This data protection policy describes how Agave Advisors SA (“Agave Advisors”) treats the personal data it may receive as data controller. Any changes or updates to this policy will be communicated to Agave Advisors’ clients via the website: www.agave-advisors.com It is recommended to consult the Agave Advisors website in order to have the latest version of the AGAVE ADVISORS data protection policy available at all times.

1. Data controller
   Agave Advisors can be contacted at the following address for any questions or complaints: wecare@agave-advisors.com.
2. Type of personal data collected
   In the context of its business relations with clients and the legal and contractual obligations arising therefrom, Agave Advisors processes personal data received in principle directly from its clients, in particular:
   • identification and contact details, such as surname, first name, date of birth, telephone number and address.
   • data relating to family and professional profile, such as occupation, investment knowledge, etc;
   • financial and tax data, such as income, gains and investments, debts, tax residence, etc;
   • data relating to interactions with Agave Advisors and the use of the Company’s services, such as letters and e-mails.
   • any other data that Agave Advisors must collect by virtue of a legal obligation.

   As part of its legal obligations, Agave Advisors may also in certain cases collect personal data from third parties, for example by accessing public databases (e.g., internet search engines) or paying databases (e.g., press subscriptions). Agave Advisors may collect data via its website. Details can be found under this link.

3. Third party data
   If a client communicates third party personal data to Agave Advisors, the client must ensure that the data subject has been informed of this data protection policy.
4. Aim of the treatment
   Agave Advisors processes the personal data of its clients in particular to provide them with the services requested, to meet its legal obligations, as well as in the presence of overriding legitimate interests (e.g., exercising a right).
5. Communication to third parties
   Personal data is transferred to third parties when this is necessary to perform the services requested, in particular for the execution of transactions (e.g., communication to a bank or broker). In addition, Agave Advisors reserves the right to subcontract the processing of personal data to third parties who are contractually bound to confidentiality, such as IT or compliance services. Personal data may also be communicated to its legal advisors, audit firms, authorities, courts or similar institutions when Agave Advisors is required to disclose information under applicable law or regulation or to protect its legitimate interests.
6. Communication abroad
   Agave Advisors may need to communicate personal data abroad in order to perform its contract, in particular if the custodian bank of the client’s assets is located abroad or if this is required by law or applicable regulations. Agave Advisors undertakes to ensure that any transfer abroad complies with the applicable provisions.
7. Deletion
   Personal data is deleted when it is no longer reasonably necessary for the provision of the services and when Agave Advisors is not required to retain it by its legal obligations, unless Agave Advisors has an overriding private interest in retaining the data concerned.
8. Rights of the persons concerned
   Any person concerned by the processing of personal data has the right to access their personal data, to have it rectified, to prohibit or limit its processing, to request its deletion and in certain cases to request that it be handed over to them or passed on to a third party. Agave Advisors may be entitled to refuse to act on a complaint if there is a legal obligation to process the data concerned or if there is an overriding private interest on the part of Agave Advisors or a third party.
9. Data security
   Agave Advisors takes appropriate technical and organizational measures to protect the security of personal data, in compliance with applicable law.
10. Changes
    This data protection policy may be amended at any time; amendments take effect as soon as they are published on the Agave Advisors website.