Alliance Trust Company of Nevada, LLC. (hereinafter referred to as “Alliance”) provides a variety of investment management and trust services to clients who have contracted for these services. As a result, Alliance is required to communicate its policies related to the privacy of customer information. We are proud of our privacy protection practices and procedures, and we want you to know how we protect your information and use this information to service your account.

Please take a moment to review our privacy policy as described below:

●In order to facilitate the servicing of your account, Alliance may receive nonpublic personal information about you from the following sources:

●Information we receive from you on questionnaires, applications, account opening documents, or other forms;

●Information about your transactions with us or others;

●Information we receive from a consumer reporting agency; and

●Information we receive from other sources with your consent.

We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. Such permitted disclosure may include the following:

●Disclosures to aﬃliates, including aﬃliated service providers (for example, third party custodians);

●Disclosures to your chosen broker-dealer ﬁrm (for example, to establish a brokerage account on your behalf);

●Disclosures to government agencies, securities regulators and law enforcement oﬃcials (for example, for tax reporting, under a court order, or to protect our legal rights);

●Disclosures to other organizations, with your consent (for example, investment advisor ﬁrms in order to open a managed account with their ﬁrm ); and

●Disclosures to other persons you authorize to obtain such information (for example, a CPA who be preparing your tax return).

Alliance restricts access to your personal and account information to those of its employees who need to know that information to provide products or services to you. Alliance maintains physical, electronic, and procedural safeguards to guard your nonpublic personal information. As required by applicable law, we will continue to adhere to the privacy policies and practices as described in this notice if you decide to close your account(s) or become an inactive customer.

Use of Generative Artificial Intelligence

In the course of providing investment management and trust services, Alliance may from time to time make use of generative artificial intelligence tools to assist with our operations and the services described in this Policy. Where such tools are used in connection with the processing of Personal Data, that processing is subject to the same safeguards described elsewhere in this Policy.

Where generative artificial intelligence tools are provided by third parties, those third parties are engaged on the basis described under the permitted-disclosure provisions of Part 1 and, where applicable, under the international-transfer provisions of the supplemental notices that accompany this Policy. We contractually require that any Personal Data processed through such tools is not used to train any underlying model and is subject to the same confidentiality, retention, and security obligations that apply to our other service providers.

The rights you have under this Policy and any applicable supplemental notice apply equally to Personal Data processed with the assistance of generative artificial intelligence tools. To exercise those rights, please contact us at privacy@alliancetrustcompany.com.

Part 2: Supplemental U.S. State Policies

Supplemental Privacy Notice for Residents of U.S. States with Comprehensive Privacy Laws

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

This Supplemental Privacy Notice is intended to be read in conjunction with our global Privacy Policy https://alliancetrustcompany.com/privacy-policy/ (the “Policy”). The deﬁnitions found in the Policy apply to this Supplemental Privacy Notice.

This Supplemental Privacy Policy and Notice (“Supplemental Policy”) describes the practices of Alliance Trust Company of Nevada (“Alliance”) (“Alliance,” “we,” “us,” or “our”) regarding the collection, use, and disclosure of personal information and provides instructions for submitting data subject requests. This Supplemental Policy applies only to information collected about Customers residing in California, Colorado, Virginia, Utah, Connecticut, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Jersey, Tennessee, Minnesota, Maryland, Indiana, or Kentucky (“customer(s),” “Customer(s),” “you,” “your”) and supplements the information contained in Alliance’s Privacy Policy.

It provides information required under the California Consumer Privacy Act of 2018 and as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), the Colorado Privacy Act of 2021 (the “CPA”), the Virginia Consumer Data Protection Act of 2021 (the “VCDPA”), the Utah Consumer Privacy Act of 2022 (the “UCPA”), and the Connecticut Data Privacy Act of 2022 (“CDPA”) and all other applicable state comprehensive privacy laws and any and all regulations arising therefrom. Some portions of this Supplemental Policy apply only to Customers of particular states, and we have indicated where those portions are state-speciﬁc.

If you are unable to review or access this Supplemental Policy due to a disability, you may contact Alliance at privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134 to access this Supplemental Policy in an alternative format.

Deﬁnitions Speciﬁc to this Supplemental Policy

●“Customer” means a natural person who resides in California, Colorado, Virginia, Utah, Connecticut, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Jersey, Tennessee, Minnesota, Maryland, Indiana, or Kentucky and to whom we oﬀer information, goods, or services. For purposes of this Supplemental Policy, this term includes natural persons who reside in California and engage with us as part of business-to-business transactions.

●“Personal Information” means information that identiﬁes, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Customer or household. Personal Information includes “personal data” as that term is deﬁned in the CPA, VCDPA, UCPA, and CDPA. Personal Information also includes “Sensitive Personal Information,” as deﬁned below.

●“Sensitive Personal Information” means Personal Information that reveals a Customer’s: 1) Social Security Number, driver’s license, state identiﬁcation card, or passport number; 2) account log-in, ﬁnancial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to the individual’s account; 3) precise geolocation; 4) racial or ethnic origin; 5) religious beliefs; 6) union membership; 7) contents of email or text messages, unless we are the intended recipient; 8) genetic data; 9) biometric information used to uniquely identify the Customer, and 10) health, sex life, or sexual orientation. Sensitive Personal Information includes “sensitive data” as that term is deﬁned in the CPA, VCDPA, UCPA, and CDPA.

●“Sell,” “Sale,” or “Sold” means renting, releasing, or transferring an individual’s Personal Information to a Third Party for money or other valuable consideration.

●“Share,” “Shared,” or “Sharing” means transferring an individual’s Personal Information to a Third Party for behavioral advertising purposes, whether or not for money or other valuable consideration.

●“Third Party” means a person or organization which is not a Customer, Vendor, or an entity owned or controlled by us and as deﬁned by the CCPA, CPA, VCDPA, UCPA, and CDPA.

●“Vendor” means a “service provider,” “contractor,” or “processor” which collects, stores, or otherwise handles data for us, as those terms are deﬁned in the CCPA, CPA, VCDPA, UCPA, and CDPA.

These deﬁnitions apply, whether terms are capitalized or not. Other terms used in this Supplemental Policy may be deﬁned under the CCPA, CPA, VCDPA, UCPA, or CDPA, and they have the meanings described in those statutes. If there are variations between such deﬁnitions in diﬀerent laws, you will be covered by the deﬁnition that applies in your state. For example, if you are a Virginia Customer, terms deﬁned in the VCDPA shall apply to you if they are used in this Supplemental Policy.

The Personal Information We Collect and Disclose

The chart below shows the categories of personal information we may collect; examples of personal information in each category; types of sources from which each category of personal information is collected; the business purposes for which each category of personal information is collected; and the types of Vendors or Third Parties with whom that category of personal information is shared. As this chart shows, we do not share or sell personal information to Third Parties or disclose certain personal information to Vendors outside of business purposes.

CATEGORY OF PERSONAL INFORMATION	EXAMPLES	SOURCES FROM WHICH THIS PERSONAL INFORMATION IS COLLECTED	BUSINESS PURPOSES FOR COLLECTION	TYPES OF VENDORS OR THIRD PARTIES WITH WHOM THIS PERSONAL INFORMATION IS SHARED, SOLD OR DISCLOSED
Unique Identiﬁers	Real name, signature, alias, address, unique personal identiﬁer, online identiﬁer, IP address, email address, account name, taxpayer identification number, government issued identification	Directly from you via our website Direct communication with you Social media interaction with you Marketing agencies	Provide you with goods and services Managing your preferences Customer service communications Other Promotions	Disclosed: Web site hosters Event planners Credit check ﬁrms Shared or Sold: None
Contact and Financial Information	Name, address, telephone, email, credit card number, debit card number, or any other ﬁnancial information	Directly from you via our website Claims management providers	Complete transactions Other services and discounts Process claims Prevent fraud	Disclosed:- Payment processors Mailing houses Lenders Shared or Sold: None
Characteristics of Protected Classiﬁcations	Age, marital status	Directly from you via our website or sign-up	Comply with legal requirements Ensure eligibility for services (e.g. over 18) Accommodate special needs	Disclosed: Service coordinators Contractors Shared or Sold: None

Sensitive Personal Information We Collect and Disclose

CATEGORY OF SENSITIVE PERSONAL INFORMATION

SOURCES FROM WHICH THIS SENSITIVE PERSONAL INFORMATION IS COLLECTED

BUSINESS PURPOSES FOR COLLECTION

TYPES OF VENDORS OR THIRD PARTIES WITH WHOM THIS SENSITIVE PERSONAL INFORMATION IS SHARED, SOLD OR DISCLOSED

Account log-in, ﬁnancial account, debit card number, plus an access code

Directly from you via our website

Complete transactions

Oﬀer services and

discounts

Prevent fraud

Disclosed: Web hoster

Payment processor Service Providers Shared or Sold:

None

Racial or Ethnic Origin, Religious Beliefs

Directly from you via our website

Comply with legal requirements

Accommodate special needs (e.g. religious dietary

restrictions)

Shared or Sold: None

Retention of Data

We intend to retain each category of personal information described above only for as long as necessary to fulﬁll the purpose for which it was collected, or a related and compatible purpose consistent with the average Customer’s expectation, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.

