Website Privacy Policy

Last updated: March 19 2025

1. Introduction

CE Global Private Equity Limited (“CE Global Private Equity”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, retain and otherwise process personal data when you:

• visit or use our website;
• contact us by telephone, email, post, website form or another communication channel;
• request information about CE Global Private Equity, our activities or our services;
• interact with us as an investor, prospective investor, investment professional, adviser, intermediary, portfolio company representative or other business contact;
• attend a meeting, conference, presentation, roadshow or other event organised or attended by us;
• apply for employment, a consultancy position, an internship or another opportunity with us;
• supply products or services to us, or act on behalf of one of our suppliers or professional advisers; or
• otherwise engage or communicate with CE Global Private Equity.

This Privacy Policy also explains your privacy rights and how applicable data protection laws may protect you.

This policy is intended to comply, where applicable, with the Cayman Islands Data Protection Act, as revised or replaced from time to time, together with associated regulations, orders and guidance (the “Cayman DPA”). Where our processing activities fall within their scope, this policy also reflects the requirements of the United Kingdom General Data Protection Regulation (“UK GDPR”), the UK Data Protection Act 2018 and other applicable privacy and data protection legislation.

This Privacy Policy relates primarily to our website and our general business relationships. Separate or supplementary privacy notices may be provided in connection with particular investment funds, investment vehicles, transactions, employment processes, regulatory obligations or other activities. Where a supplementary privacy notice applies, it should be read together with this Privacy Policy.

2. Important Information About This Policy

This Privacy Policy applies to personal data relating to identifiable living individuals. It does not apply to information that has been irreversibly anonymised so that no individual can be identified from it.

Our website may contain links to websites, platforms or services operated by third parties. Those third parties may collect or use personal data in accordance with their own privacy policies. We do not control third-party websites and are not responsible for their privacy practices, security or content. We encourage you to review the privacy policy of every website you visit.

Our use of cookies and similar technologies is addressed separately in our Cookie Policy. This Privacy Policy should therefore be read together with our Cookie Policy and any other legal notices displayed on our website.

3. About CE Global Private Equity Limited

CE Global Private Equity Limited is a private equity company founded in 2019 and established in Grand Cayman, Cayman Islands.

CE Global Private Equity also maintains an office in London, United Kingdom.

Our principal business address is:

CE Global Private Equity Limited
Ugland House
South Church Street
George Town,
Grand Cayman
Cayman Islands

Our London office is located at:

CE Global Private Equity Limited
Basildon House
7 Moorgate
London EC2R 6EA
United Kingdom

Company registration number: 1583105

4. Who Is Responsible for Your Personal Data?

For the purposes of applicable data protection legislation, CE Global Private Equity will generally act as the data controller in respect of personal data covered by this Privacy Policy. This means that CE Global Private Equity determines why and how that personal data is processed.

In some circumstances, another member of our corporate group, an investment fund, a general partner, an investment manager, an adviser, a portfolio company, a special-purpose vehicle or another entity associated with a particular investment may separately or jointly determine the purposes and means of processing.

Where another entity acts as a separate or joint controller, further information may be provided in a specific privacy notice, investment document, subscription document, engagement letter, employment notice or other relevant communication.

CE Global Private Equity may also process personal data on behalf of another organisation as a data processor or service provider. Where we act solely as a processor, the relevant controller's privacy policy will ordinarily govern that processing.

5. How to Contact Us

Questions, requests or concerns regarding this Privacy Policy or our processing of personal data may be directed to:

Privacy Contact
CE Global Private Equity Limited
121 South Church Street, George Town, Grand Cayman KY1-1104, Cayman Islands
Email: [email protected]
Telephone: ‪+1 345 987654321

If CE Global Private Equity appoints a Data Protection Officer or another designated privacy representative, their contact details may be published here or provided in a supplementary privacy notice.

6. The Personal Data We Collect

The personal data we collect will depend on the nature of your relationship and interactions with us. We may collect, use, store, disclose or otherwise process the categories of personal data described below.

6.1 Identity Data

This may include:

• full name;
• title;
• honorific or professional designation;
• date of birth;
• age;
• gender, where relevant and lawfully collected;
• photograph;
• signature;
• nationality;
• country of residence;
• passport details;
• driving licence details;
• national identification numbers;
• tax identification numbers; and
• copies of identity documents.

6.2 Contact Data

This may include:

• business or personal address;
• email address;
• telephone or mobile number;
• professional contact information;
• social media or professional networking details; and
• communication preferences.

