Updated and Effective Date: January 1, 2019

THIS PRIVACY POLICY APPLIES TO OUR WEBSITES AND PLATFORMS.

This Privacy Policy describes how Greenland Investment Management and its affiliates (“Greenland”, “we”, “our” or “us”) treat personal information collected on greenlandim.com where this Privacy Policy is located (the “Site”). This Privacy Policy does not apply to personal information Greenland collects offline, through email, or through other sites. This Privacy Policy also does not apply to websites or platforms where it is not posted and where a link to the Privacy Policy is not provided. It also may not apply to the practices of all Greenland subsidiaries or other affiliates. For example, this Privacy Policy does not apply to customers or consumers of Greenland financial services or products with respect to your use of such financial services or products.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect contact information. For example, we might collect your name, address, and email address when you register on our Site, sign up for our newsletters, or apply for a job.

We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Site. This may contain personal information about you.

We collect other information. We may also collect usage data on how you use our Site and how long you stay on the Site through the use of cookies or other commonly used technologies (e.g. web beacons). This may include information about your browser, device type, IP address, etc. and contain personal information about you.

Aggregate information. We collect statistical information about how users use the website, some of which is derived from personal information but is not itself personal information.

WE COLLECT INFORMATION IN DIFFERENT WAYS.

We collect information directly from you. For example, if you register with us, sign up for our newsletters, apply for a job, or send us an email via the Site.

We collect information from you passively. We use tracking tools like browser cookies and web beacons to provide and support our Site and each of the uses outlined in this Privacy Policy. Learn more about these tools and how you can manage them, by visiting our Cookies Policy.

We may collect information about you from third parties. For example, our business partners or vendors may give us personal information about you. We may combine this information with information that you give us via the Site.

We may collect personal information as otherwise described at the time of collection on the Site.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

The provision of personal data by you may be necessary for the performance of any contractual relationship with you, or where we have a legitimate interest to carry out the following purposes:

We use information about you to respond to your requests or questions. For example, we might use your information to contact you about employment opportunities or to process your application for a job.

We use information about you to improve our websites and the information we provide. We might use your personal information to deliver the Site and/or customize your experience with us. For example, we may use your personal information to improve the Site, our recruiting efforts and our other internal business purposes.

We use information for security and compliance purposes. We may use personal information to enforce our rights, for fraud prevention, to comply with applicable laws and regulations, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.

We use personal information to inform you about Greenland. For example, we might send you information about Greenland and what we offer. We might tell you about new features or updates. We may also use your personal information to send you information about career opportunities.

We use personal information to communicate with you about your account or our relationship. We may contact you about your use of our Site. We may contact you about your account or feedback. We might also contact you about this Privacy Policy or the Site’s Terms of Use.

We may use your personal information as otherwise described or permitted by law, for any other purpose as described in this Privacy Policy, or as we may notify you.

WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.

We may share your personal information within the Greenland family of companies.

We may use your personal information to respond to your requests or questions. For example, we might share your personal information with third parties in order to provide you with services requested by you or answer your questions.

We will share personal information with third parties who perform services on our behalf. For example, we share personal information with our vendors (e.g., IT services providers and background checks vendors), partners and consultants. We may also share personal information with companies that operate our websites.

We will share personal information if we think we have to in order to comply with the law or to protect ourselves. For example, we may share personal information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests. We might also share personal information when we are investigating potential fraud or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

We may share personal information with any successor to all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of Greenland or part of its business (or in anticipation of such an event) we may share your personal information as part of that transaction.

We may share personal information for other reasons we may describe to you or as permitted by law.

YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us.

RIGHTS FOR INDIVIDUALS IN THE EUROPEAN UNION

While Greenland uses reasonable efforts to update the information contained in the Site, Greenland makes no representations or warranties as to the accuracy, reliability or completeness of any information, Greenland Content, or User content, at or on the Site. Any content of the Site is subject to change without notice. As noted above, permission by Greenland to access this Site should not be construed as, or relied upon as, investment, financial, legal, regulatory, accounting, tax or similar advice. You acknowledge that any reliance on such material or systems will be at your own risk. Greenland makes no representations regarding the amount of time that any Greenland Content or User Content will be preserved.

Individuals who are located in or residents of the European Union have certain data subject rights that may be subject to limitations and/or restrictions.

You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the purpose or to object to the processing of your personal information as well as a right to data portability.

Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to [email protected]

For the purposes of EU data protection laws, we are the data controller of your personal information collected on the Site. This means that we are responsible for, and control the processing of, your personal information. Our data protection representative for the EU in Greenland Investment Management, which can be reached at [email protected]

Our Do Not Track Policy. Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our Sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

GREENLAND SITES AND CHILDREN

Our Sites are meant for adults. We do not knowingly collect personal information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.”

WE USE STANDARD SECURITY MEASURES

The Internet is not 100% secure. We cannot promise that your use of our Sites or software will be completely safe. We encourage you to use caution when transmitting personal information over the Internet. We keep personal information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep personal information as otherwise required by law or for internal compliance or record-keeping purposes.

WE STORE PERSONAL INFORMATION IN MULTIPLE COUNTRIES

Personal information we collect may be transferred to and stored within multiple countries (“Storage Countries”). Our Sites are subject to Mauritian laws, which may not afford the same level of protection as those in your country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. If you live outside of the Storage Countries, you understand and agree that we may transfer your personal information to the Storage Countries. You acknowledge that if you do not consent or would like to withdraw your consent to such transfer by contacting [email protected], it will impact your ability to use our Sites.

WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL

If you click on a link to a third party website, you will be taken to website(s) that we do not control. This Privacy Policy does not apply to the privacy practices of such third party website(s). Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s).

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at:

Greenland Investment Management, 4th Floor, 19 Bank Street, CyberCity, Ebene 72201, Mauritius, Attn: Legal / Privacy Matters

We may update this Privacy Policy

From time to time we may change our privacy policies. We will notify you of any material changes to our Privacy Policy as required by law by posting a notice on our Site prior to the change becoming effective. We will also post an updated copy on our Site. Please check our Site periodically for updates. You are bound by any changes to the Privacy Policy when you use the website after such changes have been first posted.