LionTree LLC and its affiliates including LionTree Advisors UK LLP, LionTree Advisors France Scs, MediaSlopes LLC and the Kindred App LLC (collectively, “LionTree”) are committed to protecting the information of individuals using the LionTree Platform (defined below) or the Kindred applications (each, “Client”) or individuals who interact with LionTree through a personal connection or from whom information is received directly or indirectly as a result of services provided by LionTree (“Contact”). This LionTree Privacy Policy (the “Privacy Policy”) sets out how we collect, use, and share information we obtain, in connection with your use of the Platform or Kindred or through interactions with, or services provided by, LionTree, that reasonably can be used to identify you as an individual (“Personal Information”).

As used in this Privacy Policy and in addition to other terms defined in this Privacy Policy, the following terms have the indicated meanings:

• “Platform” means the LionTree financial services platform; and
• “Kindred” means the social media mobile application, podcast and any related application, products or other offerings.

(a) Information Collection In connection with the use of the Platform or Kindred or through interaction with LionTree or as a result of services provided by LionTree, we will collect the following information from you and publicly accessible sources, including:

• From Clients: First and last name, address, e-mail address, phone number, passport or other identification information, utility bills or other address verification information, birth date, employment or other engagements, personal and business interests and memberships, remuneration, financial information;
• From Publicly Accessible Sources: Information about you collected pursuant to “Know Your Customer” and Anti-Money Laundering regulations;
• From Clients and Contacts Via In-Person Events or Other Interactions with LionTree Representatives: Lion- Tree may collect first and last name, address, e-mail address, phone number, curriculum vitae, dietary preferences, accommodations, medical information, religion, or employment history, marital and family information; and
• Via Website and App Interactions: IP address, location, and any Personal Information you provide while using Kindred.

(b) Cookies LionTree may use cookies to track user requests on our webpage and in our application to provide a better interactive experience for you. When you visit our website or application for the first time, you may accept or reject cookies. Should you reject cookies our website or application will not remember you or your preferences the next time you visit. (c) Information Processing When you use the Platform or Kindred or interact with LionTree or as a results of services provided by LionTree, we will collect and process information for several different purposes, including:

• To provide services to you via the Platform, Kindred, and at in-person events;
• To keep Clients and Contacts up-to-date regarding new features and services and events offered by LionTree;
• To pursue the legitimate business purposes of LionTree, including providing services and preventing fraud and other misconduct;
• To customize the Client and Contact experience on our Platform, during use of our Kindred, or at in-person events;
• To analyze, review and improve the Platform, Kindred, and interactions with Contacts;
• For internal recordkeeping requirements;
• To comply with any legal and regulatory requirements; and
• To protect and defend our rights and property, including by way of legal proceedings.

Provision of Personal Information is required to use the Platform or Kindred. If you do not provide Personal Information for processing in connection with the purposes listed, you may be prevented from accessing the Platform, Kindred, or in-person events. LionTree will tell you about the implications of your decision to not disclose Personal Information. We may not be able to act for certain Clients and their affiliates if we do not receive personal information about their officers, directors and employees for the purposes of our Know Your Customer checks.

(d) Information Sharing LionTree generally does not sell or otherwise share Personal Information about you with third parties, except to comply with legal or regulatory obligations or as you explicitly consent. We may disclose such information to the following entities:

• Affiliates: We may share your information among LionTree affiliates to provide services to you related to the Platform, Kindred, and in-person events;
• IT Partners: Your information may be disclosed to our IT partners in connection with maintenance of the Platform and Kindred;
• Other Parties When Required by Law or Regulatory Authority: We may be required by statute; court order or other government, law enforcement, or regulatory authorities to disclose information in order to comply with legal process or law; and
• Other Parties Where We Believe Necessary: We may also disclose your information (i) where we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; (ii) in the good faith belief that disclosure is otherwise necessary or advisable; or (iii) where we believe it will help to protect LionTree, its Clients, or any other person or third party, or to enforce any legal rights.

(e) Cross-Border Transfers LionTree may use your Personal Information in countries other than where you are located to fulfill any other purposes outlined in this Privacy Policy. Although the data protection laws in these countries may vary, we will endeavor to ensure that Personal Information will be afforded no less protection due to its transfer. We have executed Model Clauses between our EU and US affiliates and with applicable third parties to effectuate the secure transfer of your Personal Information to third countries.

By agreeing to this Privacy Policy, you expressly consent to the processing of your Personal Information in any jurisdiction, including, without limitation, the United States of America, France, and the United Kingdom in accordance with this Privacy Policy.

(f ) Information Retention We will retain your Personal Information throughout your relationship with LionTree as a Client or Contact and up to 10 years after the end of the Client or Contact relationship unless a different timeline for retention and destruction is required by applicable law.

LionTree maintains an information security policy that, taking into account the nature of the data processed and in accordance with a risk-based approach, includes technical and organizational measures to protect the security, confidentiality and integrity of Personal Information.

LionTree may update this Privacy Policy from time to time as it deems necessary in its sole discretion. If there are material changes to this Privacy Policy, we will provide notice where and in the manner required by applicable law, including but not limited to, by email, through Kindred, at www.liontree.com or other relevant website. Your continued use of the Platform or Kindred or interaction with LionTree after notice of any amended Privacy Policy shall constitute your agreement to be bound by such changes. Any changes to this Privacy Policy take effect immediately after being notified by LionTree.

(a) Applicability of EU Data Protection Laws LionTree is a global brand and thus may conduct business with individuals from within the European Economic Area (“EEA”). In order to carry out business with these individuals, we may transfer personal information from individuals (“Data Subjects”) located within the EEA. Personal information may be collected by us from a Data Subject in the EEA on the Platform, via Kindred, and through direct or indirect interactions.

(b) Lawful Grounds to Process and Obtain Consent Data subjects whose personal information is processed in the EEA based on their consent (i.e. when using Kindred or when agreeing to receive our newsletter or marketing communications) may withdraw consent at any time where consent is the lawful basis for processing his/her information. Should a data subject withdraw consent for processing or otherwise object to processing that impedes LionTree’s ability to comply with applicable regulations, a data subject may be unable to avail him/herself of the services that LionTree provides. The decision to withdraw consent will not affect the lawfulness of processing based on consent before its withdrawal. (c) Data Subjects’ Rights All individuals whose personal information is held by LionTree have the right to:

• ask what information LionTree holds about them and why;
• ask for a copy of such information or access to such information;
• be informed how to correct or keep that information up to date; and
• be informed on how LionTree is meeting its data protection obligations.

Furthermore, for data collected in the EEA, data subjects have the right to:

• ask for a copy of such information to be sent to a third party;
• ask for data to be erased if possible and required under the General Data Protection Regulation (“GDPR”);
• ask for processing of personal information to be restricted if possible and required under GDPR;
• object to processing of personal information if possible and required under GDPR;
• object to automated decision-making where applicable; and
• contact a supervisory authority in the EEA to lodge a complaint regarding LionTree’s processing of your personal information.

(d) Automated Decision-making LionTree does not engage in automated decision-making.

(e) LionTree Contact Information for Persons Located Within the EEA If you are located in the EEA or Switzerland and have questions or concerns regarding the processing of your personal information, you may contact Data Protection Officer, at: LT-EuropeLegal@liontree.com; or write to us at: LionTree International Limited, 3 Burlington Garden W1S 3EP. If, as an EEA Citizen, you believe that LionTree has not adequately resolved any such issues, you have the right contact the EU supervisory authority.


Last updated: 24 May 2018