Your Rights to Your Personal Information

Customers have certain rights with respect to the collection and use of their personal information. Those rights vary by state. As required by the CCPA, we provide detailed information below regarding the data subject rights available to California Customers. Customers in applicable U.S. states have similar rights and can find more detail by referencing their respective state’s comprehensive privacy statutes, such as the CPA (Colorado), VCDPA (Virginia), UCPA (Utah), CDPA (Connecticut), TDPSA (Texas), OCPA (Oregon), or the equivalent enacted consumer privacy framework in their state of residence.

You have the right to submit requests related to the personal information we have collected about you. You may make such a request twice in a 12-month span. Please note, there are circumstances when we may not be able to comply with your request. For example, we may not be able to verify your request, or we may ﬁnd that providing a full response conﬂicts with other legal obligations or regulatory requirements. We will notify you if this is the case.

Right to Receive Information on Privacy Practices

You have the right to receive the following information at or before the point of collection:

●The categories of personal information to be collected;

●The purposes for which the categories of personal information are collected or used;

●Whether or not that personal information is sold or shared with Third Parties or disclosed to Vendors;

●If the business collects Sensitive Personal Information, the categories of Sensitive Personal Information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and

●The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Supplemental Policy, and you may request further information about our privacy practices by using the contact information provided below.

Right to Know and Right to Access

You have the right to request certain information we have collected about you. You have the right to request:

●Speciﬁc pieces and categories of personal information we collected about you;

●The categories of sources from which personal information was collected;

●The purposes for which personal information was collected, shared, sold, or processed;

●The categories of personal information we shared, sold or disclosed; and

●The categories of Vendors or Third Parties with whom we shared, sold or disclosed personal information.

If you would like to make a request to know or to access your personal information, you can use the email address privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134.

Right to Delete

You have the right to request that we delete certain personal information that we have collected. If you would like to make a request to delete your personal information, you can use the email address privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134.

Right to Correct

You have a right to request that we correct any inaccurate personal information we may retain about you. If you would like to make a request to correct your personal information, you can use the email address privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134.

Right to Opt-Out of the Sale and Sharing of Your Personal Information

You have the right to opt-out of the sale and sharing of your personal information with Third Parties, and the right to opt out of the processing of personal information for targeted advertising purposes, as deﬁned in the CCPA, CPA, VCDPA, UCPA, OCPA, and CDPA. (Alliance does not sell your personal information, but you are still permitted to request that your Personal Information never be sold.)

Right to Consent to or Limit the Use of Your Sensitive Personal Information

In applicable states, you have the right to consent to the use of your Sensitive Personal information. Separately, you have the right in CA to instruct us to limit the use and disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods reasonably expected by an average Customer or for speciﬁc business purposes deﬁned by law. However, we do not use Sensitive Personal Information for purposes beyond those authorized by the CCPA, or beyond your consent.

Right to Non-Discrimination

You have a right to exercise the above rights, and we will not discriminate against you for exercising these rights. Please note that a legitimate denial of a request to access, delete, or opt-out is not discriminatory, nor is charging a fee for excessive or repetitive requests.

Right to Opt-Out of Automated Profiling and Decision-Making

To the extent provided by applicable state law, you have the right to opt-out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, such as financial, banking, or fiduciary evaluations. If you wish to exercise this right, please contact us at privacy@alliancetrustcompany.com.

Instructions to Exercise your Rights

If you would like to make any of the data requests listed above, please use the email address privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134. If you use the telephone number, you will be guided through a process that will allow you to submit a veriﬁable request, and the level of veriﬁcation will depend on the request being submitted. If you use the email address, we may email you to request additional information from you to verify your request.

You may designate an authorized agent to exercise your rights under the CCPA on your behalf. Such an individual must have power of attorney, or be an authorized agent registered with the relevant Secretary of State.

Right to Appeal

You have the right to appeal our decisions about your data subject requests. If you choose to appeal, your request will move from Operations to our Legal Department for review. If you would like to appeal a decision regarding your data request, please use the email address privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134. Please state that your request is an “Appeal,” and describe the date and nature of your original request.

Veriﬁcation Process

When you submit a request to exercise your data subject rights, we may ask you to provide information that will enable us to verify your identity.

If you designate an authorized agent to exercise your rights on your behalf, we may require that you or the authorized agent do the following:

●Verify your identity with us directly.

●Provide proof of your signed written permission for the authorized agent to submit a request on your behalf.

We may deny a request from an agent purportedly acting on your behalf if we request, and the agent does not submit, proof that he, she, or it has been authorized by you to act on your behalf.

Personal Information of Minors

Our online content is not intended for children or minors under the age of sixteen years. Accordingly, we do not knowingly store information from minors under the age of sixteen years, except as required by applicable law. If you believe that a child has submitted personal information to us, please contact us at privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134, and we will delete the information.

Additional California Privacy Rights

Shine the Light Request

California Civil Code Section § 1798.83 permits users of our website who are California residents to request information about our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to privacy@alliancetrustcompany.com with the subject “Shine the Light Request.”

Changes to Our Supplemental Policy

Alliance reserves the right to amend this Supplemental Policy at our discretion and at any time. When we make changes to this Supplemental Policy, we will post an updated policy on our website with a new Last Revised date.

Additional Information

If you would like additional information regarding our Supplemental Policy, please contact us at privacy@alliancetrustcompany.com , 1-775-384-0806, extension 134, or

Alliance Trust Company of Nevada

50 West Liberty St., Suite 500

Reno, Nevada 89501

Attn: Privacy Department

Part 3: Supplemental Countries

Supplemental Privacy Notice for the Philippines

Original Effective Date: 6/20/2024

If you are located in the Philippines in accordance with Republic Act. No. 10173, otherwise known as the Data Privacy Act 2012 (the “Act”), this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Alliance Trust Company of Nevada (“Alliance,” “we” and/or “us”) is the data controller for the purposes of Personal Data processed through this Website. If you have questions about this Policy or your rights, please contact us as indicated at privacy@alliancetrustcompany.com .

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in the Philippines for the reasons set forth below. The lawful basis for each purpose may be diﬀerent. Please contact us at privacy@alliancetrustcompany.com if you would like to know the speciﬁc legal basis which applies in connection with a particular processing operation.

In general, the lawful bases that we rely on are the following:

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

●Legitimate interests – This means our interest in conducting and managing our organization to enable us to provide you with the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Our legitimate interests include, but are in not limited to:

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

●Consent – In accordance with applicable law, we may seek your consent or explicit consent to process Personal Data collected on this Website or volunteered by you. For example, in relation to our marketing and promotional activities.

●Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International Transfers of Personal Data Outside of the Philippines

The processing of all Personal Data by us through this Website will take place in the United States. Visitors to this Website acknowledge that Personal Data provided or collected through this Website will be transferred to the United States.

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors speciﬁcally to assist with our ﬁrm’s activities. Any such third parties whom we engage will be bound contractually to keep all information conﬁdential.

We may transfer your Personal Data outside the Philippines relying on appropriate or suitable safeguards or speciﬁc derogations recognized under applicable data protection law, including Section 21 of the Act.

