Cookies Policy

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1. Who We Are

   This website (www.klothorla.com) is operated by Klotho Roundtable SPV SCSp, a Luxembourg Special Limited Partnership (société en commandite spéciale) with its registered office at C/O Roundtable Gama SCSp, 16, rue Robert Stümper, 2557 Luxembourg, Luxembourg.

   We are committed to protecting your privacy and handling your personal data with transparency and in compliance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the UK GDPR.

2. Personal Data We Collect

   • Identification Data: name, company, email address, phone number.
   • Technical Data: IP address, browser type, device information.
   • Usage Data: how you use our website, pages visited, time spent.
   • Cookie Data: see Cookie List below.

3. How We Collect Your Data

   • Direct interactions (e.g., when you contact us).
   • Automated technologies (e.g., cookies, analytics tools).
   • Third-party service providers (e.g., web hosting, analytics platforms).

4. Legal Bases for Processing

   • Your consent (e.g., for non-essential cookies).
   • Our legitimate interests (e.g., website performance and analytics).
   • Compliance with legal obligations (e.g., regulatory requirements).

5. How We Use Your Data

   • Maintain and improve website functionality.
   • Respond to inquiries or requests.
   • Conduct analytics to improve our services.
   • Comply with legal or regulatory requirements.

6. Disclosure to Third Parties

   • IT and analytics service providers (e.g., Google Analytics).
   • Legal or regulatory authorities (if legally required).
   • Our professional advisers (under confidentiality obligations).

7. International Transfers

   Your data may be transferred outside the EEA or UK, but only to jurisdictions that ensure an adequate level of protection or through lawful safeguards (e.g., standard contractual clauses).

8. Data Retention

   We retain your data only as long as necessary for the purposes stated above or as required by law.

9. Your Rights

   • Access your data
   • Rectify inaccuracies
   • Erase your data
   • Restrict or object to processing
   • Withdraw consent at any time
   • Lodge a complaint with the CNPD (Luxembourg) or ICO (UK)

   To exercise your rights, contact: info@klothocapital.com

10. Security

    We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.

11. Changes to This Policy

    We reserve the right to update this Privacy Policy. We will notify users of material changes via this website.

12. Cookie Policy

    What Are Cookies?

    Cookies are small text files stored on your device to help websites function and provide analytics and user preference settings.

    Types of Cookies We Use:

    Cookie Type	Purpose	Example Tools	Consent Required
    Strictly Necessary	Enables core site functionality	Cloudflare, session cookies	No
    Performance / Analytics	Tracks usage to improve website experience	Google Analytics, Plausible	Yes
    Functional	Remembers your preferences	Language settings	Yes
    Targeting / Advertising	(Currently not used)	N/A	Yes (if applicable)

    Cookie Consent

    Upon your first visit, a cookie banner allows you to accept or reject cookies. You may change your preferences at any time through the “Cookie Settings” link in the website footer.

    Managing Cookies

    You can block or delete cookies through your browser settings. Note that disabling cookies may affect website functionality.

    Contact

    For privacy or cookie-related inquiries, contact:
    Klotho Roundtable SPV SCSp
    Email: info@klothocapital.com
    Registered Address: C/O Roundtable Gama SCSp, 16, rue Robert Stümper, 2557 Luxembourg

13. Responsibility of International Visitors

    Visitors accessing this website from jurisdictions outside Luxembourg, the European Union, or the United Kingdom are solely responsible for ensuring that their use of the website and the provision of any personal data complies with the applicable laws and regulations of their jurisdiction.

    • You are aware of and comply with your own local data protection and privacy laws.
    • You accept full responsibility for any consequences arising from accessing the website in breach of those local laws.
    • You will not access or use the website where such use or access would be unlawful.

    Klotho Roundtable SPV SCSp disclaims all liability for any visitor’s failure to comply with their local legal requirements.

    Luxembourg, 25.06.2025