1. Privacy Policy

This policy describes how ATLAS RE CAPITAL S.C.A., SICAV-RAIF collects, uses, protects, and processes personal data in accordance with the General Data Protection Regulation (GDPR).

ARTICLE 1 — Data Controller

The data controller is:

ATLAS RE CAPITAL S.C.A., SICAV-RAIF
Registered office: [Address to be completed], Luxembourg
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

ARTICLE 2 — Personal Data Collected

ATLAS RE CAPITAL may collect the following categories:

2.1 Identification Data

• Last name
• First name
• Position
• Company

2.2 Contact Details

• Email address
• Phone number
• Postal address

2.3 Connection and Browsing Data

• IP address
• Technical logs
• Cookies and trackers (see Cookies section)

2.4 Investor Data (if applicable)

• Status as a professional/qualified investor
• Information required for regulatory obligations (KYC / AML-CFT)
• Subscription history

ARTICLE 3 — Purpose of Processing

Your data is used for:

1. Responding to requests submitted via the website
2. Verifying eligible investor status (professional/qualified investor)
3. Complying with regulatory obligations:
• anti-money laundering (AML-CFT)
• identification/verification (KYC)
4. Managing the investor relationship
5. Sending communications related to the Fund (with consent)
6. Measuring audience and improving the website (analytical cookies)

ARTICLE 4 — Legal Basis

Processing is based on:

• Your consent (forms, analytical cookies)
• The performance of pre-contractual and contractual measures (investor relationship)
• Compliance with legal obligations (KYC / AML-CFT)
• ATLAS RE CAPITAL’s legitimate interest (website improvement, statistics)

ARTICLE 5 — Data Recipients

Data may be shared with:

• The Fund’s AIFM and its service providers
• The Depositary
• Regulatory authorities (upon request)
• Technical service providers (hosting, CRM, maintenance)

No transfer outside the EEA without adequate safeguards.

ARTICLE 6 — Data Retention Period

• Contact data: 3 years after last contact
• Investor data: duration of the relationship + 10 years
• Logs and cookies: maximum 13 months

ARTICLE 7 — Your GDPR Rights

In accordance with the GDPR, you have the following rights:

• Right of access
• Right to rectification
• Right to erasure (under conditions)
• Right to restriction of processing
• Right to object
• Right to data portability
• Right to withdraw your consent at any time

To exercise a right: This email address is being protected from spambots. You need JavaScript enabled to view it.

For complaints, you can contact the CNPD (Luxembourg).

2. Cookie Policy

ATLAS RE CAPITAL uses cookies to ensure:

• proper website functionality,
• enhanced user experience,
• statistical audience analysis.

ARTICLE 8 — Types of Cookies Used

8.1 Strictly Necessary Cookies

Essential for the website’s operation:
navigation, security, session management.

8.2 Analytical Cookies

Allow to:

• measure audience,
• analyze website performance,
• optimize user experience.

(e.g., Google Analytics or equivalent)

8.3 Preference Cookies

Remember user choices (language, display).

ARTICLE 9 — Cookie Management

You can:

• accept all cookies,
• refuse non-essential cookies,
• configure your browser to block them.

Refusing certain cookies may limit some functionalities.

ARTICLE 10 — Security

ATLAS RE CAPITAL implements technical and organizational measures to protect personal data against:

• loss,
• alteration,
• destruction,
• unauthorized access.

ARTICLE 11 — Policy Update

This policy may be updated at any time to reflect:

• legal developments,
• the Fund’s practices,
• technologies used.

Last update: December 2025