All Personal Data transferred by us is subject to a cross-border arrangement and cooperation.

Rights of Data Subjects

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of the rights set out below or learn more about such rights, please contact us at privacy@alliancetrustcompany.com .

●Access your Personal Data;

●Correct or update any of your Personal Data that is inaccurate;

●Restrict or limit the ways in which we use your Personal Data;

●Object to the processing of your Personal Data;

●Request the deletion of your Personal Data; and

●Obtain a copy of your Personal Data in an easily accessible format.

In addition, where we rely on consent to process your Personal Data, you have the right to withdraw consent at any time. However, this will not aﬀect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority. However, we would appreciate the opportunity to address any concern you have so please contact us at privacy@alliancetrustcompany.com .

Data Retention

We will retain your Personal Data for as long as is necessary for the purposes listed in this Policy unless a longer period is required under applicable law, or a longer period is needed to resolve disputes or protect our legal rights or otherwise comply with legal obligations.

When assessing the data retention period, we take into account the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Failure to Provide Personal Data

Where we need to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service or order you have with us, but we will notify you if this is the case at the time.

Supplemental Privacy Notice for Argentina and Brazil

Original Effective Date: 6/20/2024

If you are located in Argentina or Brazil, pursuant to Argentina’s Personal Data Protection Act No 25,326 (“PDPA”) or Article 3 of the Brazilian General Data Protection Law (“Law No. 13,709/2018” or “LGPD”), this section of the Policy (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you. Alliance Trust Company of Nevada (“Alliance,” “we” and/or “us”) is the data controller for the purposes of Personal Data processed through this Website. If you have questions about the Policy or your rights, please contact us at privacy@alliancetrustcompany.com.

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in Argentina or Brazil for the purposes set forth below. Where more than one purpose is listed, please contact us if you would like to know the speciﬁc legal basis, which applies in connection with your speciﬁc enquiry.

We have provided further information on the legal bases we generally rely on below:

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

●Legitimate interests – This means our general interest in conducting and managing our organization to enable us to provide you with the best products and give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Our speciﬁc legitimate interests include, but are not limited to:

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Rights of Data Subjects

The PDPA and LGPD provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to beneﬁt from the mentioned rights.

We will respond and/or fulﬁll your requests for the exercise of your rights below, according to the applicable law and when applicable, to the PDPA or LGPD, and ensure that the third parties that also process your personal data will also comply with your requests, including the following:

1.conﬁrmation of whether your data are being processed;

2.access to your data;

3.correction of incomplete, inaccurate or outdated data;

4.anonymization, blocking or erasure of data that is unnecessary, excessive or not processed according to the PDPA or LGPD’s provisions;

5.erasure of data processed based on the consent of the data subject;

6.portability of personal data to a third party;

7.object to the processing of personal data, in case of violation of the law;

8.information of public and private entities with which we shared data;

9.information about the possibility to refuse providing consent to a personal data processing activity and the respective consequences, when applicable; and

10.withdrawal of your consent.

Right to Review of Algorithmic Decisions (Brazil)

In accordance with Article 20 of the Brazilian General Data Protection Law (LGPD), residents of Brazil have the right to request a review of decisions carried out solely on the basis of automated processing of personal data, including profiling, designed to analyze personal, professional, consumer, credit, or fiduciary aspects of your identity.

Limitations to Your Rights

In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights, or when such disclosure is impossible or requires a disproportionate eﬀort. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulﬁll your request.

DPO

If you wish to reach the Company’s Data Protection Oﬃcer, contact us at: privacy@alliancetrustcompany.com .

Access Logs

We keep your access logs, under conﬁdentiality, in a controlled and safe environment, for, at least, 12 months, in order to comply with legal obligations.

International Data Transfer of Personal Data

When we transfer your Personal Data across Brazilian national borders to third parties, we will ensure that this international transfer occurs in compliance with the PDPA or LGPD’s provisions.

In order to comply with the PDPA or LGPD’s provisions regarding international data transfer, we may request the Data Subject’s express and speciﬁc consent to the international data transfer.

Supplemental Privacy Notice for South Africa

Original Effective Date: 6/20/2024

If you are located in South Africa, pursuant to the Protection of Personal Information Act (“POPIA”), this section of the Policy (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Alliance Trust Company of Nevada (“Alliance,” “we” and/or “us”) is the data controller for the purposes of Personal Data processed through this Website. If you have questions about the Policy or your rights, please contact us at privacy@alliancetrustcompany.com.

The Information We Collect

We collect and process your personal information mainly to contact you for the purposes of understanding your requirements and delivering services accordingly. For this purpose, we will collect contact details including your name and organization.

We collect information directly from you where you provide us with your personal details. Where possible, we will inform you what information you are required to provide to us and what information is optional.

Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

How We Use Your Information

We will use your personal information only for the purposes for which it was collected and agreed with you. In addition, where necessary your information may be retained for legal or research purposes.

For example:

●To gather contact information;

●To conﬁrm and verify your identity or to verify that you are an authorized user for security purposes;

●For the detection and prevention of fraud, crime, money laundering or other malpractice;

●To conduct market or customer satisfaction research or for statistical analysis;

●For audit and record keeping purposes; and/or

●In connection with legal proceedings.

Disclosure of Information

We may disclose your personal information to our service providers who are involved in the delivery of services to you. We have agreements in place to ensure that they comply with the privacy requirements as required by POPIA.

We may also disclose your information:

●Where we have a duty or a right to disclose in terms of law or industry codes; and/or

●Where we believe it is necessary to protect our rights.

Information Security

We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We will, on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure.

Our security policies and procedures cover:

●Physical security;

●Computer and network security;

●Access to personal information;

●Secure communications;

●Security in contracting out activities or functions;

●Retention and disposal of information;

●Acceptable usage of personal information;

●Governance and regulatory issues;

●Monitoring access and usage of private information; and

●Investigating and reacting to security incidents.

When we contract with third parties, we impose appropriate security, privacy and conﬁdentiality obligations on them to ensure that personal information that we remain responsible for is kept secure.

We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

Your Rights: Access to Information

You have the right to request a copy of the personal information we hold about you. To do this, simply contact us at the numbers/addresses as provided on our website and specify what information you require. We will need a copy of your ID document to conﬁrm your identity before providing details of your personal information.

Please note that any such access request may be subject to a payment of a legally allowable fee.

Correction of Your Information

You have the right to ask us to update, correct or delete your personal information. We will require a copy of your ID document to conﬁrm your identity before making changes to personal information we may hold about you. We would appreciate it if you would keep your personal information accurate.

Deﬁnition of Personal Information

According to POPIA, ’’personal information’’ means information relating to an identiﬁable, living, natural person, and where it is applicable, an identiﬁable, existing juristic person. Further to POPIA, Alliance also includes the following items as personal information:

●All addresses including residential, postal and email addresses.

●Change of name – for which we require copies of the marriage certiﬁcate or oﬃcial change of name document issued by the state department.

How to Contact Us

If you have any queries about this notice; you need further information about our privacy practices; wish to withdraw consent; exercise preferences or access or correct your personal information, please contact us at privacy@alliancetrustcompany.com.

Supplemental Privacy Notice for Singapore

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in Singapore, pursuant to the Personal Data Protection Act 2012, as amended in 2020, (“PDPA”), this section of the Policy (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Alliance Trust Company of Nevada (“Alliance,” “we” and/or “us”) is the data controller for the purposes of Personal Data processed through this Website. If you have questions about the Policy or your rights, please contact us at privacy@alliancetrustcompany.com.

Summary

We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notiﬁed. We may also collect, use or disclose personal data if it is required or authorized under applicable laws.

Collection of Personal Data

We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms ﬁlled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.

We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information.

We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorized representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third-party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.

Use of Personal Data

We use personal data for the following purposes:

●to provide our services;

●to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection);

●to maintain contact with clients and other contacts;

●to keep clients and other contacts informed of the services we oﬀer, industry developments, service oﬀerings, seminars and other events we are holding, that may be of interest to them;

●for general management and reporting purposes, such as invoicing and account management;

●for recruitment purposes;

●for purposes related to the employment of our personnel and providing internal services to our personnel; and/or

●all other purposes related to our business.

