MIV Asset Management AG takes the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the applicable data protection laws. This privacy policy explains how we collect, store and process personal data and informs you about your rights concerning your processed personal data.

Definitions

• "Activities" refers to all our activities in connection with the Variopartner SICAV - MIV Global Medtech Fund managed by us, an application procedure or an employment with MIV Asset Management AG.
• "Data Protection Acts" includes the Swiss Data Protection Act, the EU General Data Protection Regulation and any other applicable data protection regulations.
• "Processing" has the meaning provided for in the respectively applicable data protection laws.
• "Personal data" is all information about an identified or identifiable natural person, in particular all information which you transmit to MIV Asset Management AG via our website or which we collect from you in the course of our activities or your application process as an employee of MIV Asset Management AG or which is defined as such by the respectively applicable data protection laws.

Collection of personal data

In the course of our activities we may collect the following personal data:

• Professional contact data of existing and interested investors and of service providers as well as of their authorized representatives (such as name, first name, address, e-mail address, telephone number, mobile phone number, company name, function, absence information, gender, marital status);
• Private contact and identification data of employees and applicants (such as name, first name, address, e-mail address, telephone number, mobile phone number, date of birth, nationality, social security number, passport, ID);
• Personal and professional data of employees and applicants (e.g. data on spouses and children, marital status, photos of employees, CVs, diplomas, letters of reference, grades, evaluations, reviews, criminal records, sanctions lists, bank details);
• Employee time management data (for example, absences and working hours logs);
• employee location data (for example, WLAN positioning and IP address).

How we collect personal data

Generally, we collect or receive personal data directly from you or your authorized representatives. The collection of personal data is usually carried out as follows:

• When you use our website;
• When you fill out an application form for the Variopartner SICAV - MIV Global Medtech Fund newsletter;
• When you apply for a position at MIV Asset Management AG and during your employment;
• On the occasion of communications or phone calls to our employees;
• Via publicly accessible sources (e.g. publicly accessible registers, economic databases, etc.).

Use of your personal data

We will only use your personal data within the scope of our activities and/or to fulfil our contractual or legal obligations. Personal data may be used by us for the following reasons:

• Communication with you in connection with your current or planned investment (this communication may take various forms, including telephone, SMS, e-mail and post);
• To provide you with a continuing service (e.g. to send you information or marketing materials that may be of interest to you);
• To comply with legal or internal accounting requirements.

Please note that you can opt out of receiving marketing communications from us at any time. In this case, please contact us using the contact details below or the opt-out option provided in the marketing communication.

Passing on your personal data

In order to provide you with the services you have requested and for the purposes mentioned above, your personal data may be passed on to third parties. Some of your personal data may therefore be passed on to the management company Vontobel Asset Management S.A. Luxemburg.

We also take appropriate measures to ensure that these third parties are bound by confidentiality and data protection obligations with regard to the protection of your personal data. These third parties may include:

• Vontobel Asset Management SA in Luxembourg, (Management Company);
• External service providers (e.g. IT service providers etc.);
• External consultants (e.g. accountants, lawyers, consultants, auditors);
• Other third parties, where necessary or legally permissible, or in connection with legal proceedings.

During the processing of some Personal Data described above, some Personal Data may be transferred to a country other than Switzerland, namely to countries of the European Economic Area ("EEA") which have an adequate level of data protection as defined by the EU.

Secure storage of personal data

We use reasonable efforts to protect your personal information from misuse, loss, damage, unauthorized access, alteration or disclosure. Access to and use of personal information is regulated in order to prevent the misuse or unlawful disclosure of such information. We use security procedures such as firewalls, intrusion detection, anti-virus technology and password login in order to prevent unauthorized access.

Storage of personal data

We store information for as long as is necessary to provide you with a continuous service or to fulfil one of our contractual obligations, but also longer if required by law. When personal data is no longer required by us, it is destroyed or de-identified.

Access and control of personal data

You can contact us by e-mail or telephone to request access to your personal information. However, please note that we must verify your identity before we can grant you access to information about you. Please also note that in due course there may be a legal reason why we must refuse such access, particularly if granting access would compromise the privacy of others or lead to a breach of confidentiality. If such access is denied, we will inform you of the reasons for a written denial and the possibility to complain about the denial. Access to this information may involve costs for you. However, there will be no charge for requests and corrections of your personal information.

Correction of your personal data

We strive to keep your personal information accurate, complete, current and relevant. To this end, we ask you to inform us as soon as your data changes. If you believe that the personal information we hold about you is incorrect, incomplete, inaccurate or misleading, you may ask us to change it.

Use of our website

Because our site is connected to the Internet and the Internet is inherently insecure, we cannot guarantee the security of any information or data you transmit to us online. We also cannot guarantee that the information you submit will not be intercepted during transmission over the Internet. Accordingly, any personal data or other information you transmit to us online is transmitted at your own risk.

