Privacy Policy & Data Protection

1. The controller of personal information involved on this Website is:

Fusion Property Assets ELP (hereinafter referred to as "the Fund", "Fusion", "we", "us", or "our")

2. Mailing Address:

DSO–IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates

3. Contact Email:

This Policy applies to the collection and processing of personal information in the following circumstances:

• Technical and log information generated when you browse this Website;
• Information you actively provide to us through the "Contact Us" section of this Website, email, or other channels (such as name, contact details, affiliated institution, etc.);
• Personal information you provide as a potential investor, existing investor, business partner, or their contact person during communication and cooperation with the Fund;
• Personal information you provide when submitting a resume or background materials to us as a job applicant.

We collect the following categories of personal information within the scope of legality, legitimacy, and necessity (depending on specific scenarios, not necessarily all collected):

1. Basic Identity Information

• Name, title, gender (if you choose to provide);
• Nationality/region, country or region of residence (if required for compliance judgment).

2. Contact and Professional Information

• Email address, phone number, WeChat or WhatsApp and other communication accounts;
• Name of affiliated institution, position/title, department, etc.

3. Information Related to Investment and Business

• Your interest preferences in the Fund or related products, communication records and historical inquiries;
• In the event you become an investor or potential investor, to meet anti-money laundering, sanctions compliance, tax, and KYC/KYB requirements, it may be necessary to collect information such as identification documents, tax residency information, beneficial owner information, etc. (This part is usually collected through offline or secure channels and is subject to stricter confidentiality obligations).

4. Technical and Log Information (usually automatically collected through cookies or server logs)

• IP address, browser type and version, operating system, access time and time zone;
• Pages visited, dwell time, click records, referral source URL;
• Device identifiers, language settings, etc.

We may use the aforementioned personal information for the following purposes (each purpose uses relevant information only within the necessary scope):

1. Responding to Your Inquiries and Communication

• Handling questions, inquiries, or feedback you raise through the website, email, or other channels;
• Providing you with Fund materials or general information you actively request.

2. Maintaining and Improving Website and Services

• Understanding page views and user preferences by analyzing website visit data;
• Improving website structure and content presentation, enhancing browsing experience and security.

3. Establishing and Managing Business Relationships

• Maintaining reasonable contact with potential investors, existing investors, and partners;
• Communicating with you regarding matters such as meeting arrangements, due diligence progress, contract signing, etc.

4. Fulfilling Legal and Compliance Obligations

• Conducting KYC/KYB, anti-money laundering, and sanctions screening;
• Complying with applicable tax reporting, regulatory reporting, and record-keeping obligations;
• Cooperating with compliance requirements raised by courts, regulatory agencies, or other authorities with legitimate jurisdiction.

5. Protecting the Legitimate Rights and Interests of the Fund and Related Parties

• Preventing and investigating potential illegal activities, abuse, or compliance risks;
• When necessary, for establishing, exercising, or defending legal claims.

We will not use your personal information for purposes unrelated to the above. If we need to change the purpose of use, we will notify you separately within a reasonable scope and obtain your consent where required by law.

1. What are Cookies?

Cookies are small text files stored on your device by websites, used to remember your visit preferences and status to provide a better experience when you visit again. In addition to cookies, we may also use similar technologies (such as pixel tags, log files, etc.) to collect relevant information.

2. What Types of Cookies Do We Use?

Based on current website functionality, we anticipate possibly using the following types of cookies (actual situation may be further adjusted and labeled by the technical team):

1. Strictly Necessary Cookies
   Used to implement basic website functions, such as page navigation, secure access, language settings, etc.; if these cookies are disabled, this Website may not function properly.
2. Performance and Analytics Cookies (if enabled)
   Used to collect statistics on visit volume, popular pages, dwell time, etc., helping us understand website usage and optimize content; related data is usually analyzed in aggregated, anonymous, or de-identified form.

Currently, we do not use cookies for personalized advertising. If there are changes in the future, it will be separately stated in this Policy or in pop-up notifications.

3. How Can You Manage Cookies?

• Most browsers allow you to restrict or delete cookies through "Settings/Preferences" and can choose to prompt each time a cookie is written.
• If you choose to reject or delete some cookies, certain features of this Website may not be fully usable or the experience may be limited.
• If the website provides a dedicated cookie pop-up or options center, you can also adjust consent settings for non-essential cookies there.

