Eight Roads (we, us, our) respects your privacy and is committed to protecting the personal data/information belonging to you which it collects. This privacy policy sets out the basis on which the data we collect about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our approach and practices regarding your personal data and how we will treat it.

1. INFORMATION ABOUT US

Eight Roads is a global venture capital firm which uses personal data in order to source, transact and manage investment opportunities and comply with legal and governance obligations. We do not provide products or services to individuals for their personal use.

Headquartered in Bermuda, Eight Roads conducts business through a number of entities in its group across Bermuda, China, Hong Kong, India, Japan and the UK.

Each of Eight Roads Capital Advisors (UK) Limited, Eight Roads Services (UK) Limited, Eight Roads GP, Eight Roads Holdings Limited, Eight Roads Capital Advisors (Hong Kong) Limited, Eight Roads Capital Advisors (Hong Kong) Limited, Japan Branch, Eight Roads Investment Advisors Private Limited is a data controller for the purposes of this notice.

For the sole purposes of the Personal Information Protection Act 2016 in Bermuda, the privacy officer in Bermuda is Eight Roads Head of Risk & Compliance, James McLaughlin.

2. WHO DO WE COLLECT INFORMATION ABOUT?

We do not provide products or services, or promote our business, to consumers. We do collect information about individuals who invest in or are concerned with the investments we manage, and much of our work is the evaluation of existing and potential investments. We therefore collect information about individuals who are or may become directors, officers, employees, shareholders or persons with management or control responsibility in:

• existing or potential investments
• other co-investors with us in our investments (or potential investments)

We also collect:

• information relating to our suppliers in order to conduct our business with them
• CV details when undertaking a search for new team members to join our business and also businesses that we invest in
• information about individuals representing businesses that we work with
• certain information from users of our website, as described in Section 6.4
• certain information from employees.

3. WHAT INFORMATION WE COLLECT

We collect and process the following types of information on the lawful basis as described next to it (depending on the purpose for which it is collected):

4. SOURCES AND HOW WE COLLECT INFORMATION

We collect information:

• through contact with you, your advisers and with businesses you are associated with or employed by
• from the evaluation and completion of investment transactions including information provided during the due diligence process
• from public domain sources, such as social media and newspaper reports
• from third party sources, such as the providers of databases which we use to assist us in building our CRM information, undertaking investment due diligence and background checking.

5. HOW WE USE INFORMATION

We use personal information for a number of purposes, including the performance of our contractual obligations, to comply with our legal and regulatory obligations and in relation to our legitimate interests in operating and promoting our business. In doing so, we balance our appropriate business needs with your right to have your information handled in a way which does not unreasonably prejudice your interests.

Where we process personal information for our legitimate interests, these interests include:

• to evaluate and execute potential investment opportunities
• to operate and manage our investments
• to carry out market research, business and statistical analysis
• to comply with best practice and standards in making investment decisions
• to comply with applicable law, regulation and internal compliance relating to the prevention of fraud, tax evasion, bribery and corruption, money laundering and terrorist offences or relating to cyber or data security
• to conduct staff hiring and human resource management.

The most common use of personal information for us is as an input to our opinion on whether to pursue, or complete, an investment transaction and if so, on what terms. We may decide not to pursue an investment transaction (or be unable to do so for legal or regulatory reasons) as a result of due diligence and background check enquiries (and the information revealed by those enquiries).

We are required to use certain personal information in order to comply with legal obligations to which we are subject. If we contract with you directly, we will use personal information in order to perform our contractual obligations.

We only collect and process "special categories" of information (such as information regarding political affiliations) when we have been provided with it by you or by third party providers of due diligence and background checking data services, or from information which is in the public domain.

6. OUR WEBSITE

We use cookies to distinguish between users of our website, to collect information about users' online preferences, to provide users with a good experience when browsing our website and to improve our website. Cookies are small pieces of information sent by a web server to a web browser which allow the server to uniquely identify the browser on each page.

If you are a user of our website and you want to delete any cookies already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. You can block cookies by activating the setting on your internet browser that allows you to refuse the setting of all or some cookies. Please note that if you delete our cookies or disable future cookies, you may not be able to access certain areas or features of our website.