6.3 Professional and Business Data

This may include:

• job title;
• employer or organisation;
• department;
• professional qualifications;
• employment history;
• directorships;
• ownership interests;
• business affiliations;
• professional biography;
• areas of responsibility or expertise;
• business relationships;
• details of advisers, representatives or authorised persons; and
• information contained in business cards, correspondence or professional profiles.

6.4 Investor and Investment-Related Data

Where relevant to our activities, this may include:

• investor type or classification;
• investment interests and preferences;
• investment history;
• investment experience;
• risk profile;
• financial circumstances;
• source of funds;
• source of wealth;
• beneficial ownership information;
• control and ownership structures;
• details of investment entities, trusts, partnerships or companies;
• capital commitments;
• subscription or redemption information;
• banking and payment details;
• tax residency and tax reporting information;
• distribution information;
• investment performance information;
• communications regarding investment opportunities;
• information contained in subscription documents, investor questionnaires or side letters; and
• records of investor meetings, enquiries, instructions and decisions.

6.5 Financial Data

This may include:

• bank account details;
• payment instructions;
• transaction information;
• billing and invoicing information;
• credit-related information;
• assets and liabilities;
• income information;
• financial statements;
• tax information;
• investment holdings; and
• information used to verify financial standing, source of wealth or source of funds.

6.6 Compliance, Due-Diligence and Regulatory Data

This may include information collected for anti-money laundering, counter-terrorist financing, sanctions, anti-bribery, anti-corruption, fraud-prevention, market-conduct, tax-reporting and other legal or regulatory purposes, including:

• identity-verification information;
• beneficial ownership and control information;
• politically exposed person status;
• sanctions-screening results;
• adverse-media screening results;
• criminal allegations or convictions, where lawfully processed;
• regulatory or disciplinary history;
• litigation or insolvency information;
• information regarding close associates or family members of politically exposed persons;
• records of compliance checks and risk assessments;
• information obtained from public registers, databases and screening providers;
• certifications, declarations and representations;
• communications with regulators, law-enforcement bodies or other authorities; and
• information required under applicable tax-transparency or financial-reporting regimes.

6.7 Communications Data

This may include:

• emails;
• letters;
• telephone call details;
• meeting notes;
• video-conference records;
• instant messages;
• website enquiries;
• feedback;
• complaints;
• instructions;
• requests;
• records of consent or objections; and
• other correspondence between you and CE Global Private Equity.

Where lawful and appropriate, telephone calls, video conferences or meetings may be recorded or transcribed for compliance, training, evidential, security or record-keeping purposes. Where required, we will notify participants before recording begins.

6.8 Website and Technical Data

When you use our website, we or our service providers may collect:

• internet protocol address;
• browser type and version;
• device type;
• operating system;
• time-zone setting;
• approximate location derived from an internet protocol address;
• website access times and dates;
• pages viewed;
• links selected;
• referring website or source;
• session duration;
• navigation paths;
• download records;
• website error information;
• security logs;
• authentication and access records;
• device identifiers; and
• other technical or diagnostic information.

Further information about information collected through cookies and similar technologies will be provided in our separate Cookie Policy.

6.9 Marketing and Preference Data

This may include:

• your preferences regarding newsletters, reports, invitations and other communications;
• your areas of business or investment interest;
• records of communications sent to you;
• whether you opened or interacted with a communication, where legally permitted;
• event attendance history;
• communication opt-in and opt-out records; and
• your preferred method and frequency of communication.

6.10 Recruitment Data

If you apply for a position or opportunity with us, we may collect:

• curriculum vitae or résumé;
• covering letter;
• application form information;
• employment history;
• education and qualifications;
• professional memberships;
• references;
• interview notes and assessments;
• salary expectations;
• right-to-work information;
• immigration and visa information;
• background-check results;
• criminal-record information, where lawful and relevant;
• conflicts-of-interest information;
• equal-opportunity monitoring information, where lawful;
• information concerning reasonable adjustments; and
• communications relating to your application.

6.11 Supplier and Adviser Data

This may include:

• contact information for supplier personnel and professional advisers;
• engagement terms;
• service and performance records;
• billing and payment information;
• professional credentials;
• insurance information;
• due-diligence information;
• conflicts-of-interest information;
• security-assessment information; and
• correspondence concerning supplied products or services.

6.12 Visitor and Security Data

If you visit one of our offices or attend an event, we may collect:

• visitor registration details;
• arrival and departure times;
• host information;
• identification details;
• access-card records;
• closed-circuit television footage;
• photographs or event recordings;
• vehicle-registration details;
• health and safety information; and
• emergency contact information.

6.13 Special Categories of Personal Data

We do not ordinarily seek to collect sensitive or special-category personal data through our general website. However, we may process such information where it is relevant and lawful to do so.

