Privacy policy

Introduction

This notice (the “Notice”) is provided by International Administration Group (Guernsey) Limited, IAG Depositary Services Limited, IAG Trustees Limited, Hirzel Limited, IAG Limited, IAG Services Limited and Kendall Nominees Limited (together “IAG”, “us” or “we”). This Notice is addressed to any natural person who is any of the following: a client of IAG or an investor in any fund administered by IAG (an “IAG Administered Fund”), or a member, partner, shareholder, beneficial owner, officer, director, employee or other representative of any client of IAG or of any investor in any IAG Administered Fund, including any prospective client, investor, interested party or a marketing contact (“you”) whose personal data IAG collects and controls in the conduct of its business.

This Notice gives information regarding your personal data and describes the basis on which we process your personal data, for what purposes, your privacy rights under applicable privacy laws including, where applicable, under General Data Protection Regulation (“GDPR“) and The Data Protection (Bailiwick of Guernsey) Law, 2017 and Data Protection (Commencement, Amendment and Transitional) (Bailiwick of Guernsey) Ordinance, 2018 (the “Privacy Laws”) and how we protect your personal data. Maintaining your privacy is important to us. Because we uphold the highest standards in the safekeeping and use of your personal data, we have developed policies designed to protect confidentiality, whilst allowing the needs of investors and clients to be served.

The information we collect

In the conduct of our business, we may obtain personal data about you in connection with any person’s existing or proposed appointment or engagement of IAG or existing or proposed investment in an IAG Administered Fund (any such person being an “IAG Client” for the purposes of this Notice), including without limitation your name, date of birth, address and other contact details, social security number, tax or other identification number, identity documents and information about your income, assets and other financial information. This information may come from sources such as application, subscription or other forms or material completed or supplied by actual or prospective IAG Clients, other written, electronic or verbal correspondence which relate to transactions by or on behalf of an IAG Client as well as financial information relating to any such person’s investment in an IAG Administered Fund or any portfolio investments, such as capital account balance, contributions, income allocations and distributions. We may also collect personal data provided by you in calls which are recorded by us, as required by applicable laws. We may also collect special categories of personal data (as defined in the GDPR and the Privacy Laws including health, disability and religious or ethnicity information) where provided by you, such as disability information or religious data for purposes required by you such as scheduling of meetings or access to IAG or IAG premises. For marketing purposes we may collect your contact details, including your email address.

How we use information that we collect

We collect your personal data to fulfil our contractual obligations, our statutory obligations and/or the legitimate interests of IAG and for other purposes for which IAG has a lawful basis under the Privacy Laws, including: (i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or “Know Your Customer” requirements, as well as to verify the status and/or eligibility of IAG Clients for funds administered or services offered by IAG and for compliance with tax reporting requirements; (ii) for purposes of reporting to, or communicating with, IAG Clients concerning their investments in IAG Administered Funds or appointment or engagement of IAG consistent with our obligations to such IAG Clients; (iii) in connection with our investment activities, including investment due diligence or investment monitoring activities or in response to “Know Your Customer” requirements of counter-parties; (iv) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving IAG, IAG Administered Funds or IAG Clients; and (v) for other legitimate business interests, including marketing.

The Disclosure of your Information
We may share your personal data with IAG Group entities including with IAG Administered Fund Boards, General Partners or Principal Managers for any of the purposes set forth above. Those entities, in turn, are not permitted to share your information with other non-affiliates entities, except as described herein or otherwise permitted by the Privacy Laws or other applicable laws. The transfer of personal data from Guernsey and the European Economic Area (“EEA”) to jurisdictions outside Guernsey, the UK and EEA is governed by data transfer agreements which are in the form of the standard contractual clauses approved by the European Commission (available at http://eur-lex.europa.eu using search criterion CELEX 32010D0087).

We may share your personal data with non-affiliated third parties for any of the purposes set forth above. By way of example, we share your personal information with:

• Service providers (e.g., legal advisers, auditors, accountants, tax advisers, administrators, custodians, depositaries, brokerage firms, event organisers or other agents, advisers or service providers of any IAG Administered Fund or IAG Client). As is common in the industry, non-affiliated third party companies may from time to time be used to provide certain services, such as administration services, tax compliance services, reporting, account statements and other information, organising events, conducting research on client satisfaction and gathering shareholder proxies. These companies may have access to your personal information but are permitted to use the information solely to provide the specific service or as otherwise permitted by law.

