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Privacy Policy
Zenith Capital (BVI) Ltd.
Effective Date: March 1st, 2025

Please read this Privacy Policy carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal information as set out in this Privacy Policy.

1. Introduction

At Zentih Capital (BVI) Ltd. ("we," "us," or "our"), safeguarding your personal data is a cornerstone of our operations. This Privacy Policy outlines how we collect, process, and protect your information through our website https://zenithbvi.com/prospecting-form.php in compliance with the laws of the British Virgin Islands (BVI) and Cayman Islands. We adhere to the highest standards of transparency and accountability, ensuring your rights are respected at all times.

2. Privacy Principles

Our business has been built on trust between our customers and ourselves. To preserve the confidentiality of all information you provide us, we maintain the following privacy principles:

• We only collect personal information that we believe to be relevant and required to process our Know-Your-Client process and to evalute you as an investor of any fund managed by us.
• We use your personal information to provide you with better investor services.
• We will not disclose your personal information to any external organisation unless we have your consent or are required by prevailing law and regulations or it will be used by any affiliate entity of Zenthi Capital (BVI) Ltd.
• We may be required from time to time to disclose your personal information to governmental or judicial bodies or agencies or our regulators, but we will only do so under the limits and scope provided by law.
• We aim to keep your personal information on our records accurate and up-to-date.
• We maintain strict security systems designed to prevent unauthorised access to your personal information by anyone, including our staff.
• All our staff and all third parties with permitted access to your information are specifically required to observe our confidentiality obligations.

By maintaining our commitment to these principles, we at Zenith Capital (BVI) will ensure that we respect the inherent trust that you place in us.

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3. Scope and Applicability

This policy applies to:

• Current and prospective investors, shareholders, and authorized representatives related to any fund managed by Zenith Capital (BVI).
• Visitors to our website https://zenithbvi.com/prospecting-form.php and users of our digital platforms.
• Third-party service providers and intermediaries engaged in our operations.

We comply with:

• British Virgin Islands: Data Protection Act, 2021 (DPA), aligned with GDPR principles.
• Cayman Islands: Data Protection Act, 2021 (DPA), including lawful processing principles and data subject rights.

4. Types of Personal Data We Collect

• Identification Data: Full name, date of birth, government-issued ID, nationality.
• Contact Details: Physical address, email, phone number.
• Financial Information: Bank details, tax ID, investment history, and transactions.
• Due Diligence Data: Source of wealth, beneficial ownership docs, KYC/AML checks.
• Technical Data: IP address, browser type, cookies, usage analytics.

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5. Lawful Basis for Processing

We process your data only where legally justified:

• Performance of a contract (e.g., managing investments).
• Compliance with legal obligations (e.g., AML/KYC checks).
• Legitimate interests, unless overridden by your rights (e.g., fraud prevention).

6. How We Use Your Data

• Administer investments, process transactions, deliver reports.
• Conduct regulatory compliance checks.
• Communicate updates or promotional materials (with consent).
• Prevent fraud and enhance cybersecurity.

7. Data Sharing and International Transfers

We may share data with:

• Service Providers: Admins, custodians, legal/audit/advisory vendors, etc.
• Regulators: BVI FSC and Cayman CIMA.
• Authorities: In response to lawful orders or investigations.

Cross-Border Transfers follow adequacy safeguards (e.g., SCCs).

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8. Data Retention

We retain personal data:

• As long as needed to meet legal, regulatory, or operational purposes (e.g., 5 years post-investment).
• Possibly longer for litigation, audits, or regulator requirements.

9. Breach of Internet Security

We implement corrective measures in case of breach, but are not liable for unauthorized third-party access or hacking.

10. Investor Rights

You may exercise the following rights:

• Access, Correction, Erasure
• Object/Restrict Processing
• Data Portability
• Withdraw Consent (e.g., for marketing)

Submit written request to the Data Protection Officer (see Section 14). We respond within 30 days.

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11. Security Measures

• Technical: AES-256 encryption, MFA, secure storage.
• Organizational: Limited access, staff training, vendor audits.
• Breach Response: Notify regulators and affected users within 72 hours.

12. Cookies and Digital Tracking

Our site uses cookies for functionality, analytics, and performance. Non-essential cookies require your consent. Manage them through our [Cookie Management Portal].

13. Policy Updates

This policy may be updated at any time. Your continued use implies agreement with changes. We encourage periodic review.

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14. Contact Us

If you have any questions or concerns:

Data Protection Officer
Email: dataprotection@zenithbvi.com

This policy reflects our unwavering commitment to protecting your privacy while delivering exceptional asset management services.