Depending on applicable law, sensitive or special-category personal data may include information concerning:

• racial or ethnic origin;
• political opinions;
• religious or philosophical beliefs;
• trade-union membership;
• genetic information;
• biometric information used for identification;
• physical or mental health;
• sex life or sexual orientation; and
• criminal allegations, proceedings or convictions.

We will process this information only where permitted by applicable law and where an appropriate legal condition applies. This may include processing required for employment purposes, legal claims, substantial public-interest reasons, regulatory compliance, security, protection of vital interests or where you have given valid explicit consent.

6.14 Aggregated and Anonymised Data

We may create aggregated, statistical or anonymised information from personal data. Such information may be used for research, reporting, analytics, risk management, business planning, website improvement and other lawful purposes.

Where information has been irreversibly anonymised so that it can no longer identify an individual, it will not be treated as personal data under this Privacy Policy. If we combine or connect aggregated information with information that can identify you, we will treat the combined information as personal data.

7. How We Collect Personal Data

We may collect personal data from a variety of sources.

7.1 Information You Provide Directly

You may provide personal data when you:

• complete a website form;
• contact us by email, telephone, post or another method;
• request information or respond to a communication;
• subscribe to a newsletter or publication;
• register for or attend an event;
• participate in a meeting, presentation or video conference;
• provide a business card;
• enter into discussions or negotiations with us;
• make or consider an investment;
• complete due-diligence, onboarding or subscription documentation;
• provide goods or services to us;
• apply for employment or another position;
• visit one of our offices; or
• otherwise interact with CE Global Private Equity.

7.2 Information Collected Automatically

We may automatically collect certain technical, usage, security and device information when you access or use our website, systems, networks or electronic communications.

This information may be collected through server logs, security tools, analytics services, cookies and similar technologies. Further details will be provided in our Cookie Policy.

7.3 Information Obtained from Third Parties

We may receive personal data from:

• fund administrators;
• investment managers;
• general partners;
• placement agents;
• banks and financial institutions;
• custodians;
• brokers;
• lawyers, accountants, auditors, tax advisers and other professional advisers;
• consultants and service providers;
• portfolio companies;
• co-investors and transaction counterparties;
• existing or prospective investors;
• your employer, colleagues, agents or representatives;
• recruitment agencies and referees;
• identity-verification and background-screening providers;
• anti-money laundering and sanctions-screening providers;
• credit-reference agencies;
• fraud-prevention agencies;
• regulators, courts, tax authorities and law-enforcement bodies;
• public authorities;
• publicly available registers;
• corporate websites;
• professional networking platforms;
• news organisations and media sources;
• company-information databases; and
• other lawful public or commercial information sources.

7.4 Information About Other Individuals

If you provide personal data about another person, such as a director, shareholder, beneficial owner, employee, family member, associate, trustee, beneficiary, adviser or representative, you should ensure that you are authorised to provide that information.

You should also ensure, where required, that the individual has been informed of the matters contained in this Privacy Policy or any relevant supplementary notice.

8. Why We Use Personal Data

We may process personal data for the following purposes.

8.1 Operating and Managing Our Business

We may use personal data to:

• operate CE Global Private Equity and its offices;
• manage our corporate affairs;
• maintain business records;
• manage internal governance and reporting;
• administer business relationships;
• coordinate meetings and communications;
• manage suppliers, contractors and professional advisers;
• process invoices, expenses and payments;
• manage insurance and risk;
• conduct business-continuity and disaster-recovery planning; and
• support internal administration and operational efficiency.

8.2 Investment and Transaction Activities

We may use personal data to:

• identify, assess and evaluate investment opportunities;
• conduct commercial, financial, legal, operational, technical, tax, compliance and reputational due diligence;
• consider potential acquisitions, disposals, restructurings, financings or other transactions;
• negotiate and execute transactions;
• establish and operate investment structures and vehicles;
• monitor investments and portfolio companies;
• exercise governance, voting, consent or oversight rights;
• manage relationships with investors, co-investors, lenders and counterparties;
• evaluate potential exit opportunities;
• prepare investment committee materials;
• conduct valuations, analysis and reporting;
• administer capital calls, distributions, subscriptions, transfers and redemptions;
• respond to investor enquiries and instructions; and
• maintain records relating to investment decisions and transactions.

8.3 Investor Relations and Business Development

We may use personal data to:

• communicate with existing and prospective investors;
• provide information about CE Global Private Equity and its activities;
• respond to requests for information;
• organise meetings, presentations, conferences and roadshows;
• distribute reports, updates, publications and announcements;
• understand investor interests and preferences;
• identify potential business relationships;
• maintain relationship-management records;
• manage fundraising and investor-engagement activities;
• assess whether communications or opportunities may be relevant to a recipient; and
• maintain accurate records of communications and interactions.

