The Privacy Policy of GXB Capital RAIF V.C.I.C. LTD (hereinafter “GXB Capital”) explains how we collect, use, share and protect your data and personal information that are being obtained by GXB Capital’s website. It is necessary to read all the provisions of the Privacy Policy since with this website you share with us your personal data including your geo-location. We know that you take your privacy seriously. We do, too. We seek to be transparent about our data practices and give you control over the information we collect about you. This Privacy Policy also describes applicable data protection rights including a right to object to some of our processing.

1. General Information
    1.1. This Privacy Policy explains how GXB Capital, which is a Registered Alternative Investment Fund, incorporated in Cyprus with
           registration number HE 436688, and with registered address of 12 Dimostheni Severi, 6 th Floor, Office 601, 1080 Nicosia, Cyprus
           and its Affiliates (hereinafter “we,” “us,” and “our”) collects, uses, shares, and protects user information obtained through the        
           Website. When we ask for certain personal information from users, it is because we are required for the provision of our services
           and/or it may be required by law, for example court decision or other investigatory body for legitimate reasons.
    1.2. Any non-required information you provide to us is done so voluntarily. You decide whether to provide us with this non-required
           information. Note that some information are not required but necessary for you to unravel all the provided services of GXB Capital.
    1.3. By accepting the Privacy Policy notification before entering the application, you consent to the data practices described in this 
           Privacy Policy, as well as when you register for an account, transact with GXB Capital, sending an enquiry and/or visiting the     
           Website and/or downloading and opening the Website’s material.
    1.4. On occasion, we may revise this Privacy Policy to reflect changes in law or our personal data collection and use practices. If
           material changes are made to this Privacy Policy, the changes will be announced by personal notification to your account. We will             ask for your consent before using your information for any purpose that is not covered in this Privacy Policy.
    1.5. This Privacy Policy was made on the basis the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27
           April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data 
           and repealing Directive 95/46 / EC (General Data Protection Regulation), hereinafter also referred to as “GDPR”.

2. Definitions and legal references
    2.1. Data subject: The person who uses this Website and which, unless otherwise specified, coincides with the Underlying Data.
    2.2. Data processor: The individual or legal person, public authority, organization or other entity processing personal data on behalf of 
           the controller as described in this privacy policy.
    2.3. Data controller: An individual or legal person, a public authority, an organization or other entity which, either alone or together with 
           others, determines the purposes and means of processing the Personal Data, including security measures relating to its operation
           and use. The Data Controller, unless otherwise specified, is the owner of this Website.

    2.4. European Union (or EU): Unless otherwise stated, all references made in this document to the European Union include all the     
           current Member States in the European Union and the European Economic Area.
    2.5. Geo-location: The identification of the geographic location of a user or computing device via a variety of data collection 
           mechanisms such as Bluetooth, wifi connection or GPS. Typically, most geolocation services use network routing addresses or                 internal GPS devices to determine this location.
    2.6. Legal information: This privacy statement has been prepared on the basis of provisions of Regulation (EU) 2016/679 (General                   Data Protection Regulation). This privacy policy is strictly related to this site.
    2.7. Personal data (or data): Personal data is any information that relates to an identified or identifiable living individual. Different     
           pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
    2.8. Service: Any service provided by GXB Capital through its Website.
    2.9. Website: www.gxbcapital.io through which the User & Personal Data is collected and processed.
    2.10. Usage data: Information collected automatically through this Website (or third party services used on this Website), which may
             include: the IP addresses or domain names of the computers used by the Users using this Website, the URIs (Uniform Resource
             Identifier), at the time of the request, the method used to submit the request to the server, the size of the file received in
             response, the numeric code indicating the status of the server response (successful outcome, error, etc.), the source country, the
             browser and operating system functions used by the User, the various time-per-visit details (e.g., time spent on each page of the               Website), and details of the route followed in the Website with special reference to the sequence, the pages you have visited,     
             and other measures relating to the operating system of the device and/or the user& IT environment.

3. Administrator of Personal Data
    3.1. The Personal Data of the Users are under the authority of GXB Capital. If you have any questions, requests or complaints
            regarding the processing of your personal data by us, you can also contact GXB Capital using the following dedicated email 
            address at info@gxbcapital.io
    3.2. Questions, applications and complaints referred to in the preceding paragraphs should, in particular include:
           3.2.1. data relating to the person or persons concerned by the inquiry or request,
           3.2.2. the event which is the reason for sending a message to us,
           3.2.3. requests and legal grounds for demanding request,
           3.2.4. the expected manner of handling the matter.

