdrawal of Your Consent 

You can tell the Firm to stop collecting, using and retaining Your Personal Information at any time by emailing  the Firm at davisinvestorrelations@TheDavisCompanies.com. You should note that notwithstanding your  withdrawal of consent, the Firm may be legally required to retain some or all of Your Personal Information.  Where the Firm or the Administrator requires Your Personal Information to comply with AML or other legal  requirements, failure to provide this information will mean that you will be unable to be accepted as an investor  in the Fund and/or may be mandatorily redeemed from the Fund if you are already an Investor.  

Protection of Investor Information 

The Firm maintains appropriate technical and organizational measures to ensure a level of security appropriate  to potential risks, including physical, electronic and procedural safeguards that comply with the GDPR to protect  customer information, including:  

  1. the encryption of Your Personal Information where appropriate;  
  2. ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and  services;  
  3. ensuring the Firm can restore access to Your Personal Information in a timely manner if a physical or  technical incident occurs; and  
  4. regular testing, assessment and evaluation of the effectiveness of its technical and organizational  measures to attempt to ensure Your Personal Information is secure.  

The Firm restricts access to the personal and account information of Investors to those employees and third parties who need to know that information in the course of their job responsibilities. The Firm will destroy, erase  or make unreadable data, computer files and documents containing Your Personal Information that is non-public  prior to disposal.  

Making a Complaint 

If you would like to make a complaint about the way the Firm has collected, used or retained Your Personal  Information, please contact us at davisinvestorrelations@TheDavisCompanies.com. Also, where you believe  that the Firm has not complied with its obligation under this privacy policy or European law, you have the right  to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.  

Former Customers and Investors 

This EU Privacy Policy also applies to former Investors in the EU and the EEA.  

Further Information 

This EU Privacy Policy is in addition to the Firm’s existing Privacy Policy adopted under US law, a copy of  which is available from the Firm on request. The Firm reserves the right to change this EU Privacy Policy at any  time and without prior notification.