8.4 Legal and Regulatory Compliance

We may use personal data to:

• comply with applicable laws, regulations, regulatory rules and professional obligations;
• conduct customer, investor, counterparty and supplier due diligence;
• verify identity and beneficial ownership;
• assess source of funds and source of wealth;
• conduct anti-money laundering and counter-terrorist financing checks;
• conduct sanctions, politically exposed person and adverse-media screening;
• prevent bribery, corruption, fraud and other financial crime;
• comply with tax-reporting and tax-transparency requirements;
• respond to court orders, subpoenas, regulatory requests and legal processes;
• make required filings and disclosures;
• cooperate with regulators, courts, law-enforcement agencies and other public authorities;
• manage conflicts of interest;
• maintain books, records and audit trails;
• investigate suspected misconduct or breaches of policy;
• protect whistleblowers and administer reports of concern;
• comply with market-abuse, insider-dealing or similar requirements, where applicable; and
• establish, exercise or defend legal rights and claims.

8.5 Website Administration

We may use personal data to:

• operate, maintain and improve our website;
• respond to website enquiries;
• analyse website performance and usage;
• diagnose technical problems;
• maintain website security;
• prevent malicious, fraudulent or unauthorised activity;
• customise website content where appropriate;
• administer access-controlled areas of the website;
• monitor compliance with our website terms; and
• develop new website features and functionality.

8.6 Security and Fraud Prevention

We may use personal data to:

• protect our personnel, visitors, premises, systems, networks, data and assets;
• authenticate users and manage access permissions;
• monitor system and network activity;
• detect and respond to cyber threats;
• investigate security incidents;
• prevent identity theft, fraud and unauthorised transactions;
• maintain access, audit and security logs;
• test and improve security controls;
• manage business continuity; and
• protect the rights, property or safety of CE Global Private Equity and others.

8.7 Recruitment and Personnel Management

We may use applicant personal data to:

• assess applications;
• communicate with candidates;
• arrange interviews and assessments;
• verify qualifications, experience and references;
• conduct background and right-to-work checks;
• assess suitability for a role;
• consider candidates for current or future vacancies;
• manage conflicts of interest;
• comply with employment and immigration laws;
• make and administer employment offers;
• defend or respond to employment-related claims; and
• monitor and improve our recruitment processes.

8.8 Marketing and Communications

Subject to applicable law, we may use personal data to:

• send corporate news and announcements;
• send investment-related publications, reports or updates;
• invite you to meetings, presentations or events;
• provide information about activities that may be relevant to your professional interests;
• maintain and update contact databases;
• measure engagement with communications;
• record and respect communication preferences; and
• develop our professional and institutional relationships.

We will not send electronic direct marketing where applicable law requires consent unless we have obtained the necessary consent or another lawful exemption applies.

8.9 Corporate Transactions

We may process and disclose personal data in connection with:

• a merger;
• an acquisition;
• a financing;
• a reorganisation;
• a restructuring;
• the establishment or closure of an investment vehicle;
• a sale of assets or business interests;
• a transfer of business operations;
• insolvency or administration proceedings; or
• another actual or proposed corporate transaction.

9. Our Legal Bases for Processing

Depending on the circumstances and applicable law, we may rely on one or more of the following grounds when processing personal data.

9.1 Performance of a Contract

We may process personal data where it is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract.

This may include administering an investment relationship, responding to a formal request, managing an engagement, processing payments or handling an employment application.

9.2 Compliance with a Legal or Regulatory Obligation

We may process personal data where necessary to comply with a legal, regulatory, tax, reporting, record-keeping, anti-money laundering, sanctions, court, law-enforcement or other binding obligation.

9.3 Legitimate Interests

We may process personal data where it is necessary for our legitimate interests or those of another person, provided that those interests are not overridden by your rights, interests or freedoms.

Our legitimate interests may include:

• operating and managing our business;
• conducting investment and transaction activities;
• communicating with investors and business contacts;
• developing and maintaining professional relationships;
• improving our website and services;
• protecting our systems, personnel and assets;
• preventing fraud and financial crime;
• maintaining accurate business records;
• managing risk and insurance;
• conducting due diligence;
• obtaining professional advice;
• establishing, exercising or defending legal claims;
• supporting corporate governance;
• evaluating business performance;
• managing suppliers and advisers; and
• promoting our business to relevant professional and institutional contacts.

Where required, we will assess and balance our legitimate interests against the potential impact of the processing on affected individuals.

9.4 Consent

We may rely on your consent where required or appropriate, including for certain forms of direct marketing or the processing of particular sensitive information.