4. What Data Does GXB Capital Collects
    4.1. Data You Provide to us:
           4.1.1. We collect data that you provide to us when you create an account, such as full name, email address, your professional title
                     and occupation, financial information, phone number, birthday, gender, the city in which you live, username, and other data                       if you create an account using third party log-in credentials.
           4.1.2. We may also collect other data you provide when you use the Services, including Geo-location of your device.

    4.2. We also collect additional data about you when you use the Services. For example:
           4.2.1. data about how you interact with the Services, such as your search words, page views, date and time of interactions, time
                     spent on each page;
           4.2.2. device information, such as your operating system, IP address, browser type and language; and
           4.2.3. data from cookies, pixels and other technologies, such as cookie ID, advertising ID or other unique advertising ID, web
                     beacons, and local storage. You can control certain types of cookies through your browser settings or other tools.
    4.3. Data Received from Third Parties. We may receive data about you from third parties, including:
           4.3.1. our Affiliates (e.g. business customers of our Services, or brokers);
           4.3.2. third parties that provide services to us, such as credit reference agencies, public databases, registers and records and
                     information obtained from sanction checking and background screening, offered by our business partners, including those
                     from whom we license data; and
           4.3.3. The information we obtain from third parties includes demographic data, data about how you interact with the third party &
                     websites and apps, device data (including mobile device and advertising identifiers, such as Apple IDFA or Google
                     Advertising ID), and information from cookies, pixels and other similar technologies. We may also collect information such                         as your credit card’s details and billing address.

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5. How Is My Data Used by GXB Capital?
    5.1. To Operate, Maintain and Improve the Services
           5.1.1. We use your data to operate, maintain the Services, and our business, and to provide you with our Services in a more
                     personalized manner, including complying with our reporting and obligations to regulatory and supervisory authorities.
           5.1.2. We use various technologies to determine your precise location, such as the location services of your operating system or
                     browser, sensor data from your device (e.g. magnetometer, barometer, gyroscopes, accelerometers, compasses, Bluetooth
                     data, beacon data, Wi-Fi access points, GPS data, and cell tower data), and other data that may help us understand your
                     precise location.
    5.2. Communicate with You
           We use your data to communicate with you by email, text (if you opt-in), or in our Website, about material changes or updates to
           our Services, or anything else we think may be of interest to you.
    5.3. Protection of Our Rights
           We may use your data to protect the rights, property or safety of GXB Capital, the Services, our users and employees, or any third             party. For example, we may use your data to protect against identity theft, prevent fraud or other criminal activity, claims or other
           liabilities. We may also use your data to comply with and enforce applicable legal requirements, relevant industry standards and               our policies, including this Privacy Policy and our Terms of Service.

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6. When Is My Data Shared?

    We may share your data as described in this Privacy Policy or when you have given us consent to do so.
    6.1. Data That May Be Shared with Other Users
           6.1.1. When you use the GXB Capital’s Website, the network may see some of your data (e.g. name, address, birthday, gender,
                     telephone number, email, and other information you provide).
    6.2. Data That May Be Shared with Affiliates, Service Providers and Partners
           We may share your data with our affiliated entities, and service providers that perform services on our behalf, such as           
           management, administration and IT services. These service providers may be located in countries other than the country in which
           the information originally was collected. We do not authorize our service providers to retain, use or disclose the data except as
           necessary to perform services on our behalf or comply with legal requirements.
    6.3. Compliance with Law, Protection of Rights and Corporate Events
           6.3.1. We may share data if required by law or if a legal issue arises between us and you and we need to protect your or our 
                     rights.
           6.3.2. We may also share data as part or in anticipation of a business sale, merger, consolidation, investment, change in control,
                     transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.
    6.4. Third-Party Analytics
           On our Consumer Services, we use third-party analytics services, such as those of Google Analytics. The service providers that 
           administer these analytics services use cookies and other automated technologies to collect data (such as IP addresses and
           other device identifiers) to evaluate, for example, use of our Services and to diagnose technical issues. To learn more about
           Google Analytics, please visit https://www.google.com/policies/privacy/partners/.

