Privacy Policy

Avalon Strategic Energy Transition Fund Inc. Privacy Policy

Updated: [Feb 18, 2025]
Version: 0.1D

Introduction

This Privacy Policy is established by Avalon Strategic Energy Transition Fund Inc., a company registered at [Placeholder Address] (“we,” “us,” “our”). This Policy sets forth our commitment to protecting the privacy of our users and investors by delineating our responsibilities as the data controller of your personal data. In this capacity, we determine the purposes and methods of processing such data.

1. Definition of Personal Data

Personal Data Defined

For the purposes of this Privacy Policy, “Personal Data” refers to any information relating to a living, identifiable individual. This includes data that can be used, alone or in combination with other information, to identify you.

2. Data Collection and Processing

How We Collect and Process Your Data

We collect and process data in connection with the services we provide.

When you submit an inquiry regarding our energy transition funds or related services, the information provided is processed as Inquiry Data. This data is used for the purpose of offering, marketing, and tailoring our investment solutions. The legal basis for this processing is your explicit consent.

Any communication you direct to us, including the associated metadata, is classified as Correspondence Data. We process this data to facilitate effective communication, maintain records, and provide timely responses.

In addition, we may collect information regarding your investment preferences and sustainability objectives. This data, which includes details about your investment choices, risk profiles, and sustainability impact metrics, is essential for developing personalized investment solutions and managing associated risks. Furthermore, where processing is required for legal claims, risk management, or regulatory compliance, we rely on our legitimate interests.

We kindly request that you do not submit personal data on behalf of any other individual unless explicitly requested by us.

3. Use of Data

Purpose of Data Use

Your personal data is used primarily to enhance the quality and customization of our services. We analyze website usage, manage technical administration, and employ cookies to understand user interactions. The data collected is also used for research and development purposes to continuously improve our energy investment strategies.

Our objective is to tailor our services to meet your specific needs. Accordingly, your data is processed to ensure a more intuitive and personalized user experience.

4. Data Storage and International Transfers

Data Storage and Transfer

Personal data is stored and processed primarily within the British Virgin Islands. We may, however, transfer your data to other jurisdictions as necessary for operational or compliance purposes. By using our services, you consent to such transfer, storage, and processing. For users accessing our services from outside the British Virgin Islands, please note that your data may be processed in locations with data protection laws that differ from those in your country.

5. Disclosure of Personal Data

Data Disclosure to Third Parties

We do not disclose your personal or business data to third parties except under specific circumstances. When necessary for risk management, professional advice, or to support investment decisions, your data may be shared with our insurers or advisers. In addition, we may disclose your personal data to comply with legal obligations, to safeguard vital interests, or for the establishment, exercise, or defence of legal claims. Should disclosure be mandated by law, such as by a subpoena or court order, we may be required to provide your data to the relevant authorities without prior notice.

6. Data Retention

Data Retention Policy

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. The retention period depends on the type of data and the legal or operational requirements. Once your data is no longer required, or when the purposes for its collection have been met, it is securely deleted or anonymized.

7. Data Security

Data Security Measures

We implement commercially reasonable technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. While we strive to secure your data, please note that no method of transmission over the Internet or method of electronic storage is entirely secure.

8. User Rights

Your Rights Regarding Your Data

Under applicable data protection laws, you are entitled to certain rights regarding your personal data. You have the right to request access to, correction of, or deletion of your data. You may also request that we restrict the processing of your data or provide it in a portable format. Additionally, you reserve the right to withdraw your consent at any time without affecting the lawfulness of processing conducted prior to such withdrawal. If you believe that our handling of your data infringes your rights, you may lodge a complaint with the appropriate supervisory authority. Requests to exercise your rights should be submitted in writing using the contact details provided below.

9. Cookies

Use of Cookies

Our website employs cookies to enhance functionality, authenticate users, manage sessions, and improve user experience. Cookies allow us to understand how you interact with our website and store your preferences for future visits. You may adjust your cookie settings via your browser; however, disabling cookies may impair the functionality and usability of our website.

10. Third-Party Processors and Service Providers

Third-Party Data Processors

We may engage third-party processors and service providers to assist in the operation of our services. These entities are required to adhere to confidentiality and data protection obligations that are consistent with this Privacy Policy. We do not permit third parties to use your personal data for purposes beyond those specified in this Policy.

11. Data Breach Notification

Data Breach Protocol

In the unlikely event of a data breach, we will notify you and the relevant supervisory authorities in a timely manner in accordance with applicable legal requirements. Such notification will include details of the breach, the categories and approximate number of data subjects affected, and the measures taken to address the breach.

12. Governing Law and Jurisdiction

Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the British Virgin Islands. Any disputes arising from or related to this Policy shall be subject to the exclusive jurisdiction of the courts in the British Virgin Islands.

13. Regulatory and Contact Information

Contact and Regulatory Information

If you believe that our processing of your personal data infringes your rights, you may file a complaint with the appropriate supervisory authority in your jurisdiction. For inquiries or further information regarding this Privacy Policy or our data practices, please contact us via our website’s contact form, by telephone during regular business hours, or by email at [contact@avafundco.com]. Should you require additional assistance, please reach out to our Data Protection Officer at [Placeholder Address] or via email at privacy@avafundco.com.

14. Amendments

Policy Updates

We reserve the right to update this Privacy Policy from time to time. Each revised version shall govern the processing of personal data collected during the period in which the preceding version was in effect. We encourage you to review this Policy periodically to stay informed of any changes.

16. Language

Language of Policy

This Privacy Policy has been drafted in English. In the event of a translation into another language, the English version shall prevail.

Corporate Information Avalon Strategic Energy Transition Fund Inc. is registered with the business number [Placeholder]. Its registered address is [Placeholder Address], and it is based in the British Virgin Islands.