Where we rely on consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing undertaken before consent was withdrawn.

9.5 Legal Claims and Substantial Public Interest

Where sensitive, special-category or criminal-offence data is involved, we may process that information where necessary for legal claims, regulatory compliance, fraud prevention, substantial public-interest reasons or another condition permitted by applicable law.

9.6 Vital Interests

In rare circumstances, we may process personal data where necessary to protect your life, health or physical safety, or that of another person.

9.7 Public Functions

Where applicable, we may process personal data where necessary for a task carried out in the public interest or in the exercise of an official function conferred by law.

10. Where Providing Personal Data Is Required

In some circumstances, you may be required by law, regulation, contract or the requirements of a proposed relationship or transaction to provide certain personal data.

For example, we may require information to:

• verify your identity;
• conduct anti-money laundering checks;
• confirm beneficial ownership;
• comply with sanctions requirements;
• assess source of funds or source of wealth;
• enter into an agreement;
• process an investment or payment;
• respond to a request;
• provide access to restricted information;
• consider an employment application; or
• comply with tax or regulatory reporting obligations.

If you do not provide required information, we may be unable to begin or continue a relationship with you, process a transaction, consider your application, provide requested information or fulfil our legal obligations.

11. Automated Decision-Making and Profiling

CE Global Private Equity does not ordinarily make decisions producing legal or similarly significant effects solely through automated processing in connection with general use of this website.

We may use automated tools to support screening, risk assessment, fraud detection, sanctions checking, cybersecurity, communication management or website analysis. However, where applicable law requires meaningful human involvement, safeguards or specific notice, we will implement those measures.

If we introduce solely automated decision-making that produces legal or similarly significant effects, we will provide affected individuals with additional information about the logic involved, the significance and likely consequences of the processing, and any applicable right to request human review.

12. How We Share Personal Data

We may share personal data with the categories of recipients described below where necessary for the purposes set out in this Privacy Policy and where permitted by law.

12.1 Group and Associated Entities

We may share personal data with:

• our parent entities;
• subsidiaries;
• affiliates;
• associated companies;
• investment managers;
• general partners;
• investment funds;
• co-investment vehicles;
• special-purpose vehicles;
• portfolio companies; and
• other entities under common ownership, management or control.

12.2 Investors and Investment Counterparties

We may share personal data with:

• existing and prospective investors;
• co-investors;
• limited partners;
• lenders;
• borrowers;
• banks;
• brokers;
• custodians;
• nominees;
• placement agents;
• transaction counterparties;
• potential purchasers or sellers;
• portfolio company management teams;
• directors and officers; and
• other participants in an actual or proposed investment or transaction.

12.3 Professional Advisers

We may share personal data with:

• law firms;
• accountants;
• auditors;
• tax advisers;
• corporate-service providers;
• fund administrators;
• valuation advisers;
• investment consultants;
• insurance providers and brokers;
• compliance consultants;
• investigators;
• public-relations advisers;
• recruitment advisers; and
• other professional consultants.

12.4 Technology and Operational Service Providers

We may share personal data with providers of:

• website hosting;
• cloud computing;
• data storage;
• email and communication systems;
• customer or relationship management systems;
• document-management systems;
• virtual data rooms;
• cybersecurity;
• information technology support;
• data analytics;
• identity and access management;
• electronic signatures;
• payment processing;
• business continuity;
• archiving;
• printing and mailing;
• event management;
• telephone and video-conferencing services; and
• other operational or administrative services.

12.5 Compliance and Screening Providers

We may share personal data with providers of:

• identity verification;
• anti-money laundering screening;
• sanctions screening;
• politically exposed person screening;
• adverse-media screening;
• background checks;
• credit checks;
• fraud detection;
• corporate intelligence;
• tax reporting; and
• regulatory compliance services.

12.6 Public Authorities and Other Required Recipients

We may disclose personal data to:

• courts and tribunals;
• financial regulators;
• data protection authorities;
• tax authorities;
• law-enforcement agencies;
• government departments;
• statutory bodies;
• stock exchanges;
• self-regulatory organisations;
• liquidators, administrators or insolvency practitioners;
• persons appointed under legal or regulatory processes; and
• other recipients where disclosure is required or permitted by law.

12.7 Corporate Transaction Recipients

We may disclose personal data to prospective purchasers, sellers, investors, financiers, advisers and other parties involved in an actual or proposed corporate transaction, investment, restructuring, financing or transfer of assets.

Where appropriate, recipients may be required to keep information confidential and use it only for evaluating or completing the relevant transaction.