Any individual may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by contacting us at privacy@alliancetrustcompany.com . Such requests will be processed within 28 days.

Disclosure of Personal Data to Third Parties

We may transfer all data in our possession to a successor-in-interest to our business or assets.

Access to and Correction of Personal Data

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We may charge for a request for access in accordance with the requirements of the PDPA.

Withdrawal of Consent

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorized under applicable laws.

Accuracy of Personal Data

We will make a reasonable eﬀort to ensure that personal data collected by us or on our behalf is accurate and complete.

Security and Protection of Personal Data

We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorized access, collection, use, disclosure, copying, modiﬁcation, disposal or similar risks. All Alliance personnel follow a network-wide security policy. Only authorized Alliance personnel are provided access to personally identiﬁable information and these personnel have agreed to ensure conﬁdentiality of this information. Alliance’s policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulﬁlment agents of Alliance.

Retention of Personal Data

We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

Transfer of Personal Data Outside of Singapore

We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

Privacy on Our Websites

This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text ﬁles placed on your hard drive that assist us in providing a more customized website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.

Because we want visitors’ website experience to be as informative and resourceful as possible, we may provide a number of links to third party websites. We assume no responsibility for the information practices of these third party websites that visitors are able to access through ours. When a visitor to our website links to these third party websites, our privacy practices no longer apply. We encourage visitors to review each website’s privacy policy before disclosing any data.

Data Protection Oﬃcer

If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Oﬃcer at privacy@alliancetrustcompany.com .

Modiﬁcations

We reserve the right to modify or amend this Policy at any time. The eﬀective date will be displayed at the beginning of this Policy. To keep you informed, we will notify changes to this Policy by prominently identifying the alteration for a period of not less than two weeks on our home page at www.alliancetrustcompany.com .

Supplemental Privacy Notice for Belize

Original Effective Date: 6/20/2024

If you are located in Belize, pursuant to the Data Protection Act (the “Act”), this section of the Policy (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Alliance Trust Company of Nevada (“Alliance,” “we” and/or “us”) is the data controller for the purposes of Personal Data processed through this Website. If you have questions about the Policy or your rights, please contact us at privacy@alliancetrustcompany.com.

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in Belize for the purposes set out below. Where more than one purpose is listed, please contact us at privacy@alliancetrustcompany.com , if you would like to know the speciﬁc legal basis which applies in connection with your speciﬁc enquiry.

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

●Legitimate interests – This means our general interest in conducting and managing our organization to enable us to give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Our speciﬁc legitimate interests include, but are not limited to:

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

●Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International Transfers of Personal Data Outside of Belize

We may transfer your Personal Data outside Belize where the transfer is (a) to a country or territory deemed to provide an adequate level of protection by a relevant government authority (e.g. the Belize government), (b) pursuant to standard contractual clauses approved by a relevant government authority, or (c) in exceptional cases only, under a speciﬁc derogation recognized under applicable data protection law, including the Act.

Please contact us at privacy@alliancetrustcompany.com, if you would like further information.

Rights of Data Subjects

●Access your Personal Data;

●Correct or update any of your Personal Data that is inaccurate;

●Restrict or limit the ways in which we use your Personal Data;

●Object to the processing of your Personal Data;

●Request the deletion of your Personal Data; and

●Obtain a copy of your Personal Data in an easily accessible format.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may extend the timeframe by up to two further months but we will notify you and keep you updated if this is the case.

Failure to Provide Personal Data

Supplemental Privacy Notice for Turkey, Jordan and United Arab Emirates

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in Turkey, Jordan, or the United Arab Emirates (UAE), pursuant to the Turkey Law on Protection of Personal Data No. 6698, as amended in 2024 (‘DPL’), the Jordan Personal Data Protection Law (“JPDPL”) or the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data(the “PDPL”), this section of the Policy (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Alliance Trust Company of Nevada (“Alliance,” “we” and/or “us”) is the data controller for the purposes of Personal Data processed through this Website. If you have questions about the Policy or your rights, please contact us at privacy@alliancetrustcompany.com.

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in Turkey, Jordan or the UAE for the purposes set out below. Where more than one purpose is listed, please contact us at privacy@alliancetrustcompany.com , if you would like to know the speciﬁc legal basis which applies in connection with your speciﬁc enquiry.

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

●Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International Transfers of Personal Data Outside of Turkey, Jordan or the UAE

We may transfer your Personal Data outside Turkey, Jordan or the UAE where the transfer is (a) to a country or territory deemed to provide an adequate level of protection by a relevant government authority, (b) pursuant to standard contractual clauses approved by a relevant government authority, or (c) in exceptional cases only, under a speciﬁc derogation recognized under applicable data protection law.

Please contact us at privacy@alliancetrustcompany.com, if you would like further information.

Rights of Data Subjects

●Access your Personal Data;

●Correct or update any of your Personal Data that is inaccurate;

●Restrict or limit the ways in which we use your Personal Data;

●Object to the processing of your Personal Data;

●Request the deletion of your Personal Data; and

●Obtain a copy of your Personal Data in an easily accessible format.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may extend the timeframe by up to two further months but we will notify you and keep you updated if this is the case.

Failure to Provide Personal Data

Supplemental Privacy Notice for Israel

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in Israel, pursuant to the Protection of Privacy Law, 5741-1981, as amended by Amendment No. 13 (2024, effective August 2025), and regulations promulgated under it (the “PPL”), this section of the Policy (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Alliance Trust Company of Nevada (“Alliance,” “we” and/or “us”) is the data controller for the purposes of Personal Data processed through this Website. If you have questions about the Policy or your rights, please contact us at privacy@alliancetrustcompany.com.

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in Israel for the purposes set out below. Where more than one purpose is listed, please contact us at privacy@alliancetrustcompany.com , if you would like to know the speciﬁc legal basis which applies in connection with your speciﬁc enquiry.

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

●Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International Transfers of Personal Data Outside of Israel

We may transfer your Personal Data outside Israel where the transfer is (a) to a country or territory deemed to provide an adequate level of protection by a relevant government authority, (b) pursuant to standard contractual clauses approved by a relevant government authority, or (c) in exceptional cases only, under a speciﬁc derogation recognized under applicable data protection law.

Please contact us at privacy@alliancetrustcompany.com, if you would like further information.

Rights of Data Subjects

●Access your Personal Data;

●Correct or update any of your Personal Data that is inaccurate;

●Restrict or limit the ways in which we use your Personal Data;

●Object to the processing of your Personal Data;

●Request the deletion of your Personal Data; and

●Obtain a copy of your Personal Data in an easily accessible format.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may extend the timeframe by up to two further months but we will notify you and keep you updated if this is the case.

Failure to Provide Personal Data

Supplemental Privacy Notice for India

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in India in accordance with Digital Personal Data Protection Act (the “DPDPA”), the rules under which are being phased through May 17, 2027 and during which transition the Information Technology Act, 2000 and the SPDI Rules, 2011 remain partially in force,

this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

The Information We Collect

We collect and process your personal information mainly to contact you for the purposes of understanding your requirements, and delivering services accordingly. For this purpose we will collect contact details including your name and organization.

Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

How We Use Your Information

For example:

●To gather contact information;

●To conﬁrm and verify your identity or to verify that you are an authorized user for security purposes;

●For the detection and prevention of fraud, crime, money laundering or other malpractice;

●To conduct market or customer satisfaction research or for statistical analysis;

●For audit and record keeping purposes;

●In connection with legal proceedings.

Disclosure of Information

We may also disclose your information:

Where we have a duty or a right to disclose in terms of law or industry codes; and/or Where we believe it is necessary to protect our rights.

Information Security

Our security policies and procedures cover:

●Physical security;

●Computer and network security;

●Access to personal information;

●Secure communications;

●Security in contracting out activities or functions;

●Retention and disposal of information;

●Acceptable usage of personal information;

●Governance and regulatory issues;

●Monitoring access and usage of private information; and

●Investigating and reacting to security incidents.

We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

Your Rights: Access to Information

Please note that any such access request may be subject to a payment of a legally allowable fee.