7. How do I Access or Delete My Data?
    7.1. You may access and update your data at any time through the “Settings” tab in your account.
    7.2. You may also delete your data and account at any time by contacting us through the Website. If you delete your data, your profile,             including your history, addresses and other account data will be removed, and you will no longer be able to access such data. 
           We will not be able to restore your account once it has been deleted. Deletion of your account may not be immediate. Residual
           copies of your personal information or posts may remain on backup media for a short period of time thereafter.
    7.3. We may also retain data as required by applicable law and we may retain data that has been anonymized or otherwise does not
           constitute or contain personal information.
    7.4. The person responsible for collecting and processing personal data on the Website, i.e. Data Protection Officer (DPO) is 7Q Asset
           Management LTD If you have questions about accessing, updating, or deleting your data, please contact the DPO at
           info@gxbcapital.io

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8. Unsubscribe from Marketing Emails

    By Email: You can opt out of marketing or promotional emails at any time by adjusting your preferences in your “Settings” in the
    Website, if you are logged into your account. You may also unsubscribe from marketing emails by following the instructions in the
    email or by contacting us. Please note that you cannot opt out of legal notices.

9. Personal Information Retention
    To the extent required by applicable law, we keep the personal information you provide for the duration of our relationship, plus a
    reasonable period thereafter to comply with the applicable statute of limitations and other applicable laws.

10. How We Protect Personal Information
      We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the
      Services against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

11. More Information for Users From the EEA, UK and Switzerland
      11.1. Where GDPR applies to the processing of your Personal Data, we rely on several legal bases. These include:
               11.1.1. When the processing is necessary to perform our contract with you, such as our Terms of Service.
               11.1.2. When the processing is necessary for our legitimate business interests, including but not limited to, improving our
                           Services;
               11.1.3. When you have given us your consent, including as described in this Privacy Policy. You may withdraw your consent to 
                           processing at any time using the settings on your device or in your account;
               11.1.4. When we have a legal obligation to do so, as described in this Privacy Policy.
      11.2. Subject to applicable law, you may have a number of rights regarding the processing of your Personal Data, including:
               11.2.1. the right to request access to, or copies of, your personal data that we process or control, together with information
                           regarding the nature, processing and disclosure of that personal data;
               11.2.2. the right to request rectification of any inaccuracies in your Personal Data that we process or control;
               11.2.3. the right to request:
               11.2.4. deletion of your personal data that we process or control; or
               11.2.5. restriction of processing of your personal data that we process or control;
               11.2.6. the right to object, to the processing of your personal data by us or on our behalf;
               11.2.7. the right to have your personal data that we process or control transferred to another data controller, to the extent
                           applicable;
               11.2.8. the right to withdraw where we process your personal data on the basis of your consent, and
               11.2.9. the right to file a complaint with a Data Protection Authority regarding the processing of your personal data by us or on
                           our behalf.
      11.3. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or
               about our processing of your personal data, please use the contact details provided in the “Contact Us” section.
      11.4. These rights may be limited in certain circumstances, for example if fulfilling your request would (i) reveal personal data about
               another person, (ii) infringe the rights of a third party (including our rights), (iii) cause us to delete information that we are
               required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR
               and in local implementing legislation. We will inform you of relevant exemptions we rely upon when responding to any request
               you make.

12. Contact Us
      If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to our Data Protection Officer at
      info@gxbcapital.io. We will make every effort to resolve your concerns.

 
13. Cookies
      13.1. Our Website uses Cookies technology in order to adapt its operation to your individual needs. According to this, you may     
               consent to the storage of the data and information entered by you, so that it can be used for future visits to our Website without
               the need to re-enter it. The owners of other websites will not have access to this data and information. However, if you do not
               agree to personalize the Website, we suggest disabling the use of cookies in the options of your Internet browser.
      13.2. Learn more on our “Cookies” policy.

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14. Restriction of Responsibility
      14.1. GXB Capital shall not be held liable for any claim, damage or loss that was facilitated through sophisticated technological
               means that surpasses the common level of security provided by companies such ours.
      14.2. GXB Capital shall not be held liable for any claim, damage, or loss for any action or omission outside the power of control of
               the Company or based on Acts of God, including environmental disasters, cut of electricity, earthquakes, pandemics, and other
               phenomena.
      14.3. GXB Capital shall not be held liable for any claim, damage, or loss for any action that was initiated and/or instructed and/or 
               executed by the User, and/or such action was in violation of any agreement, Policy, Regulation and/or circumvents such
               agreements, policies, regulations in bad faith, fraudulently and/or against the interests of the Company or its Operators.
      14.4. GXB Capital shall not be held liable or accountable for any illegal and/or fraudulent action with information received from an
               order or purchase.
      14.5. To the maximum extent permitted by applicable law, the services, content and user content are provided “as is,” “with all faults”
               and “as available” and the entire risk of use and performance remains with you. GXB Capital is not responsible for the content
               that you upload, share or circulate in the network and any legal action that may arise from such content is completely at your
               own responsibility.
 

               For more information or any question please contact us at info@gxbcapital.io

Dated:: 5 June 2023