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, Ireland, the Netherlands, the Philippines.
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 between the 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.