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 an application to support services to be rendered for board meetings.United Kingdom All client data contained in board packs and information in the client’s account to access the application.YESIreland, United Kingdom, United States
Tool providing for simplified and qualified electronic signature.France Information contained in contractual agreements with clients and the clients’ identification verification data.YESUnited States. Data centers are located in the Netherlands, France and Germany.
Provision of Office 365 and Exchange Online.IrelandAll client data exchanged via email.YESData centers are located in Ireland and the Netherlands.
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).YESSpain, Poland, Canada, United States, Singapore, Australia. Data centers are located in Ireland and Germany.
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…)YESUnited Kingdom, Switzerland, France, India, Poland, United States, Ireland, the Netherlands, the Philippines.
Provision of audit services.LuxembourgAll client data.YESEuropean 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
Tessian LimitedSolution to prevent accidental data loss caused by misdirected emails and misattached files on emails, preventing client data breaches.The service provider will scan through emails, accessing client data contained in emails, including, but not limited to, recipients’ names, document file names, content of the email.United Kingdom  As long as the client is a client of the Company.
Post Telecom S.A.Provide a professional mobile plan, allowing communication between the Company and the clients.Clients’ phone numbers Luxembourg As long as the client is a client of the Company.
Refinitiv LimitedDatabase 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. Luxembourg
United Kingdom  		As long as the client is a client of the Company.
Cleversoft FCCS S.A.KYC database used for daily identification of the clients and to manage financial, regulatory and reputational risk.Information on the clients’ identity for KYC screening.  Luxembourg As long as the client is a client of the Company.
Moody’s Analytics UK Ltd Provide near real-time interface (API) to the commercial registries of a large number of jurisdictions, to facilitate and expedite the collection of companies’ identification documents.Information on clients’ identification. United KingdomAs long as the client is a client of the Company.