Correction of Your Information

How to Contact Us

Supplemental Privacy Notice for the Bahamas

Original Effective Date: 6/20/2024

If you are located in the Bahamas in accordance with Data Protection (Privacy of Personal Information) Act 2003 (the “Act”), this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

The Information We Collect

Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

How We Use Your Information

For example:

●To gather contact information;

●To conﬁrm and verify your identity or to verify that you are an authorized user for security purposes;

●For the detection and prevention of fraud, crime, money laundering or other malpractice;

●To conduct market or customer satisfaction research or for statistical analysis;

●For audit and record keeping purposes; and/or

●In connection with legal proceedings.

Disclosure of Information

We may also disclose your information:

Where we have a duty or a right to disclose in terms of law or industry codes; and/or Where we believe it is necessary to protect our rights.

Information Security

Our security policies and procedures cover:

●Physical security;

●Computer and network security;

●Access to personal information;

●Secure communications;

●Security in contracting out activities or functions;

●Retention and disposal of information;

●Acceptable usage of personal information;

●Governance and regulatory issues;

●Monitoring access and usage of private information; and

●Investigating and reacting to security incidents.

We will ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

International Transfers of Personal Data Outside of the Bahamas

We may transfer your Personal Data outside the Bahamas where the transfer is (a) to a country or territory deemed to provide an adequate level of protection by a relevant government authority, (b) pursuant to standard contractual clauses approved by a relevant government authority, or (c) in exceptional cases only, under a speciﬁc derogation recognized under applicable data protection law, including the Act.

Please contact us at privacy@alliancetrustcompany.com, if you would like further information.

Your Rights: Access to Information

Please note that any such access request may be subject to a payment of a legally allowable fee.

Correction of Your Information

How to Contact Us

Supplemental Privacy Notice for Australia

Original Effective Date: 6/20/2024

Latest Revised Date: 7/24/2026

If you are located in Australia in accordance with the Privacy Act 1988, as amended by the Privacy and Other Legislation Amendment Act 2024, and the Australian Privacy Principles, this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

This Privacy Policy explains what types of information we collect from you, how we may use it, to whom we may disclose it and how you can change the information that you provide us.

The Privacy Policy applies to all of the client relationships and potential client relationships oﬀered to our customers in Australia and applies regardless of which country you access our services from, or how you access those services.

By engaging us to provide investment management and trust services, you consent to our collection, use and transfer of information provided by you in accordance with the terms of this Privacy Policy.

If you do not agree with this Privacy Policy, please do not continue to use our services.

Information We Collect

Client Information

Alliance may collect information about:

●Clients, business associates and potential clients and their employees;

●Suppliers and their employees;

●Prospective employees, employees and contractors; and/or

●Other people who come into contact with members of Alliance.

●If you utilize our services, we may collect some or all of the following information from you:

●Your full name and address;

●Your e-mail address or telephone number;

●Your date of birth and gender;

●Your bank details for payments, invoices or reimbursements;

●Information about your legal issues and personal circumstances; and/or

●Any other information which you provide us.

We may combine the information which you provide us with other information we collect from other sources and, if we do so, our use of the resulting combined information will be subject to this Privacy Policy.

Failure to Provide Information

If you do not provide us with some or all of the above information, this may aﬀect our ability to provide you with services.

Information Collected Through Automatic Data Collection

The Alliance website uses “cookies” (which are small data ﬁles containing information about you that is stored on your hard drive), “embedded scripts,” and other similar tracking technologies (“Tracking Technologies”) to collect information about you. We do not collect personal information through unreasonably intrusive means such as address harvesting software.

Some Tracking Technologies are used to track your interaction with the website and target your interests to enhance your website experience. We may also use Tracking Technologies to collect “clickstream” data, such as the domain name of the service providing you with Internet access, the Internet protocol (“IP”) address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our website, pages viewed, content searched for, access times and other relevant statistics, and assign unique identiﬁers to the device you use to access the website for the same purposes.

Methods of Collecting Information

Alliance will generally collect personal information by way of forms ﬁlled out by people, face-to-face meetings, interviews, business cards, telephone conversations and from third parties.

In some circumstances, Alliance may be provided with personal information about an individual from a third party.

Any personal information provided by, or regarding, third parties is collected and used in accordance with this Privacy Policy and the Australian Privacy Principles. In addition, where third-party personal information is provided by our clients in the delivery of our services, we will be subject to a legal obligation of duty of confidentiality in relation to client data or information provided to us.

How We Use Information

Permitted Uses

Alliance may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorized by the Privacy Act.

In general, we will use and disclose your personal information for the following purposes:

●To conduct our business;

●To provide and market our services;

●To communicate with you;

●To comply with our legal obligations; and/or

●To help us manage and enhance our services.

Disclosure of Information to Others

General Disclosures

Alliance may disclose your personal information to:

●Other oﬃces of Alliance;

●Other companies or individuals who assist Alliance in providing services or who perform functions on its behalf (such as vendors, specialist consultants and lawyers);

●Courts, tribunals and regulatory authorities; and/or

●Anyone else to whom you authorize disclosure.

We also collect personal information from these organizations and individuals, and deal with that information in accordance with this Privacy Policy.

Overseas Data Transfers

Alliance will not send your personal information to recipients outside of Australia without:

●Taking reasonable steps to ensure that the overseas recipient complies with the Australian Privacy Principles and this Privacy Policy;

●Obtaining your consent; and

●Otherwise complying with the Privacy Act.

●You consent to any such transfers, provided that they are otherwise in accordance with this Privacy Policy.

Third-party Data Transfers

We will only transfer your personal information to third parties, other than those listed above, in the following circumstances:

●To protect or defend the legal rights or property of Alliance, our aﬃliated entities or their employees, agents and contractors (including enforcement of our agreements);

●To protect the safety and security of our website and clients;

●To protect against fraud or for risk management purposes;

●If we believe your actions violate this Privacy Policy; and/or

●To comply with law or legal process.

Opting Out of Marketing and Promotional Use

We would like to send you marketing and promotional information about the services of Alliance. We comply with the provisions of the Spam Act 2003. If you have consented to receive such information, you may opt out at a later date by phoning us by contacting us at privacy@alliancetrustcompany.com .

Data Collection From Children and Lack of Consent

We do not knowingly collect personal information from children under 13 without appropriate parental notice and consent.

Sensitive Information

Some personal information that Alliance collects is ‘sensitive information’. Sensitive information, which is also personal information, includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record and health information about an individual.

Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise, or where certain other limited circumstances apply (e.g., where required by law).

Management of Personal Information

The Privacy Act requires Alliance to take reasonable steps to protect the security of personal information. Our personnel are required to respect the conﬁdentiality of personal information and the privacy of individuals.

We take reasonable steps to protect personal information from misuse and loss and from unauthorized access, modiﬁcation or disclosure, for example, by use of physical security and restricted access to electronic records.

Where Alliance no longer requires your personal information for a permitted purpose under the Privacy Act, we will take reasonable steps to destroy it.

As noted above, we maintain certain technical and security safeguards to protect the information which you disclose to us. However, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. We also limit access to our website by our own employees, contractors, website service providers and those individuals who are authorized for the proper handling of such information. We request that our third-party contractors and website service providers follow similar standards of security and conﬁdentiality.

Your Rights

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email us at privacy@alliancetrustcompany.com . We may request that you cover our reasonable costs for providing you with access.

We want to make sure that your personal information is up to date. You may ask us to correct or remove information which you think is inaccurate.

If you are concerned that we may have breached the Australian Privacy Principles, please email us at privacy@alliancetrustcompany.com . We will undertake a reasonable and expeditious assessment of the concern and suggest relevant resolution processes.

If you have any queries or concerns about your rights, please contact the Australian Information Commissioner.

Links

Alliance is not responsible for the privacy practices of any third-party websites or other services operated by third parties that are linked to or integrated with our website. Please refer to those parties’ websites to view their privacy policies.

Privacy Policy Changes

From time to time, we may modify this Privacy Policy to reﬂect industry initiatives or changes in the law, our information collection and use practices, the features of our services, or technology, and such modiﬁcations are eﬀective upon posting. Your continued use of our services after we notify you of our revised Privacy Policy signiﬁes your acceptance of the revised Privacy Policy.

