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 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. | YES | Ireland, 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. | YES | United States. Data centers are located in the Netherlands, France and Germany. |
| Provision of Office 365 and Exchange Online. | Ireland | All client data exchanged via email. | YES | Data 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). | YES | Spain, 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...) | YES | United Kingdom, Switzerland, France, India, Poland, United States. |
| Tool providing identification verification during the onboarding of investors. | France | Identification verification data of investors. | YES | European Union including Romania, France, Germany. |
| Provision of audit services. | Luxembourg | All client data. | YES | European Economic Area |
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 |
| Tessian Limited | Solution 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 betweenthe Company and the clients. | Clients' phone numbers | Luxembourg | As long as the 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. | 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 Kingdom | As long as the client is a client of the Company. |
