Last updated December 2018

Thank you for visiting Zanklon Capital (“Website”). We operate an investment fund which focuses on advancing loans secured commercial real estate located in Europe. We are committed to protecting and respecting your privacy.

This policy together with our Terms of Use sets out the basis on which any personal data we collect from you (“you”, “your”, or “user”), or that you provide to us, will be processed by us. Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us and you.

The data controller of your personal data is Zanklon Capital, a company registered office in Harwood House, 43 Harwood Road, London, United Kingdom, SW6 4QP (“Zanklon”, “we” or “us”) (info@zanklon.com).

IF YOU DO NOT ACCEPT AND AGREE WITH OUR PRIVACY POLICY THEN YOU MUST NOT ACCESS OR USE THE WEBSITE.

INFORMATION WE COLLECT FROM YOU

• Information you give us. This is information about you that you give us by filling in the ‘Contact Us’ form on the Website or by corresponding with us by phone, e-mail or otherwise.

This information may include your name, email address, postal address, employer and any details that you may provide us with.

• Information we collect about you. With regard to each of your visits to the Website we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

• information about your visit, including the dates and times you use the Website, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Website.

COOKIES

We use cookies to distinguish you from other users of the Website. This helps us to provide you with a smooth experience when you visit the Website, and also allows us to improve the Website.  A cookie is a small text file that can be placed on your computer or other device when using the Website.

First and third party cookies

We set cookies (first party cookies) on web pages, however, where we require additional information or services, we may also allow other companies to host cookies on our web pages (third party cookies). These partner companies have been carefully selected by us and are required to meet contractual obligations they have with us.

What do we use cookies for?

The cookies on this website may be from any of four categories:

1. Strictly Necessary cookies – these cookies are used for technical reasons and are necessary to enable the Website to operate efficiently so that you can navigate the Website with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Website may not operate effectively.

1. Performance cookies – these cookies are used to obtain statistics about the number of users of the Website and how such users interact with the Website. These cookies collect information that is aggregated and therefore cannot be used to ascertain an individual’s identity. Such information allows us to continuously improve the Website to provide users with a better online.

1. Functionality cookies – these cookies are used to improve the functionality of the Website and make it easier to use. They help us to identify you as a repeat user of the Website and help us remember your preferences (for example, your choice of language or region), improving your user experience.

1. Analytical – These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose

We may share information that we collected through cookies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies as set out below.

How do I control my cookie settings on my computer or device?

Please be aware that if you decide to disable or block cookies, parts of the Website may not function correctly, or at all.

Should you choose however to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the ‘Help’ menu on your particular browser to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org  or www.youronlinechoices.eu for comprehensive information on how to manage cookies.

USES MADE OF THE INFORMATION

We may use information held about you in the following ways:

Information you give to us. We will use this information:

• to provide you with information in respect of your enquiry;

• to notify you about changes to any services we provide; and

Information we collect about you. We will use this information:

• to deliver the Website effectively and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• to improve the Website to ensure that content is presented in the most effective manner for you and for your computer or other device;

• as part of our efforts to keep the Website safe and secure;

• to make suggestions and recommendations to you about services we offer that may interest you; and

DISCLOSURE OF YOUR INFORMATION

You agree that we have the right to share your personal data with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

• Selected third parties, including analytics and search engine providers that assist us in the improvement and optimisation of the Website.

We will disclose your personal data to third parties:

• If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.

• If Zanklon or substantially all of its assets are acquired by a third party, in which case personal data held by it about its Websites’ users will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use  and other agreements; or to protect the rights, property, or safety of us, our clients, or others.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you will be transferred to, and stored at, a destination within the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. All information you provide to us is stored on our secure servers.

Unfortunately, the transmission of information via the internet is not completely secure. While we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us over the email or through the ‘Contact Us’ form on the Website; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have a number of rights in relation to how we process your personal data.  These include:

• the right access the personal data that we may hold about you;

• the right to rectify any inaccurate personal data that we may hold about you;

• the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to process your personal data to fulfil our processing purposes; where you object to your data being processed on certain grounds (for example, for marketing purposes)  or where your personal data is being unlawfully processed; and

• the right to have your data ported to a new service provider if you no longer wish to use the Website or our services.

You can exercise any of these rights any time by contacting us at info@zanklon.com.

The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

CONTACT

Questions, comments and requests regarding this privacy policy should be addressed to info@zanklon.com.

Should you have any concerns about how we handle your personal data, please contact us in the first instance.  We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the Information Commissioner’s Office (ICO).  For further details on how to complain to the ICO, please follow the links below: https://ico.org.uk/concerns/ or https://ico.org.uk/global/contact-us/.