Access to Client Data
Data transfer for outsourcing and sub-outsourcing purposes
| Purpose of client data sharing | Country of establishment of the outsourcing service provider | Type of information transmitted | Sub-Outsourcing | Location of sub-outsourcing(s) |
| Provision of services for managing the investors’ lifecycle journey of fund Clients. | Ireland | All fund investor Client data (from onboarding to offboarding, including KYC information). | YES | European 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 States | All Client data related to fund investment (including register, accounting, etc.) | YES | European Union, United Kingdom, Switzerland, India, United States, the Philippines. |
| Provision of audit services. | Luxembourg | All Client data | YES | European Union |
| Provision of Data Protection Officer function. | Luxembourg | All Client data | NO | N/A |
| Provision of IT tool automating the preparation of annual accounts. | Canada | All Client data relating to Client accounting services. | YES | European 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 Clients | Luxembourg | Name of Client and AML / CFT / CPF framework related data | YES | European Union |
| Provision of IT tool automating the completion of documents / templates | Denmark | All Client data | YES | European Union |
Data transfer other than for outsourcing and sub-outsourcing purposes
| Service Provider | Purpose of client data sharing | Type of information transmitted | Country of establishment of the service provider | Duration of client data sharing |
| Arendt & Medernach | Provision of legal expertise. | Client data, if required to provide legal expertise. | European Union | As long as Client is a Client of the Company. |
| Refinitiv Limited | Database of politically exposed persons and heightened risk individuals and organizations, used to identify and manage financial, regulatory and reputational risk. | Information on Clients’ identity for KYC screening. | European Union United Kingdom | As long as Client is a Client of the Company. |
Version of 30.05.2026