Investor Privacy Notice

Auberon & Co Cayman SPC - Three Body Fund SP
Auberon & Co Cayman (INTL) SPC - Three Body Fund (INTL) SP

 

Each of Auberon & Co Cayman SPC - Three Body Fund SP and Auberon & Co Cayman (INTL) SPC - Three Body Fund (INTL) SP (each a “Fund”) values your privacy and is committed to protecting your personal data in accordance with the Cayman Islands Data Protection Act (2021 Revision) (“DPA”) and applicable regulatory guidance issued by the Cayman Islands Monetary Authority (“CIMA”). This Privacy Notice explains how the Fund, as a data controller, collects, uses, discloses, and safeguards personal data relating to its investors and prospective investors.

1. Data Controller

The Fund, acting through its board of directors, is the data controller of your personal data. The Fund may also delegate certain processing functions to its service providers, who act as data processors for these purposes.

2. Personal Data Collected

The Fund may collect, process, and store the following categories of personal data:

  • Identification information (e.g., name, date of birth, nationality, passport or other identification numbers);

  • Contact details (e.g., residential address, email address, telephone number);

  • Financial information (e.g., bank account details, source of wealth, source of funds, tax identification numbers);

  • Transactional details relating to subscription, redemption, distribution, and holding of Fund interests;

  • Information provided for anti‑money laundering (“AML”), know‑your‑customer (“KYC”), and regulatory compliance purposes.

3. Purposes of Processing

Personal data may be processed for the following purposes:

  • Establishing, managing, and administering investor relationships with the Fund;

  • Processing applications for investment and subsequent transactions;

  • Meeting legal, regulatory, and tax obligations under Cayman Islands, international, or other applicable laws;

  • Preventing fraud, money laundering, and terrorist financing;

  • Communicating with investors about Fund operations, performance, and governance;

  • Maintaining Fund records and complying with regulatory reporting obligations.

4. Legal Basis for Processing

Processing of personal data by the Fund is carried out under one or more of the following legal bases:

  • The processing is necessary for the performance of a contract with you;

  • The processing is required for compliance with applicable legal or regulatory obligations;

  • The processing is necessary for the purposes of legitimate interests pursued by the Fund or its service providers, provided such interests are not overridden by your data protection rights.

5. Data Disclosure and Transfers

Personal data may be shared with:

  • The Fund’s administrator, manager, investment advisor, auditors, legal counsel, and other professional service providers;

  • Regulatory authorities, tax authorities, law enforcement agencies, or courts as required by applicable law or regulation;

  • Affiliates of the Fund and third‑party service providers who support Fund operations.

Personal data may be transferred outside the Cayman Islands, including to jurisdictions which may not have equivalent data protection laws. In such cases, the Fund will ensure that appropriate data protection safeguards are in place.

6. Data Retention

Personal data will be retained for as long as necessary to fulfil the purposes for which it was collected, and to comply with applicable legal, regulatory, and recordkeeping requirements.

7. Data Subject Rights

Under the DPA, you have the following rights (subject to applicable limitations):

  • To access your personal data;

  • To request correction of inaccurate or incomplete data;

  • To request deletion where data is no longer required for lawful purposes;

  • To object to or restrict certain forms of processing;

  • To receive a copy of your data in a portable form, where feasible.

Requests to exercise these rights should be submitted in writing to the Fund at the contact address listed below.

8. Data Security

The Fund and its service providers maintain appropriate technical and organisational security measures designed to protect your personal data against unauthorised or unlawful processing, accidental loss, destruction, or damage.

9. Contact Information

For questions about this Privacy Notice or to exercise your data protection rights, please contact:

Data Protection Officer
Eugene Lim
Auberon & Co Cayman SPC - Three Body Fund SP
Auberon & Co Cayman (INTL) SPC - Three Body Fund (INTL) SP
94 Solaris Avenue, 2nd Floor, Camana Bay, Grand Cayman, Cayman Islands, KY1-1203
Email: eugene@threebody.capital

10. Updates to this Notice

The Fund may amend this Privacy Notice from time to time to reflect updates in legislation, best practices, or Fund operations. The latest version of this Privacy Notice will be made available upon request.