Please review this Privacy Policy regularly to ensure you are updated as to any changes.

Accuracy and Amendments to Your Information

We are not responsible for any problems that may arise if you do not give us accurate, truthful or complete information, or if you fail to update such information. Any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy may be deleted by us.

If you wish to amend any of your details or the information which you have provided us with, please contact us using the details below.

How to Contact Us

If you have any questions about our privacy practices or any of the terms or conditions of this Privacy Policy, please feel free to contact us at privacy@alliancetrustcompany.com.

Supplemental Privacy Notice for Japan

Original Effective Date: 6/20/2024

If you are located in Japan, in accordance with the Act on the Protection of Personal Information and its amendments(the “Amended APPI”), this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in Japan for the reasons set forth below. The lawful basis for each purpose may be diﬀerent. Please contact us at privacy@alliancetrustcompany.com if you would like to know the speciﬁc legal basis which applies in connection with a particular processing operation.

In general, the lawful bases that we rely on are the following:

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

●Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International Transfers of Personal Data Outside of Japan

We may transfer your Personal Data outside Japan relying on appropriate or suitable safeguards or speciﬁc derogations recognized under applicable data protection law.

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors speciﬁcally to assist with our ﬁrm’s activities. Any such third parties whom we engage are bound contractually to keep all information conﬁdential.

All Personal Data transferred by us is subject to a cross-border arrangement and cooperation.

Rights of Data Subjects

●Access your Personal Data;

●Correct or update any of your Personal Data that is inaccurate;

●Restrict or limit the ways in which we use your Personal Data;

●Object to the processing of your Personal Data;

●Request the deletion of your Personal Data; and

●Obtain a copy of your Personal Data in an easily accessible format.

If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority.

Data Retention

Failure to Provide Personal Data

Supplemental Privacy Notice for Curaçao

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in Curaçao in accordance with National Ordinance on the Protection of Personal Data (Landsverordening bescherming persoonsgegevens, P.B. 2010, no. 84) (the “Act”), this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

The Information We Collect

Website usage information may be collected using “cookies” which allows us to collect standard internet visitor usage information.

How we Use Your Information

For example:

●To gather contact information;

●To conﬁrm and verify your identity or to verify that you are an authorized user for security purposes;

●For the detection and prevention of fraud, crime, money laundering or other malpractice;

●To conduct market or customer satisfaction research or for statistical analysis;

●For audit and record keeping purposes; and/or

●In connection with legal proceedings.

Disclosure of Information

We may also disclose your information:

●Where we have a duty or a right to disclose in terms of law or industry codes; and/or

●Where we believe it is necessary to protect our rights.

Information Security

We are legally obliged to provide adequate protection for the personal information we hold and to stop unauthorized access and use of personal information. We , on an on-going basis, continue to review our security controls and related processes to ensure that your personal information remains secure.

Our security policies and procedures cover:

●Physical security;

●Computer and network security;

●Access to personal information;

●Secure communications;

●Security in contracting out activities or functions;

●Retention and disposal of information;

●Acceptable usage of personal information;

●Governance and regulatory issues;

●Monitoring access and usage of private information; and

●Investigating and reacting to security incidents.

We make ever effort to ensure that anyone to whom we pass your personal information agrees to treat your information with the same level of protection as we are obliged to.

International Transfers of Personal Data Outside of Curaçao

We may transfer your Personal Data outside Curaçao where the transfer is (a) to a country or territory deemed to provide an adequate level of protection by a relevant government authority, (b) pursuant to standard contractual clauses approved by a relevant government authority, or (c) in exceptional cases only, under a speciﬁc derogation recognized under applicable data protection law, including the Act.

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors speciﬁcally to assist with our ﬁrm’s activities. Any such third parties whom we engage are bound contractually to keep all information conﬁdential.

Please contact us at privacy@alliancetrustcompany.com, if you would like further information.

Your Rights: Access to Information

Please note that any such access request may be subject to a payment of a legally allowable fee.

Correction of Your Information

How to Contact Us

Supplemental Privacy Notice for the European Union, the United Kingdom and Switzerland

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in the European Union (including, but not limited to, Bulgaria, France, Germany, Italy, the Netherlands, or Spain) (the “EEA”), the United Kingdom or Switzerland, in accordance with Article 13 of the European Union General Data Protection Regulation 2016/679 (the “GDPR”), the relevant national implementing acts (France: Loi Informatique et Libertés; Italy: Codice Privacy; the Netherlands: Uitvoeringswet AVG; Spain: LOPDGDD; Bulgaria: PDPA), the UK General Data Protection Regulation, as amended by the Data (Use and Access) Act 2025, and the revised Swiss Federal Act on Data Protection (revFADP/nFADP),in force since September 1, 2023, this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in the EEA or the UK for the purposes set forth below. Where more than one purpose is listed, please contact us at privacy@alliancetrustcompany.com , if you would like to know the speciﬁc legal basis which applies in connection with your speciﬁc enquiry. We have provided further information on the legal bases we generally rely on below:

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

●Legitimate interests – This means our general interest in conducting and managing our organization to enable us to provide you with the best products and give you the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Our speciﬁc legitimate interests include, but are not limited to:

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

●Consent – In accordance with applicable law, we may seek your consent or explicit consent to process Personal Data collected on this Website or volunteered by you. For example, in relation to our marketing and promotional activities.

●Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International Transfers of Personal Data Outside of the EEA, the UK or Switzerland

We may transfer your Personal Data outside the EEA, the UK or Switzerland where the transfer is (a) to a country or territory deemed to provide an adequate level of protection by a relevant government authority (e.g. the European Commission or the UK government), (b) pursuant to standard contractual clauses approved by a relevant government authority (e.g. the European Commission or the UK government), or (c) in exceptional cases only, under a speciﬁc derogation recognized under applicable data protection law, including the GDPR.

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors speciﬁcally to assist with our ﬁrm’s activities. Any such third parties whom we engage are bound contractually to keep all information conﬁdential.

Please contact us at privacy@alliancetrustcompany.com, if you would like further information.

Rights of Data Subjects

●Access your Personal Data;

●Correct or update any of your Personal Data that is inaccurate;

●Restrict or limit the ways in which we use your Personal Data;

●Object to the processing of your Personal Data;

●Request the deletion of your Personal Data; and

●Obtain a copy of your Personal Data in an easily accessible format.

In addition, where we rely on consent to process your Personal Data, you have the right to withdraw consent at any time. However, a withdrawal of consent does not aﬀect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will make a good-faith effort to advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we may extend the timeframe by up to two further months but we will make a good-faith effort to notify you and keep you updated if this is the case.

●A list of EU supervisory authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

●The relevant UK supervisory authority is the UK Information Commissioner’s Oﬃce: https://ico.org.uk/.

●The relevant Swiss supervisory authority is the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edoeb/en/home.html .

Automated Decision-Making and Profiling

Pursuant to Article 22 of the GDPR and UK GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You have the right to request human intervention from Alliance, to express your point of view, and to contest any decision generated or assisted by automated or artificial intelligence tools that carries such effects.

Data Retention

We retain your Personal Data for as long as is necessary for the purposes listed in this Policy unless a longer period is required under applicable law, or a longer period is needed to resolve disputes or protect our legal rights or otherwise comply with legal obligations.

Failure to Provide Personal Data

Supplemental Privacy Notice for Canada

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in Canada, in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), Quebec’s Act respecting the protection of personal information in the private sector (Law 25), British Columbia’s Personal Information Protection Act (PIPA), and Alberta’s Personal Information Protection Act (PIPA), this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Lawful Bases for Processing

We process the Personal Data of visitors to this Website who are located in Canada for the reasons set forth below. The lawful basis for each purpose may be diﬀerent. Please contact us at privacy@alliancetrustcompany.com if you would like to know the speciﬁc legal basis which applies in connection with a particular processing operation.

In general, the lawful bases that we rely on are the following:

●Contractual necessity – We will process your Personal Data where necessary for us to meet our contractual commitments to you.

○Administering our operations;

○Providing high quality customer service;

○Developing our services, and what we charge for them;

○Deﬁning types of customers for any new services;

○Understanding how our Website is being used;

○Developing and growing our operations;

○Ensuring cybersecurity;

○To enhance protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and

○To meet our obligations and enforce our legal rights.

