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Data Protection Notice

This notice is intended to inform you about how Sauder Global processes the personal data that you provide. In this notice, "SGI" refers to one or more of the following Sauder Global entities you have a contractual relationship with: Sauder Global Trustee Services (Ireland) Limited, Sauder Global Fund Administration Services (Ireland) Limited, Sauder Global Investor Services Limited (UK), Sauder Global (Luxembourg) S.C.A.

As a Data Controller, SGI processes personal data in compliance with the General Data Protection Regulation (EU/2016/679) ("GDPR").

If you are an individual associated with a client who provides SGI with your personal data in connection with your business relationship, the information in this notice is relevant to you. We kindly request that the client makes this information available to you.

By continuing to provide us with personal data, you confirm that:

  1. All personal data you provide to SGI is collected, processed, and shared in accordance with applicable laws, including the GDPR.
  2. The personal data you provide is accurate, relevant, limited to the necessary purposes, and, when applicable, kept up-to-date.
  3. If you provide personal data to SGI with the intention of transferring it to a jurisdiction without equivalent personal data protection as the EU, you have informed the relevant individuals about this in compliance with the GDPR. Additionally, you have obtained their specific, unambiguous, and freely given consent.

GDPR Compliance

Sauder Global Investment ("SGI") acknowledges its responsibility as a Data Controller under the GDPR for processing any personal data you provide. We are committed to adhering to the requirements of the GDPR and have implemented suitable technical and organizational measures to ensure the proper security and protection of your personal data. Rest assured that SGI will handle your personal data in compliance with the GDPR's provisions.

 

Purposes and Legal Basis of Processing

  1. To fulfill its contractual obligations as stated in its agreement(s) with you.
  2. To engage in communication with you and further establish and nurture our business relationship. This includes providing you with information about our products and services.
  3. To comply with relevant laws, rules, and regulations, such as anti-money laundering, sanctions screening, and taxation requirements.

SGI

Sauder Global will exclusively process personal data for the purposes for which it has been provided, unless authorized by applicable law.

The processing of personal data is based on its legitimate interests in conducting its business operations and fulfilling legal obligations, including compliance with relevant laws, rules, and regulations.

Recipients of Personal Data

In the course of processing personal data for the aforementioned purposes, it may be necessary for us to transfer or disclose such data to the following entities, as well as their personnel and agents:

  1. Affiliates of SGI.
  2. Agents, network, and service providers of SGI, including providers of audit, legal, tax, sub-custody, and information technology services.
  3. Regulatory agencies with authority over SGI, as mandated by applicable law.

SGI will comply with the GDPR when transferring personal data to a recipient outside of the European Economic Area.

 

Storage Limitation

Sauder Global Investment ("SGI") will retain personal data for a duration that is deemed reasonably necessary for the specific purpose for which it was provided. However, if applicable laws, rules, and regulations require SGI to retain such personal data for a longer period, SGI will comply with those requirements.

 

Individuals’ Rights

Individuals have the right to obtain a copy of their personal data held by Sauder Global Investment ("SGI") and to rectify any inaccuracies in it. These rights can be exercised by submitting a written request to SGI. Under the GDPR, individuals also have the right to request erasure, restriction, and portability of their personal data, as well as the right not to be subject to automated decision-making, including profiling. If individuals wish to assert any of these rights, they can contact SGI using the provided email address. SGI will respond to such requests in a timely manner, as required by applicable law.

Furthermore, individuals have the right to lodge a complaint with the relevant data protection supervisory authority if they are dissatisfied with how SGI processes their personal data.

 

Contact

Please address requests to SGI by email at dpo@sgiml.com.

 

The information provided in this publication by Sauder Global and its subsidiaries ("SGI") is intended solely for recipients classified as Professional Clients or Eligible Counterparties within the European Economic Area ("EEA") for informational purposes only. It should not be construed as legal, tax, or investment advice, nor does it constitute an offer to sell or a solicitation to buy securities or investment products. References to tax matters are not intended to be used for the purpose of evading penalties under the U.S. Internal Revenue Code or for promoting, marketing, or recommending to third parties.

The information contained in this publication has been obtained from sources believed to be reliable, which can be made available upon request. However, SGI does not guarantee its accuracy or completeness. This material does not constitute an offer of services, and any opinions expressed are subject to change without notice.

Unauthorized use or distribution of this publication without the prior written permission of SGI is strictly prohibited. Sauder Global Investor Services Limited, authorized and regulated by the Financial Conduct Authority (FCA), approves the distribution of this publication in member states of the EEA. "SGI" is a service mark of Sauder Global, registered in the United States and other countries.