PRIVACY NOTICE

This privacy notice applies to all external service providers, members, visitors (e.g. visitors to our website), job applicants, volunteers and any other third parties who deal with and whose personal data are processed by Fundsight S.A. (hereinafter referred to as the ” Concerned Person ” or the ” Concerned Persons “).

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing the Directive 95/46 / EC, (hereinafter the “GDPR“), we wish to inform the Concerned Persons about the processing of their personal data.

Fundsight S.A. is registered with the Luxembourg Trade and Companies Register under number B44870 (hereafter referred to as the “Fundsight”).

In conformity to the GDPR, Fundsight can act both as a data controller and a processor. The present Privacy Notice covers Fundsight’s processing activities as a data controller.

1. Personal Data

• In accordance with the GDPR definitions, when we refer to “personal data” we mean any data that could identify an individual, directly or indirectly, in particular, by reference to an identifier such as :Identification and professional data (e.g. first name, last name, e-mail address, date of birth, postal address, family members)
• Online identifiers (e.g. including IP addresses, cookie identifiers, online website tracking)
• Government issued identification numbers (e.g. national ID card, passport number, driver’s license number)
• Financial data (e.g. bank account numbers, background checks)
• Communications (e.g. telephone conversations, voice recording when applicable, emails and meetings)
• Publicly available data: (e.g. data about you that is openly available on the internet/public statements)
• Sensitive data (e.g. in specific situation such as Politically Exposed Persons we may collect political data on you as data subject and on your relatives).

Fundsight collects personal data and will act as the data controller of this data if:

• you are a client or represent one of our clients ( e.g. client being the sponsor of an investment fund);
• you are a client entering into discretionary mandate agreement with us;
• you have a business relationship with us ( e.g. adviser or service provider);
• you are are candidate for a position at Fundsight;
• you use one of our websites visit us in our offices or register to attend an event organized or sponsored by Fundsight.

1. Collection of personal data

We collect your personal data during the course of your business relationship with us. For example, when you engage with us in respect of a new relationship/prospective relationship, you will communicate with your contacts within Fundsight. We may also receive data about you from other sources, such as directly from your organization or via other publicly available sources. We combine data about you from various sources, including the data that you have provided to us directly.

Fundsight only collects data that is necessary to fulfil the purpose behind our relationship with you. We won’t collect data we don’t need.

2. How we use your personal data

We will only process your personal data on the basis allowed in the GDPR, for the purposes below, and we will limit the use of sensitive data which have special legal protection.

3. Legal basis for processing your data

We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do so.

Such legal basis may be one of the following:

• to fulfil a contract we have with you or to take steps to enter into a contract with you;
• Customer relationship management;
• to respond to complaints and seek to resolve them;
• to provide certain services ( e.g. domiciliary agent);
• to comply with a legal or regulatory obligation
• report to tax authorities to detect, investigate, report, and seek to prevent fraud, financial crime and anti-money laundering, for example through know-your-customer checks, AML screening and other identity checks to comply with other laws and regulations that apply to us, for example other financial services or country-specific legislation;
• to fulfil our legitimate interest, such as:

(i) to develop new ways to meet our clients’ needs and to grow our business, for example by seeking feedback or sharing our market research to log and monitor use and abuse of our technical services to understand how our clients use products and service from us;

(ii) to protect our IT systems, network and infrastructure to run our business in an efficient and proper way, for example managing our financial position, building our business capability, or for planning, communications, corporate governance or audit;

(iii) to provide direct marketing and/or provision of important regulatory updates or based on a consent that you have given us when you have provided data for use for certain marketing purposes.

(iv) to deploy AI tools that may improve the services that we deliver to clients or enhance the clients’ experience.

In particular, we operate an IA tool NeoSIT Clients Health, that allows monitoring of professional e-mail communications with employees of our CRM team, with the purpose of measuring and improving client satisfaction (by taking measures such as adjustment of response time, improvement of quality of service etc.). The processing includes automated text analysis of e-mail content (sent and received), extraction of sentiment indicators (e.g. positive, neutral, negative) and aggregation of results into dashboards. The AI tool entails human oversight.

• Another legal basis for the processing of the personal data of the Concerned Persons for specific purposes can be their consent. The consent can be withdrawn at any moment. If the processing is in parallel based on another legal basis, then the withdrawal of the consent will in principle not impact the processing by Fundsight (or at least not the full extent of the processing).

4. Data sharing and transferring personal data globally

Fundsight may share your data to manage our business and deliver services and/or to comply with applicable laws, regulations and rules.

Fundsight may transfer your personal data to:

• competent authorities (e.g. working to prevent fraud);
• our regulators (e.g. CSSF, CNPD, CONSOB …);
• third parties which are bound by a contractual agreement and have agreed to confidentiality restrictions being located in the EU or in a country providing an adequate level of data protection;
• other offices of Fundsight within the European Union for administrative and customer relationships purpose, and for the provision of services to investors or Fund.

In the event of the transfer of personal data to another country, in particular a country outside the European Economic Area, Fundsight will ensure that the transfer is carried out in compliance with the legal provisions in force in terms of data protection, including the GDPR, inter alia by putting in place appropriate safeguards.

Fundsight will take appropriate steps to ensure that such processing will be executed in accordance with the below:

• transfers within Fundsight will be covered by an agreement to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred within Fundsight,
• where we transfer your personal data outside Fundsight, or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal data by including standard contractual clauses as defined by the European Commission.

5. Data retention

Personal data is kept no longer than necessary and in compliance with the purpose for which it has been collected and processed, without prejudice to the right of Fundsight to retain certain data for a longer period due to legal / regulatory obligations applying to Fundsight, respectively because of exceptional situations that would justify a longer storage (judicial procedure etc.).

6. Direct Marketing

We may use personal data to let you know about Fundsight products and/or services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing communications with you.

7. Your rights as a data subject

You have a number of legal rights in relation to the personal data that we hold about you and you can exercise your rights by contacting us using the details at the back of this document.

These rights include:

• the right to obtain data regarding the processing of your personal data and access to the personal data which we hold about you;
• the right to withdraw your consent to our processing of your personal data at any time in circumstances where you have explicitly given your consent;
• the right to data portability via the receipt of some of your personal data in                                     a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible;
• the right to request that we correct your personal data when your personal data is inaccurate or incomplete ;
• the right to request that we erase your personal data in certain circumstances;
• the right to object to the processing of your personal data or the right to request that we restrict our processing of your personal data in certain circumstances.

Please note that these rights are subject to certain conditions like legal obligations, retention period requirements especially where you ask us to restrict the use of your personal data or the erasure of such data.

Any complaint can be logged with the applicable data protection regulator.
As regards to this Privacy Policy, there is no need for you to take any action.

Should you have any question on the aforementioned or should you want to exercise one of the above rights, please contact privacy@fundsight.com and visit GDPR Request information in the Corporate Governance section.

8. Amendment of this Declaration

Fundsight reserves the right to modify this declaration at any time and for any reason whatsoever. In case of amendment of the privacy notice, Fundsight will inform the Concerned Persons on time by appropriate means. In addition, the reviewed statement may be consulted on the website of Fundsight.