13. Service Providers and Data Processors

Where third parties process personal data on our behalf, we will take reasonable steps to select appropriate providers and put suitable contractual arrangements in place.

Such providers may be required to:

• process personal data only on documented instructions;
• maintain confidentiality;
• implement appropriate security measures;
• assist with individual rights requests;
• assist with security incidents and regulatory obligations;
• delete or return personal data at the end of the engagement, where appropriate;
• provide information necessary to demonstrate compliance; and
• restrict the appointment of sub-processors.

Some recipients will act as independent data controllers rather than processors. Independent controllers are responsible for their own compliance with applicable data protection laws.

14. International Transfers of Personal Data

CE Global Private Equity operates from the Cayman Islands and the United Kingdom and may conduct business internationally. Personal data may therefore be transferred to, accessed from, stored in or otherwise processed in countries other than the country in which it was originally collected.

Recipients may be located in the Cayman Islands, the United Kingdom, the United States, the European Economic Area, Asia, the Middle East or other jurisdictions in which CE Global Private Equity, its advisers, service providers, investors, portfolio companies or transaction counterparties operate.

The data protection laws of some recipient countries may not provide the same level of protection as the laws of the jurisdiction from which the personal data was transferred.

Where required by applicable law, we will use an appropriate transfer mechanism or safeguard. Depending on the circumstances, this may include:

• a transfer to a jurisdiction recognised as providing an adequate level of protection;
• contractual clauses approved or recognised by a competent authority;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved contractual clauses;
• binding corporate rules;
• contractual provisions designed to provide equivalent protection;
• a legally recognised certification or code of conduct;
• explicit and informed consent, where appropriate;
• a transfer necessary for the performance of a contract;
• a transfer necessary for important reasons of public interest;
• a transfer necessary for legal claims;
• a transfer necessary to protect vital interests; or
• another exception or derogation permitted under applicable law.

Where appropriate, we may conduct transfer-risk assessments and implement supplementary technical, contractual or organisational measures.

You may contact us for further information about the safeguards applicable to a particular transfer, subject to legal, security, confidentiality and commercial restrictions.

15. Data Security

We maintain technical and organisational measures designed to protect personal data against:

• unauthorised or unlawful processing;
• accidental loss;
• destruction;
• damage;
• alteration;
• unauthorised disclosure;
• unauthorised access; and
• other misuse.

Depending on the nature and sensitivity of the information, these measures may include:

• access controls;
• role-based permissions;
• multi-factor authentication;
• password controls;
• encryption in transit or at rest;
• firewalls and network-security controls;
• endpoint protection;
• security monitoring and logging;
• backup and recovery procedures;
• physical access restrictions;
• confidentiality obligations;
• employee training;
• incident-response procedures;
• supplier-security reviews;
• business-continuity planning;
• data-minimisation measures; and
• periodic testing or review of relevant safeguards.

Access to personal data is restricted to personnel and service providers who have a legitimate business need to access it and who are subject to appropriate confidentiality obligations.

No internet transmission, electronic storage system or security measure is completely secure. Although we take reasonable steps to protect personal data, we cannot guarantee absolute security.

16. Personal Data Breaches

We maintain procedures designed to identify, assess, contain, investigate and respond to suspected personal data breaches.

Where required by applicable law, we will notify the relevant data protection authority, regulator, affected individual or other appropriate party.

Any notification will be made in accordance with the applicable legal requirements, taking into account the nature of the breach, the categories of information affected, the likely consequences and the measures taken or proposed in response.

17. How Long We Retain Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, tax, accounting, reporting, audit, compliance, security and record-keeping requirements.

Retention periods may vary according to:

• the nature of the personal data;
• the sensitivity of the information;
• the purposes for which it is processed;
• the nature and duration of our relationship with you;
• legal and regulatory requirements;
• limitation periods for legal claims;
• the need to establish, exercise or defend legal rights;
• anti-money laundering and tax-reporting obligations;
• contractual commitments;
• regulatory enquiries or investigations;
• actual or anticipated disputes;
• security and fraud-prevention needs; and
• our legitimate business and record-keeping requirements.

As a general principle:

• business and contractual records may be retained for the duration of the relevant relationship and for an appropriate period afterwards;
• investment, investor, transaction and compliance records may be retained for the period required under applicable financial-services, anti-money laundering, tax or corporate laws;
• recruitment records for unsuccessful applicants may be retained for a reasonable period after the recruitment process, unless a longer period is justified or you agree to consideration for future opportunities;
• website-security logs may be retained for a period appropriate to security, investigation and operational needs;
• marketing records may be retained while we have an active relationship or legitimate reason to communicate with you, together with suppression records necessary to respect opt-out requests; and
• information connected with legal claims or investigations may be retained until the matter and any relevant retention or limitation period have concluded.

