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.
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
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.
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.
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