Cookies

We may use "cookies" to better tailor our website to your needs (e.g. we may use cookies to store the personal settings you have specified) and to provide a more effective way to access various components of our website. If you choose to disable cookies, the functionality of our website may be affected. Cookies are small text files that are stored in the memory and hard drive of your computer, mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to website owners or other third parties who receive data from this website. This information may relate to you, your settings or your device and is used primarily to help us make the website work the way you expect it to. The information does not generally identify you directly, but it can provide you with a more personalized web experience.

Cookies help us to offer tailor-made services and information. We use cookies to tell us generally how and when pages on our websites are visited, what technology preferences our users have and whether our website is functioning properly. Depending on their purpose, some cookies only function for the duration of a single browser session, while others have a longer lifetime to ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that as long as a cookie is active, you can delete cookies (and thus stop any further data collection), as described in more detail below.
If you use a password-protected website, the website may use cookies or other technologies to authenticate you, store and recognize your configuration and user attributes, facilitate your navigation on the website, and customize its content so that the information provided is appropriate to the information likely to be of greater interest to you.

In general, we use cookies on our website for the following purposes:

• Analytical purposes: Analytical cookies enable us to recognize, measure and track visitors of the website. This helps us to improve and develop the functioning of the site, for example by determining whether visitors of the site can easily find information or by identifying those aspects of the site that are of most interest to them.
• User Preferences: Some of the cookies on the website are activated when visitors of our websites make a decision about their use of the website. Our website then remembers the settings of that user. This allows us to tailor aspects of the website to the individual user.
• General terms of use: We use cookies on the website to record whether a site visitor has seen this Privacy Policy or to indicate consent, such as agreeing to certain terms of use on our site. This helps to improve the user-friendliness of the website - e.g. we avoid asking a user repeatedly to agree to the same terms and conditions.
• Session management: The software that operates the website uses cookies for technical purposes that are necessary for the internal functioning of our servers. For example, we use cookies to distribute requests to multiple servers, authenticate users and determine what features of the site are available to them, verify the origin of requests, track information about a user's session, and determine what options or pages need to be displayed to make the site work.
• Functional purposes: Functional purpose-cookies store information needed by our applications to process and operate. For example, if transactions or requests within an application involve multiple workflow steps, cookies are used to temporarily store information from each step to facilitate the completion of the entire transaction or request.
• Advertising: Advertising-cookies enable us (or third parties) to monitor the behaviour of users of our website. This information is used to ensure that products and services which are highlighted to these individuals are targeted and relevant (e.g. by advertising on our website or on third-party websites based on your experience with our website) or to monitor the effectiveness of these digital marketing campaigns. We also monitor whether the ads displayed on our site are of interest to users and store this information to ensure that the ads viewed by users of our site over a longer period of time are appropriate.

We may disclose details of the general use of our website to third parties (e.g. to show business partners usage patterns). Information that we disclose for this purpose does not include any personal data by which you can be identified.
You can set your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so please check the "Help" menu of your browser to learn how to change your cookie settings. You can refuse our cookies at any time if your browser allows it, although in this case you may not be able to use certain features of our website.

On the website, which is designed to be viewed with the Adobe Flash Player, we can include contents such as animations, videos and tools. Local flash memory (often called "flash cookies") can be used to enhance your user experience. Flash memory is stored on your device similar to standard cookies, but is managed directly by your Flash software. If you want to disable or delete information stored locally in flash, please refer to the documentation of your flash software at www.adobe.com. Please note that if you disable flash cookies, some website features may not work.
When you visit our website, you may receive cookies that are set by third parties. The nature of the cookies and the associated data processing by these third parties is governed by the privacy policy of the third party. We have no control over the placement of these third-party cookies. You may wish to browse such third party's website for more information on how they use and manage cookies.

Contact

If you believe that your privacy has been violated, please contact our data protection officer using the contact information below and provide details of the incident for us to investigate. We ask you to submit complaints about suspected privacy violations in writing so that we can remain in contact with you in connection with your complaint.

If you have any questions or concerns regarding the protection of your personal data, please contact our data protection contact person as follows:

phone: +41 44 253 64 13
e-mail: gubler@mivam.ch

If you have contacted us and believe that we have not handled your matter properly, you may contact the competent data protection authority, which is the following in Switzerland:

Swiss Federal Data Protection and Information Commissioner
https://www.edoeb.admin.ch/edoeb/en/home.html

Changes to this privacy policy

We reserve the right to change this privacy policy if we consider it necessary at a later date or if data protection laws require it. Any changes will be posted on the site immediately and you will be deemed to have accepted any subsequent changes to this Privacy Policy when you first use the site.

April 2020