When personal data is no longer required, we may securely delete it, destroy it or irreversibly anonymise it.

We may retain anonymised information indefinitely where it can no longer be associated with an identifiable individual.

18. Accuracy of Personal Data

We take reasonable steps to ensure that personal data is accurate, complete and, where necessary, kept up to date.

Please notify us if your personal data changes or if you believe that information we hold about you is inaccurate or incomplete.

We may periodically request updated information or supporting documents, particularly where required for identity verification, investor administration, tax reporting, sanctions screening, anti-money laundering compliance or other regulatory purposes.

19. Your Privacy Rights

Your rights will depend on the laws applicable to the particular processing activity. Subject to applicable conditions, limitations and exemptions, you may have the rights described below.

19.1 Right to Be Informed

You may have the right to receive clear information about how and why we process your personal data. This Privacy Policy is intended to support that right.

19.2 Right of Access

You may have the right to request confirmation as to whether we process your personal data and to receive a copy of that data together with certain supplementary information.

19.3 Right to Rectification

You may have the right to request correction of inaccurate personal data and completion of incomplete personal data.

19.4 Right to Erasure

In certain circumstances, you may have the right to request deletion of your personal data.

This right is not absolute. We may retain information where processing remains necessary for legal compliance, regulatory obligations, legal claims, public-interest purposes, contractual requirements or other lawful reasons.

19.5 Right to Restrict Processing

You may have the right to request that we restrict the processing of your personal data in certain circumstances, including while the accuracy or lawfulness of processing is being considered.

19.6 Right to Object

You may have the right to object to processing based on legitimate interests or the performance of a public-interest task.

Where you object, we may stop the processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or unless processing is required for legal claims.

19.7 Right to Object to Direct Marketing

You may object at any time to the use of your personal data for direct marketing. We will honour such requests in accordance with applicable law.

We may retain limited information on a suppression list to ensure that we do not send you further marketing communications contrary to your request.

19.8 Right to Data Portability

In certain circumstances, you may have the right to receive personal data you provided to us in a structured, commonly used and machine-readable format, and to request its transmission to another controller.

19.9 Rights Relating to Automated Decision-Making

Where applicable, you may have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.

You may also have the right to request human intervention, express your point of view and challenge a decision.

19.10 Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn and will not affect processing based on another lawful ground.

19.11 Right to Complain

You may have the right to submit a complaint to the relevant data protection authority.

For matters relating to processing governed by Cayman Islands law, you may contact the Office of the Ombudsman of the Cayman Islands.

For matters relating to processing governed by UK data protection law, you may contact the UK Information Commissioner's Office.

We would appreciate the opportunity to address your concerns directly before you approach a supervisory authority, although this does not affect your legal right to make a complaint.

20. Exercising Your Rights

To exercise a privacy right, please contact us using the details in Section 5.

When submitting a request, please provide enough information to allow us to:

• identify you;
• locate the relevant personal data;
• understand the right you wish to exercise; and
• respond appropriately.

We may request additional information or identification documents where reasonably necessary to verify your identity, protect personal data and prevent unauthorised disclosure.

You may authorise another person to submit a request on your behalf. We may require evidence of that person's authority and may need to verify your identity directly.

We will respond within the period required by applicable law. Where permitted, the response period may be extended for complex or multiple requests. If an extension applies, we will notify you where required.

We will generally not charge a fee for responding to a valid rights request. However, where permitted by law, we may charge a reasonable fee or decline to act if a request is manifestly unfounded, excessive, repetitive or otherwise abusive.

Certain information may be withheld where an exemption applies, including where disclosure would adversely affect the rights of another person, reveal legally privileged material, undermine an investigation, conflict with regulatory obligations or prejudice the prevention or detection of crime.

21. Direct Marketing

We may send relevant business-to-business communications, investor-relations materials, event invitations, publications or corporate updates to professional contacts where permitted by law.

We may rely on consent, legitimate interests or another permitted legal basis, depending on the nature of the communication and the jurisdiction of the recipient.

You may ask us to stop sending marketing communications at any time by:

• using the unsubscribe facility contained in an electronic communication;
• contacting the sender;
• emailing [email protected]; or
• contacting us using the details in Section 5.

Opting out of marketing communications will not prevent us from sending necessary administrative, contractual, compliance, regulatory, security or transactional communications.

22. Children's Privacy

Our website and services are intended for business, professional, institutional and investment-related audiences. They are not directed at children.

We do not knowingly seek to collect personal data from children through our general website.

If we become aware that personal data relating to a child has been collected inappropriately, we will take reasonable steps to delete or otherwise address the information.