Within a reasonable and necessary scope, we may share your personal information with the following categories of recipients:

1. Institutions Providing Professional Services to Us

• Administrators, legal advisors, audit institutions, compliance advisors, IT and website hosting service providers, etc.;
• Such service providers access your information only within the scope necessary to perform their services and are bound by confidentiality obligations.

2. Financial Institutions and Intermediaries

• Such as custodian institutions, banks, brokers, etc., for purposes of handling subscription/redemption payments, custody of assets, or transaction settlement, sharing information within the necessary scope.

3. Regulatory Agencies, Judicial Authorities, and Other Authorities with Legitimate Jurisdiction

• When required by laws and regulations or to fulfill regulatory obligations, we may provide necessary information to relevant agencies in accordance with the law.

4. Potential Counterparties or Professional Advisors

• In circumstances involving fund restructuring, mergers, significant asset transactions, etc., under the premise permitted by law and with appropriate protective measures, disclose necessary information to potential counterparties and their professional advisors.

Given that the Fund is a cross-border private structure and operates and invests in different countries/regions, your personal information may be stored or processed outside the country/region where it was collected, including but not limited to the Cayman Islands, Dubai, UAE, and other jurisdictions where we or service providers are located.

When conducting cross-border transfers, we will:

• Only transfer within the scope necessary to achieve the purposes described in this Policy;
• Take corresponding contractual arrangements, confidentiality terms, and security technical measures to protect the security of your personal information as much as possible;
• Take additional compliance measures where required by applicable law (such as complying with special rules for data transfer, etc.).

We will retain your personal information for the minimum period necessary to achieve the purposes described in this Policy, and determine the specific retention time by comprehensively considering the following factors:

• The period required to achieve the processing purposes;
• The minimum/maximum retention period stipulated by applicable laws and regulations (for example, anti-money laundering and tax regulations usually require retention for several years);
• Statute of limitations, regulatory requirements, and risk control needs.

When we no longer need to retain your personal information, we will delete, anonymize, or otherwise securely process the relevant data in accordance with applicable legal requirements and industry practices.

We take reasonable and appropriate technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, modification, or destruction, including but not limited to:

• Access control and principle of least privilege;
• Encrypted transmission or encrypted storage (depending on specific systems);
• Confidentiality obligations and compliance training for employees and service providers;
• Regular review of system security and access logs.

Under applicable data protection laws, subject to meeting specific conditions, you may have the following rights (the specific scope of rights and methods of exercise depend on the laws of your jurisdiction):

1. Right of Access: The right to inquire whether we process personal information related to you and obtain a copy;
2. Right to Rectification: If you believe that the information we hold about you is inaccurate or incomplete, you have the right to request correction or supplementation;
3. Right to Erasure: Under circumstances permitted by law, you may request us to delete personal information related to you;
4. Right to Restriction of Processing: In certain circumstances, the right to require us to restrict the processing of your personal information;
5. Right to Data Portability (if applicable): Subject to meeting legal conditions, require us to provide relevant data to you or a third party you designate in a structured, commonly used, and machine-readable format;
6. Right to Object: In specific circumstances, you have the right to object to our processing of your information for certain purposes (such as processing based on legitimate interests);
7. Right to Withdraw Consent: If we process personal information based on your consent, you have the right to withdraw that consent at any time (processing activities already carried out based on consent prior to withdrawal are not affected);
8. Right to Lodge a Complaint: If you believe that our information processing activities violate applicable data protection laws, you may lodge a complaint with the data protection supervisory authority with jurisdiction in your location.

If you wish to exercise any of the above rights, please contact us via ir@fusionfund.capital. To protect your privacy, we may need to verify your identity first. We will respond within the timeframe required by law.

This Website and the products and services of this Fund are not directed at minors (usually referring to those under 18 years of age or the age of majority stipulated by your jurisdiction).

We do not knowingly collect personal information from minors. If you believe we have collected information from a minor without parental consent, please contact us as soon as possible, and we will take appropriate measures in accordance with applicable law (including deletion, etc.).

We may update this Policy from time to time based on changes in laws and regulations, regulatory requirements, technological developments, or business adjustments. The updated version will be posted on this Website with the "Last Updated Date" indicated and will take effect from the time of publication.

For significant changes (such as substantive changes in processing purposes, significant impact on personal rights, etc.), we will notify you through website announcements, pop-ups, or other appropriate means within a reasonable scope.

It is recommended that you regularly review this Policy to understand how we protect your personal information.

This Website may provide this Policy in Chinese, English, and other language versions. To avoid ambiguity, if there are inconsistencies or differences in understanding between different language versions, the English version shall prevail.