• Other counterparties, including any vendor, any lender or any of their respective managers, general partners or investment advisers or administrators, or any of their respective agents or representatives or any affiliate of any of the foregoing.

• Any party to whom we are required to make disclosures in accordance with any applicable law or regulation.

Where your personal data is processed by third parties outside Guernsey, the UK and EEA, we will ensure appropriate safeguards are in place to protect it adequately, as required by applicable law, including the execution of standard contractual clauses (referred to above) if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission) or certified under the EU-US Privacy Shield framework.

Security

We take seriously our obligation to safeguard your non-public personal data. We maintain physical, electronic, and procedural safeguards to protect against unauthorised access to your data. We endeavour to restrict access to non-public personal information about you to those members, officers, employees and other workers of IAG and service providers who need access to that information. All of our employees and service providers are required to maintain the confidentiality of all non-public personal data.

Changes to this Notice

We may change this Notice from time to time. The latest version will be posted on our website.

Updating your details

If any of the information that you have provided to us changes, please let us know by sending an email to DataProtection@iag.co.gg

Your rights

You have certain rights relating to the personal data we hold in accordance with and subject to the Privacy Laws to: (i) check whether we hold personal data about you and to access such data (in accordance with our policy); (ii) request the correction of personal data about you that is inaccurate; (iii) have a copy of the personal data we hold about you provided to you or another controller where technically feasible; (iv) request the erasure of your personal data; and (v) request the restriction of processing concerning you. To do so, please send your request to DataProtection@iag.co.gg. We are required to ensure the personal data we hold about you is up-to-date and accurate and you must notify us of any changes to the personal data you provided to us. For example, you must advise us of changes to information supplied in relation to an investment in an applicable IAG Administered Fund. If you provided consent for us to use your personal data you have the right to withdraw consent and we will process this withdrawal promptly.

Data Retention

We retain your personal data for a period of at least six years from the date on which the relevant business relationship, for which purpose such personal data was provided, has ended (or if later the date on which the last transaction was completed or the last entry to the record was made). Thereafter, IAG will delete (or otherwise erase, de-identify, or anonymise) any such personal data except as required or permitted by applicable law or regulation.

What if I have a question?

Please email DataProtection@iag.co.gg if you have any questions about our privacy notice. You may also make a complaint, in accordance with applicable Privacy Laws to a supervisory authority. Our Guernsey supervisory authority is the office of the Data Protection Commissioner.

Cookies policy

IAG uses cookies on the www.iagfundservices.com website (the “Service”). By using the Service, you consent to the use of cookies. Our cookies policy explains what cookies are, how we use cookies, how third parties we may partner with may use cookies on the Service, your choices regarding cookies and further information about cookies.

What are cookies?
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third party to recognise you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

How we uses cookies
When you use and access the Service, we may place a number of cookies files in your web browser. We only use session cookies.

Analytics cookies
We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows) which helps to identify when our site isn’t working as it should for particular technologies, how long they spend on the site, what page they look at, etc. This helps us to continuously improve our website. These analytics programmes also tell us how people reached this site (e.g. from a search engine) and whether they have been here before. We use Google Analytics to collect website visitor statistics.

Third-party cookies
In addition to our own cookies, we may also use various third parties cookies’ to report usage statistics oN the Service.

What are your choices regarding cookies?
If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, and some of our pages might not display properly.

For the Chrome web browser, please visit this page from Google:

https://support.google.com/accounts/answer/32050

For the Internet Explorer web browser, please visit this page from Microsoft:

http://support.microsoft.com/kb/278835

For the Firefox web browser, please visit this page from Mozilla:

https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

For the Safari web browser, please visit this page from Apple:

https://support.apple.com/kb/PH21411?locale=en_US

For any other web browser, please visit your web browser’s official web pages.

Granting us permission to use cookies
If the settings on your software that you are using to view this website (your browser) are adjusted to accept cookies, we take this, and your continued use of our website, as acceptance of our use of cookies.

“IAG has been administrator to one of our funds for over 10 years. Their service is always flexible, accurate and speedy. I couldn’t fault them and would hire them again for a similar fund structure."
JAMIE BROOK, LOMBARD ODIER ASSET MANAGEMENT

#EXPERIENCETELLS

Learn More

SIGN UP TO EXPERIENCE

Want to hear more from us? We'll send you the latest news, updates, opinion and success stories from IAG.