Neverwinter | Crypto Hedge Fund

Privacy Policy

Last updated: 13/08/2025

Regulatory Development

This Privacy Policy explains how Neverwinter Fund I SLP (“Neverwinter”, “we”, “us”, “our”) collects, uses, and protects personal data when you visit our website www.neverwinter.ai.

We are committed to protecting your privacy and complying with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection laws.

1. Data Controller

The data controller responsible for your personal data is:

Neverwinter Fund I SLP
Registered Office: 2C, Parc d’Activités, 3rd Floor, L-8308 Capellen, Grand Duchy of Luxembourg
Email: investor@neverwinter.ai.

2. Data We Collect

We only collect and process personal data in the following situations:

Remarketing

We use cookies and similar technologies for remarketing purposes to display targeted ads based on your past interactions with our website.
This may include your IP address, browser type, pages visited, and general location data.

Contact Form
- When you send us a message through our contact form, we collect the personal data you provide, which may include:
  - Name
  - Email address
  - Any other information you choose to share in your message.

We do not collect or process any other personal data unless a separate privacy policy covering such processing is provided.

3. Purpose and Legal Basis for Processing

We process your personal data for the following purposes:

Remarketing – based on your consent under Article 6(1)(a) GDPR.
Responding to Contact Form Submissions – based on our legitimate interest in responding to inquiries under Article 6(1)(f) GDPR or, if applicable, to take steps at your request prior to entering into a contract under Article 6(1)(b) GDPR.

4. Cookies and Tracking

Our remarketing activities rely on cookies and similar technologies. You will be asked for consent before such cookies are placed, and you may withdraw your consent at any time.

5. Data Sharing

We do not sell your personal data. We may share your data with:

Service providers assisting with website hosting, analytics, and advertising (only as necessary and subject to confidentiality obligations).
Authorities or regulators where required by law.

6. Data Transfers Outside the EEA

If personal data is transferred outside the European Economic Area, we will ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

7. Data Retention

Contact form data will be kept for as long as necessary to respond to your inquiry and, where relevant, to comply with legal obligations.

Remarketing data will be kept according to the retention periods set by the relevant advertising platform or until you withdraw your consent.

8. Your Rights under GDPR

You have the right to:

Access your personal data
Rectify inaccurate or incomplete data
Erase your personal data (“right to be forgotten”)
Restrict processing
Object to processing, including direct marketing
Withdraw consent at any time
Lodge a complaint with a supervisory authority

To exercise your rights, contact us at investor@neverwinter.ai.

9. Security

We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction.