Shaping the future
With conscientious investments

Introduction
This Privacy Notice describes the personal data that Tonic Private Equity (“the Company”) collects through our website located at www.tonic-pe.com and how we use and protect that information. The Company keeps the Privacy Notice under regular review. This version was last updated in January 2022. If you have any questions or comments about this Privacy Notice or our practices regarding your personal data, please contact us via email (info@tonic-pe.com) or by phone (82-2-6001-2400).

Collection of Personal Data
You can browse our website without providing us with any personal data. Personal data means any information about an individual from which that person can be identified.

However, if you voluntarily submit information to our website a request for general information or create an account on our website, we may collect, use, store and transfer (“process”) different kinds of personal data about you, including the following categories of personal data:

Identity Data includes name, title, phone number and e-mail address.
Technical Data includes internet protocol (IP) address, links clicked, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website.
Profile Data includes your username and password, preferences and feedback responses.
Usage Data includes information about how you use our website, including information gathered by cookies or other tracking technologies.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Use and Disclosure of Personal Data
The Company will only use and process the personal data collected where it has a legal basis to do so, and for one or more of the following purposes:

Administering, managing and protecting the Company’s business and this website
Delivering relevant and up-to-date website content to website users
Analyzing how website users use the website
Compliance with any legal, regulatory or contractual obligations to which the Company is subject
Prevention of fraud, detection of crime and ensuring the security of the Company’s business and its investors’ information and assets.

The Company may share your personal data collected through this website with third party service providers (such as IT service providers or data centers) we have retained to perform services on our behalf. These service providers are contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements and are required to put in appropriate security measures to protect the information. In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government agencies and authorities, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

Data Security
The Company has put in place appropriate technical and organizational security measures to prevent accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access of personal information by third parties. The Company’s security measures are continuously improved in line with technological developments. Access to your personal data is strictly limited to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention
The Company will only retain your personal data for as long as reasonably necessary to fulfil the purposes it collected the data for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. The Company may retain your personal data for a longer period in the event of a complaint.

In order to determine the appropriate retention period for personal data, the Company considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which the Company processes your personal data and whether the Company can achieve those purposes through other means, and any applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you have the right to request that your personal data is deleted (further information is set out below).

Your Legal Rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Access – the right to request confirmation of whether the Company processes personal data relating to you and, if so, to request a copy of that personal data
Correction – the right to request that the Company rectify or update your personal data that is inaccurate, incomplete or outdated
Erasure – the right to request that the Company erase your personal data in certain circumstances, such as where the Company collected personal data on the basis of your consent and you withdraw your consent
Restriction of processing – the right to request that the Company restrict the use of your personal data in certain circumstances
Withdraw consent – in the limited circumstances where the Company’s processing of your personal data is based on your consent, the right to withdraw your consent, although withdrawal of consent does not invalidate the consent-based processing that occurred prior to such withdrawal or processing that is not based on consent
Portability – the right to request that the Company provide a machine readable copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances
Object to processing – the right to object to certain processing, such as for direct marketing purposes or where the Company is relying on legitimate interests to which you object based on your particular circumstances.

If you wish to exercise any of the rights set out above, please contact us as detailed in the Introduction section above.

Copyright Notice
All of the content you see on this website, including, for example, all of images, illustrations, graphics, video clips, and text, are subject to trademark, service mark, trade dress, copyright and/or other intellectual property rights or licenses held by Tonic Private Equity (“the Company”). They may therefore not be used without the prior written consent of the Company for purposes other than to identify and present the Company.

The entire content of this website is protected under the copyright law of the relevant countries and international treaty. You may download, print and store selected portions of the content, provided you (i) only use these for your own personal, non-commercial use, (ii) do not copy or post the content on any network computer or broadcast the content in any media, and (iii) do not modify or alter the content in any way, or delete or change any copyright or trademark notice. Any use beyond the provisions outlined above is strictly prohibited.

Disclaimer
While the information on this website is given in good faith based upon the latest available to the Company, no warranty or representation is given concerning such information, which must not be taken as establishing any contractual or other commitment binding upon the Company.

Changes
The Company reserves the right, at its sole discretion, to change, modify, add or remove any portion of this Agreement in whole or in part, at any time. Changes in this Agreement will be effective when notice of such change is posted. Your continued use of the website after any changes to this Agreement are posted will be considered acceptance of those changes.
The Company may terminate, change, suspend or discontinue any aspect of this website, including the availability of any features of the website, at any time. The Company may also impose limits on certain features and services or restrict your access to parts or the entire website without notice or liability.

Linked Websites
As a convenience to you, we may provide, on this website, links to websites operated by other entities. We do not control any of those linked websites, we may not have reviewed them, and we make no representations or warranties and assume no responsibility for anything that may happen through your use of any linked website. You should read carefully the terms of use of any other website that you may use.