●Compliance with laws and regulations – We will process your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

International Transfers of Personal Data Outside of Canada

We may transfer your Personal Data outside Canada relying on appropriate or suitable safeguards or speciﬁc derogations recognized under applicable data protection law.

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors speciﬁcally to assist with our ﬁrm’s activities. Any such third parties whom we engage are bound contractually to keep all information conﬁdential.

All Personal Data transferred by us is subject to a cross-border arrangement and cooperation.

Rights of Data Subjects

●Access your Personal Data;

●Correct or update any of your Personal Data that is inaccurate;

●Restrict or limit the ways in which we use your Personal Data;

●Object to the processing of your Personal Data;

●Request the deletion of your Personal Data; and

●Obtain a copy of your Personal Data in an easily accessible format.

In addition, where we rely on consent to process your Personal Data, you have the right to withdraw consent at any time. However, withdrawal of consent does not aﬀect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will make a good-faith effort advise you if this is the case at the time you withdraw your consent.

If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority.

Data Retention

Failure to Provide Personal Data

Supplemental Privacy Notice for People’s Republic of China and Chinese Taipei

Original Effective Date: 6/20/2024

Latest Revised Date: 7/23/2026

If you are located in The People’s Republic of China or Chinese Taipei, in accordance with the China’s Personal Information Protection Law (“PIPL”), the Data Security Law (2021), the Cypersecurity Law (2017), or Chinese Taipei’s Personal Data Protection Act, as amended in 2023 (“PDPA”), this Supplemental Privacy Notice (together with other relevant sections of the Policy) provides information about the collection, use, processing, and sharing of data about you.

Personal Information Collected and Processed

Depending on the services that you use, Alliance collects and processes personal information from you. Alliance is located outside of the People’s Republic of China and Chinese Taipei. Such personal information includes contact details and other information necessary to verify your identity; internet or other network activity information; biographical information, including professional and employment information; information necessary to provide services that you request; and information that we are required to obtain under applicable laws.

Alliance may also collect and process the following categories of sensitive personal information about you: ﬁnancial and commercial information and location-tracking information. Our collecting and processing of ﬁnancial and commercial information and location-tracking information is necessary to provide products and services to you and to comply with applicable laws, and your rights regarding our processing of this and other personal information are described in this Privacy Notice.

We also may obtain personal information about you from other legitimate sources, including from our service providers and publicly available sources, to assist us in verifying your identity, providing our services to you, and complying with applicable laws.

Bases for and Purposes of Personal Information Processing

We collect and process your personal information when necessary for the performance of a contract with you, to take steps at your request before you enter into a contract with Alliance, with your consent, and/ or to comply with applicable laws. For further information about our privacy practices in the United States, please review our Privacy Notice at https://alliancetrustcompany.com/privacy-policy/.

Sharing of Personal Information

We may share your personal information with entrusted parties to improve the services that we provide to you and to help us conduct our business.

Our entrusted parties provide: (a) vendor services to facilitate and support the services we provide, (b) professional services, such as auditing, accounting, and tax services, (c) public relations, including education and development services, (d) marketing and promotional event services, (e) market data and research, (f) network platform support services, (g) administrative services, such as printing and mailing, and (h) legal, governmental, and regulatory support. These entrusted parties maintain processes and/or are subject to contractual obligations that require the personal information to be safeguarded and only used for the purposes for which it was shared and retained for the contracted period.

Additionally, we may share your personal information in connection with a merger, acquisition, corporate reorganization, or the sale of all or substantially all the assets of Alliance, one of its affiliates, or any of its third-party custodians, and with government authorities and regulators to comply with applicable laws. Notification may be issued when such circumstances arise pursuant to applicable law.

Security of Personal Information

We use technical, administrative, and physical controls to protect the conﬁdentiality, integrity, and availability of your personal information.

Information Storage Period

We process and store personal information for as long as is required to provide our products and services to you, or as otherwise required by applicable laws.

Your Rights

You have certain rights with respect to your personal information. You can exercise or address these rights as allowed under applicable law, ask questions about our use of your personal information, or raise other issues or disputes by contacting us through the communication method provided at the beginning of this Privacy Notice.

1.Access and explanation. You have the right to obtain access to your personal information and an explanation of the rules for processing.

2.Correction. You have the right to ask that your personal information that is incorrect, inaccurate, or incomplete be corrected.

3.Deletion. You have the right to request that your personal information be deleted.

4.Restriction on processing. You have the right to request the restriction of the processing of your personal information in speciﬁc cases.

5.Objection to processing. You have the right to object to the processing of your personal information for marketing purposes or on grounds relating to your particular situation.

6.Portability. You have the right to receive your personal information in a machine-readable format and to send it to another personal information processor.

7.Withdrawal of consent. You have the right to withdraw consent.

8.Lodging a complaint with the relevant authorities. You have the right to lodge a complaint, as applicable, with the relevant authorities of the P.R.C. or Chinese Taipei.

9.Other rights under applicable laws.

Updates

We may update or change this Privacy Notice from time to time without advance notice. Should any new Privacy Notice go into eﬀect, we will post it on our website. When we make changes, we will update the “Eﬀective Date” at the top of this page. Any changes to this Privacy Notice will become eﬀective when posted.

Supplemental Privacy Notice for Panama

Effective Date: 7/23/2026

This Supplemental Privacy Notice for Panama applies strictly to residents of the Republic of Panama and is intended to be read in conjunction with our global Privacy Policy (the “Policy”). The definitions found in the Policy apply to this Supplemental Privacy Notice.

This Supplemental Notice provides information required under Law No. 81 of March 26, 2019, on Personal Data Protection (Ley 81 de Protección de Datos Personales) and its regulating Executive Decree No. 285 of May 28, 2021, and any subsequent regulations arising therefrom.

Scope and Banking Confidentiality Carve-Out

Please note that pursuant to Article 3 of Law 81, personal data processed by financial, banking, trust, or fiduciary institutions subject to special regulatory frameworks in Panama (such as those overseen by the Superintendency of Banks or the Superintendency of the Securities Market) shall continue to be governed by their respective special laws regarding information retention, confidentiality, and security. This Supplemental Notice does not override, and must be read in alignment with, those mandatory fiduciary and professional confidentiality frameworks.

Your Data Subject Rights (ARCO Rights)

As a data subject in Panama, you are granted the following fundamental statutory rights regarding your personal data:

1.Right of Access: You have the right to obtain confirmation from us as to whether your personal data is being processed, and to receive a copy of your personal data along with details regarding its origin and the purposes of its processing.

2.Right of Rectification: You have the right to request the correction, modification, or updating of your personal data if it is inaccurate, incomplete, or outdated.

3.Right of Cancellation (Deletion): You have the right to request the deletion or erasure of your personal data when its storage is no longer necessary, justified, or authorized under Law 81 or applicable fiduciary and trust retention statutes.

4.Right of Opposition: You have the right to object to the processing of your personal data based on legitimate and justified grounds related to your particular situation, or where your data is being used for direct marketing or promotional purposes.

5.Right of Portability: You have the right to obtain a copy of your personal data in a structured, commonly used, and machine-readable format, or to request that we transfer it directly to another data controller, where technically feasible.

Data Security and Integrity

In compliance with Panamanian law, we implement strict technical, administrative, and organizational measures to ensure the confidentiality, integrity, and safety of your personal data, preventing unauthorized access, loss, or alteration.

Instructions to Exercise Your Rights

If you are a resident of Panama and wish to exercise any of your statutory data privacy rights, or if you have any questions regarding our data practices in Panama, please submit a verifiable request to our Privacy Department at privacy@alliancetrustcompany.com or by calling 1-775-384-0806, extension 134.

Supplemental Privacy Notice for Nigeria

Effective Date: 7/23/2026

This Supplemental Privacy Notice for Nigeria applies strictly to data subjects residing in the Federal Republic of Nigeria and is intended to be read in conjunction with our global Privacy Policy (the “Policy”). The definitions found in the Policy apply to this Supplemental Privacy Notice.