Where information relating to a minor is lawfully required in connection with an investment structure, trust, estate, beneficial ownership arrangement, employment benefit or other legitimate activity, we will process it only for appropriate purposes and subject to applicable safeguards.

23. Confidentiality and Investment Information

Information submitted through the website should not be assumed to create an advisory, fiduciary, contractual or confidential relationship unless CE Global Private Equity has expressly agreed otherwise in writing.

You should not transmit highly sensitive, confidential, privileged, regulated or transaction-specific information through a general website form unless we have requested it and confirmed an appropriate transmission method.

Where you disclose personal data in connection with an investment, proposed transaction or confidential business matter, additional confidentiality provisions, engagement terms, non-disclosure agreements or transaction documents may also apply.

24. Communications Monitoring

To the extent permitted by applicable law, we may monitor, inspect, retain or record communications made through our business systems for:

• security;
• compliance;
• quality assurance;
• training;
• fraud prevention;
• evidential purposes;
• record keeping;
• business continuity;
• investigation of misconduct; and
• protection of our legal rights.

This may include business emails, telephone calls, instant messages, video conferences, file transfers and access to company systems.

25. Social Media and Professional Networking Platforms

CE Global Private Equity may maintain profiles on social media or professional networking platforms.

If you interact with us through such a platform, the platform operator may process your personal data independently in accordance with its own terms and privacy policy.

We may receive information including your name, profile, employer, job title, public posts, messages, reactions and other interactions. We may use that information to respond to you, manage professional relationships, monitor public commentary and communicate about our business.

Our ability to control information processed by a platform operator may be limited. You should review the platform's privacy settings and policies.

26. External Websites and Third-Party Services

Our website may provide links to third-party websites, publications, virtual data rooms, service portals or other resources.

Following a third-party link may allow the relevant third party to collect or receive personal data. CE Global Private Equity does not control those third parties and is not responsible for their privacy policies, security measures or processing activities.

The inclusion of a link does not necessarily constitute endorsement of the third party or its privacy practices.

27. Changes of Purpose

We will ordinarily use personal data only for the purposes for which it was collected or for another compatible purpose.

If we need to use personal data for a materially different and incompatible purpose, we will identify an appropriate legal basis and provide additional notice where required.

We may process personal data without additional notice where required or permitted by law, including for legal compliance, regulatory reporting, investigations, security or legal claims.

28. Changes to This Privacy Policy

We may amend this Privacy Policy periodically to reflect:

• changes to our business or activities;
• changes to our website;
• changes to the personal data we process;
• changes to legal or regulatory requirements;
• changes to regulatory guidance;
• changes to our service providers or international operations; or
• improvements to our privacy and security practices.

The updated version will be published on this page and the “Last updated” date will be revised.

Where a change is material, we may provide additional notice by email, through the website or by another appropriate method.

We encourage you to review this Privacy Policy periodically.

29. Contact and Complaints

Questions, concerns, complaints and requests regarding personal data should be sent to:

Privacy Contact
CE Global Private Equity Limited
121 South Church Street, George Town, Grand Cayman KY1-1104, Cayman Islands
Email: [email protected]
Telephone: ‪+1 345 987654321

Please include sufficient details to allow us to understand and investigate your concern.

29.1 Cayman Islands Supervisory Authority

Where the Cayman DPA applies, you may have the right to complain to:

Office of the Ombudsman
Cayman Islands

Current contact information for the Office of the Ombudsman can be found on its official website.

29.2 United Kingdom Supervisory Authority

Where UK data protection law applies, you may have the right to complain to:

Information Commissioner's Office
United Kingdom

Current contact information for the Information Commissioner's Office can be found on its official website.

30. Interpretation

In this Privacy Policy:

• “applicable law” means any privacy, data protection, communications, financial-services, employment, tax, anti-money laundering, sanctions or other law applicable to the relevant processing activity;
• “controller” means the person or organisation that determines the purposes and means of processing personal data;
• “personal data” or “personal information” means information relating to an identified or identifiable living individual;
• “processing” includes collecting, recording, organising, structuring, storing, adapting, retrieving, consulting, using, sharing, disclosing, combining, restricting, erasing or destroying personal data;
• “processor” means a person or organisation that processes personal data on behalf of a controller;
• “sensitive personal data” or “special-category data” means personal data that receives additional protection under applicable law; and
• “website” means the CE Global Private Equity website and any associated web pages, online forms, portals or digital services to which this Privacy Policy is displayed or linked.

31. Governing Language

This Privacy Policy is written in English. If it is translated into another language and there is any inconsistency between the English version and a translated version, the English version will prevail to the extent permitted by applicable law.