Access to Client Data

Data transfer for outsourcing and sub-outsourcing purposes

Purpose of client data sharingCountry of establishment of the outsourcing service provider Type of information transmitted Sub-OutsourcingLocation of sub-outsourcing(s) 
Provision of services for managing the investors’ lifecycle journey of fund Clients.IrelandAll fund investor Client data (from onboarding to offboarding, including KYC information).YESEuropean Union, Canada, United States, Singapore, Australia. Data centers are located in the European Union.
Provision of solutions for fund administration services (including transfer agent and fund administration).  United StatesAll Client data related to fund investment (including register, accounting, etc.)YESEuropean Union, United Kingdom, Switzerland, India, United States, the Philippines. 
Provision of audit services.LuxembourgAll Client dataYESEuropean Union
Provision of Data Protection Officer function.LuxembourgAll Client dataNON/A
Provision of IT tool automating the preparation of annual accounts.CanadaAll Client data relating to Client accounting services.YESEuropean Union, United States, Canada.
Provision of IT tool to assist in the performance of ML / TF / PF risk assessments of funds and/or AIFMs for ClientsLuxembourgName of Client and AML / CFT / CPF framework related dataYESEuropean Union
Provision of IT tool automating the completion of documents / templatesDenmarkAll Client dataYESEuropean Union
Provision of IT tool for the preparation and management of board meeting packs.United KingdomAll Client data contained in board packsYESEuropean Union, United Kingdom, United States
Provision of electronic signature solution.FranceClient data linked to signatories’ detailsYESEuropean Union, United Kingdom
Provision of AI-powered tool for the automation of board meetings minuting (BriefAI).United KingdomAll Client data discussed during board meetingsYESEuropean Union
Provision of AI-powered tool for legal research, contract review, document drafting and process automation.SwedenAll Client dataYESEuropean Union / European Economic Area

Data transfer other than for outsourcing and sub-outsourcing purposes

Service Provider Purpose of client data sharingType of information transmitted Country of establishment of the service provider Duration of client data sharing
Arendt & MedernachProvision of legal expertise.Client data, if required to provide legal expertise.European UnionAs long as Client is a Client of the Company.
Factiva Limited –
Dow Jones
Platform for global news and data monitoring.Information on Clients and/or entities and individuals linked to Clients, if enhanced screening is required.United KingdomAs long as Client is a Client of the Company.

Version of 30.05.2026