PERFORMANCE COOKIES

We use performance cookies which collect anonymous information on how people use our website. For example, we use Google Analytics cookies to help us to understand how users arrive at our website, browse or use our website and highlight areas that can be improved such as navigation. The data stored by these cookies never shows personal details from which users' individual identities can be established.

USE OF WEB BEACONS

Some of our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides.

LINKS TO OTHER WEBSITES

Our website contains links to other websites. Any such links are provided for your convenience only. We are not responsible for privacy policies or practices of other websites to which users choose to link from our website. We encourage users to review the privacy policies of those other websites to understand how they collect, use and share personal information. Furthermore, we have no control over third party websites and accept no legal responsibility for any content, material or information contained in them. Your use of a third party site may be governed by the terms and conditions of that third party site.

7. MARKETING COMMUNICATIONS

We may use your information to send you marketing communications, for example, with newsletters and invitations to events. If you do not wish to receive these kinds of communications, you can opt out of our mailing list.

8. SHARING INFORMATION

We may use your information to send you marketing communications, for example, with newsletters and invitations to events. If you do not wish to receive these kinds of communications, you can opt out of our mailing list.

We may share information with other companies in the Eight Roads group and with our associated firms, FIL Limited and FMR LLC (and members of their groups), with associated entities and limited partners of the venture funds in which we invest.

We may share information collected as detailed under Section 4 in order to comply with legal and regulatory obligations and best practice in relation to investment due diligence and decisions.

We may share information with third party suppliers or service providers, for example, professional advisers, but this will be limited to the amount of information needed for that third party to carry out the relevant function.

We may also share information with third parties where you have authorised us to do so, or for compliance with legal and regulatory obligations, such as providing information for the purposes of completing tax returns, responding to queries from regulators and other authorities. We will never transfer more personal data than is necessary to discharge our legal obligations.

If you would like more details about our sharing of your personal information, please contact us as set out in Section 1.

9. OUR RETENTION OF INFORMATION

We retain information we collect for as long as is reasonably necessary to comply with the purposes set out in Section 5.

10. SECURITY

We have implemented reasonable technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. These include the anonymisation and encryption of information stored in our systems where possible.

In accessing our website, because the internet is an open system, we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use our website users' personal information for improper purposes.

11. TRANSFERS OF INFORMATION

Personal data may be transferred outside of the country or region where it was initially collected by Eight Roads.

In respect of transfers of personal information from the UK or the EEA to countries outside the UK or the EEA, including to other members of the Eight Roads group, Eight Roads will either transfer the personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK (as appropriate) or we will ensure that the UK and/or European Commission (as appropriate) approved safeguards for international transfers of personal data outside of the UK and/or EEA are adopted.

In respect of transfers of personal information from Hong Kong to countries/regions outside Hong Kong, including to other members of the Eight Roads group, by accepting this privacy policy, you consent to such transfer. This may include transfers to some countries/regions that do not provide the substantially similar legal protection for personal information to Hong Kong. We take reasonable steps to ensure that all such recipients adequately protect such personal data.

You can contact us as detailed in Section 1 to find out more about such transfers.

12. YOUR RIGHTS

In accordance with the terms of the applicable laws, you have a right to:

• access information we hold about you, and know for what purpose we use that information
• correct inaccuracies in information we hold about you
• withdraw any consent you have given to use of your information
• complain to the relevant supervisory authority in any jurisdiction about our use of your information
• in some circumstances:
• • request that we erase information we hold about you
  • receive a copy of any personal information provided by you and require us to provide this information to a third party
  • restrict the use of information we hold about you
  • object to the use of information we hold about you, including where that information is used for direct marketing purposes.

You can exercise these rights by contacting us as detailed under Section 1.

In accordance with the terms of the applicable ordinance, we have the right to charge a reasonable fee for the processing of any data access request in Hong Kong.

13. CHANGES TO OUR PRIVACY POLICY

If our privacy policy changes in any way, we will place an updated version on our website.

Thank you for visiting our website.