Privacy notice

You have the following rights:

• To obtain access to, and copies of, the personal data that we hold about you;
• To require that we cease processing your personal data if the processing is causing you damage or distress;
• To require us not to send you direct marketing communications;
• To require us to erase your personal data;
• To require us to restrict our data processing activities;
• To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• To require us to correct the personal data we hold about you if it is incorrect.

The above rights are not absolute, and we may be entitled to refuse requests where exceptions apply. If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Privacy Officer.

Your personal data may be processed by the Administrator (or any of their affiliates, agents, employees, delegates or sub-contractors) for the following purposes:

• To facilitate the management and administration of your holdings in SFFPL and any related account on an on-going basis which is necessary, including without limitation the processing of redemption, conversion, transfer and additional subscription or investment requests and the payment of dividends;
• In order to carry out anti-money laundering checks and related actions which the Administrator considers appropriate to meet any legal obligations imposed on the Administrator, or relating to processing in the public interest or to pursue the Administrator’s legitimate interests in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with the Administrator's anti-money laundering procedures;
• To report tax related information to tax authorities in order to comply with a legal obligation;
• To disclose information to other third parties such as service providers, auditors, regulatory authorities and technology providers in order to comply with any legal obligation imposed on the Administrator or in order to pursue the legitimate interests of the Administrator.

The Administrator may collect the following types of personal data about you:

• Your name, date of birth, passport or national identity card details;
• Country of birth, domicile and citizenship;
• Information such as residential or business address, email address and telephone number and your bank account details;
• Biometric data such as CCTV images when you visit our offices;
• Gender, marital status;
• Information relating to your tax affairs including your tax status and tax identification number;
• Information to assess whether you may represent a money laundering or terrorist financing risk, for example, whether you are a Politically Exposed Person, or have had previous criminal convictions or regulatory sanctions imposed and your source of wealth.

The Administrator may collect your personal data in a number of ways, for example:

• From the information you provide to us when you meet with us, from an employee or employees of one of our Group companies;
• When you communicate with us or when we communicate with you by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
• When you or your agent complete or we complete on your behalf application or other forms;
• From intermediaries, your agents, or advisers and individuals in any organisation with which you are associated;
• From publicly available sources or from third parties where we need to conduct background checks about you.

In order to facilitate, manage and administer your holdings we may need to transfer your personal information to other Group companies located in Switzerland, Israel, Jersey, Liechtenstein, Luxembourg, Guernsey, Malta, the Isle of Man, the United Kingdom and Canada, which provide an adequate level of protection for your personal data.

We may also need to share your personal data with Group companies located in the United States of America, South Africa, Monaco and Mauritius, which do not provide an adequate level of protection for your personal data. Where we share your data with a Group company in a non-adequate jurisdiction we will meet our obligations under privacy law by using Standard Contractual Clauses, as a safeguard, or will do so with your explicit consent.

The Administrator may also disclose your data to competent authorities (including tax authorities), courts and bodies as required by law, or to banks and other relevant third parties where requested to do so, or to affiliates for internal investigations and reporting.

Please contact our Privacy Officer should you wish to receive details about how your data has been shared.

The Administrator retains your personal data for a period of 10 years after your holdings ends in order to meet our regulatory and legal obligations. This does not impact any other ongoing relationships you may have with other members of the Stonehage Fleming Group.

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact our Privacy Officer using any of the following: ‒

By post - No 2, The Forum, Grenville Street, St Helier, Jersey, JE1 4HH Channel Islands.

By email - jerseyprivacyofficer@stonehagefleming.com

By telephone - +44 1534 823 109

Version: 4 October 2023