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 Information Technology services.	Luxembourg	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.