This Supplemental Notice provides information required under the Nigeria Data Protection Act, 2023 (NDPA), as enforced by the Nigeria Data Protection Commission (NDPC), and any subsequent regulations or guidelines arising therefrom.

Lawful Bases for Processing

We process your personal data under Nigeria law only when we have a valid lawful basis to do so, which includes, may not be limited to:

●Consent: Where you have given explicit consent for specific processing purposes.

●Contractual Obligation: Where processing is necessary for the performance of a contract or trust agreement to which you are a party.

●Legal Obligation: Where processing is necessary for compliance with statutory, legal, financial, or regulatory duties imposed upon Alliance.

●Legitimate Interests: Where processing is necessary for legitimate commercial interests pursued by us, provided they do not override your fundamental rights and freedoms.

Your Data Subject Rights under the NDPA

Pursuant to the NDPA, you have specific, enforceable rights regarding your personal data, which include:

1.Right to Information: The right to be informed of the identity of the data controller, the specific purposes of processing, the categories of data collected, and the third parties to whom your data may be disclosed.

2.Right of Access: The right to obtain confirmation as to whether we hold your personal data and to receive a clear copy of such data free of charge.

3.Right to Rectification: The right to request the immediate correction or updating of any inaccurate, incomplete, or misleading personal data.

4.Right to Erasure (Deletion): The right to request the erasure of your personal data where it is no longer necessary for the purposes collected, or where you have withdrawn your consent and no other legal or regulatory retention obligation exists.

5.Right to Restriction of Processing: The right to restrict or suspend the processing of your personal data under specific statutory conditions (e.g., while the accuracy of the data is being contested).

6.Right to Object: The right to object at any time to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.

7.Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance.

8.Right to Withdraw Consent: The right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Cross-Border Data Transfers

Where personal data collected in Nigeria is transferred outside of Nigeria, Alliance ensures that such transfers comply strictly with the cross-border requirements of the NDPA, utilizing appropriate safeguards, standard contractual clauses, or verifying that the destination country maintains an adequate level of data protection.

Instructions to Exercise Your Rights

To exercise your data privacy rights under Nigerian law, or to lodge an inquiry, please contact our Privacy Department at privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134. If you remain unsatisfied with our response, you maintain the right to lodge a complaint directly with the Nigeria Data Protection Commission (NDPC).

Supplemental Privacy Notice for Latin America

Effective Date: 7/23/2026

This Supplemental Privacy Notice for Latin America applies strictly to residents of Mexico, Colombia, Ecuador, Chile, Peru, Costa Rica, and the Dominican Republic, and is intended to be read in conjunction with our global Privacy Policy (the “Policy”). The definitions found in the Policy apply to this Supplemental Privacy Notice.

This Supplemental Notice describes our practices regarding the collection, use, and disclosure of personal data (datos personales) pursuant to the comprehensive data protection frameworks enacted across these jurisdictions, including Mexico’s Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP), Colombia’s Ley 1581 de 2012, Ecuador’s Ley Orgánica de Protección de Datos Personales (LOPDP), Chile’s Ley 19.628, Peru’s Ley de Protección de Datos Personales (Ley N° 29733), Costa Rica’s Ley de Protección de la Persona frente al tratamiento de sus datos personales (Ley N° 8968), and the Dominican Republic’s Ley No. 172-13, alongside their respective regulations.

Shared Definitions Across the Region

●“Personal Data” (Datos Personales): Any information concerning an identified or identifiable natural person.

●“Sensitive Data” (Datos Sensibles): Personal data that affects the most intimate sphere of the data subject, or whose misuse may give rise to discrimination or entail a serious risk for the individual. This includes data revealing racial or ethnic origin, religious beliefs, union membership, political opinions, health data, genetic or biometric data, and sexual life.

●“Data Subject” (Titular): The natural person to whom the personal data belongs.

Specific Consent Requirements

In accordance with Latin American privacy frameworks, by interacting with our website or engaging our services, you generally consent to the processing of your personal data for the purposes outlined in our Policy.

●State-Specific Variant (Mexico): For residents of Mexico, we will request your explicit written, electronic, or verbal consent prior to processing any Sensitive Data, as required by the LFPDPPP.

●State-Specific Variant (Colombia & Ecuador): For residents of Colombia and Ecuador, you are informed that providing answers to questions regarding sensitive data or data of children and adolescents is completely voluntary.

Your Fundamental Rights (ARCO Rights)

Data subjects across these Latin American nations are guaranteed fundamental rights commonly known as ARCO Rights, subject to statutory limitations or fiduciary recordkeeping requirements:

1.Access (Acceso): The right to know if your personal data is being processed, the origin of such data, and the specific terms and purposes of its processing.

2.Rectification (Rectificación): The right to request the update, correction, or modification of your data if it is partial, inaccurate, incomplete, misleading, or outdated.

3.Cancellation / Deletion (Cancelación o Supresión): The right to demand that your personal data be blocked, deleted, or erased from our databases when it is no longer necessary for the purposes collected, or when legal or contractual requirements permit its removal.

4.Opposition (Oposición): The right to object, on legitimate grounds, to the processing of your personal data for specific purposes, including direct marketing, advertising, or commercial prospecting.

In addition to ARCO rights, residents of specific states (such as Ecuador and Colombia) maintain the right to Data Portability and the right to request proof of the consent granted to the data controller.

Instructions to Exercise Your Rights

If you reside in any of the covered Latin American nations and wish to exercise your ARCO rights, or if you have questions regarding our localized data practices, please submit a verifiable request to our Privacy Department at privacy@alliancetrustcompany.com or by calling 1-775-384-0806, extension 134.

Supplemental Privacy Notice for Caribbean and Offshore Jurisdictions

Effective Date: 7/23/2026

This Supplemental Privacy Notice for Caribbean and Offshore Jurisdictions applies strictly to data subjects residing in Bermuda, the British Virgin Islands (BVI), and Saint Kitts and Nevis, and is intended to be read in conjunction with our global Privacy Policy (the “Policy”). The definitions found in the Policy apply to this Supplemental Privacy Notice.

This Supplemental Notice provides information required under the comprehensive data protection statutes of these respective jurisdictions, including Bermuda’s Personal Information Protection Act 2016 (PIPA), the British Virgin Islands Data Protection Act, 2021 (DPA), and the Saint Christopher and Nevis Data Protection Act, alongside any subsequent regulations or statutory updates arising therefrom.

General Privacy Principles

In alignment with the common law and statutory structures of these jurisdictions, Alliance adheres to the core principles of data protection, ensuring that your personal information is:

●Processed lawfully, fairly, and transparently;

●Collected only for specified, explicit, and legitimate business or fiduciary purposes;

●Adequate, relevant, and limited to what is necessary (data minimization);

●Accurate and, where necessary, kept up to date; and

●Retained only for as long as required to fulfill the operational purposes or to satisfy regulatory, financial, and corporate trust record-retention mandates.

Your Data Subject Rights

As a data subject residing in these offshore jurisdictions, you possess the following rights regarding your personal information, subject to applicable legal, fiduciary, and anti-money laundering (AML) verification exemptions:

1.Right to be Informed: The right to receive clear, transparent, and easily accessible information regarding how we collect, use, disclose, and protect your personal information.

2.Right of Access: The right to request a confirmation of whether we process your personal information and to obtain a clear copy of the specific pieces of information held about you.

3.Right to Rectification: The right to require that any inaccurate, incomplete, or outdated personal information we maintain be corrected or updated without undue delay.

4.Right to Erasure (Deletion): The right to request the deletion or destruction of your personal information where there is no overriding legal, regulatory, or fiduciary justification to retain it.

5.Right to Restrict or Object to Processing: The right to request that we restrict the processing of your personal information under certain circumstances, or to object to its processing for direct marketing, promotional, or automated decision-making purposes.

6.Right to Complain: The right to lodge an inquiry or complaint with the appropriate localized regulatory authority if you believe your information has been handled in breach of local laws.

Instructions to Exercise Your Rights

To submit a request to know, access, correct, or delete your personal information under the laws of Bermuda, the BVI, or Saint Kitts and Nevis, please contact our Privacy Department at privacy@alliancetrustcompany.com or call 1-775-384-0806, extension 134.