International Financial Data Services (“IFDS” or “we” or “us/our”) is committed to handling your personal data (“Personal Data”) responsibly and transparently. This Privacy Notice is intended to comply with the transparency requirements under the General Data Protection Regulation 2016/679 (EU GDPR) and applicable data protection laws in the jurisdictions in which we operate. It explains how IFDS processes your Personal Data in connection with your relationship with us. The Notice applies to any Personal Data we may collect from you through our employment and job application process, provision of services and products, via our website and relevant applications or when you otherwise interact with us as described below.

If you wish to contact the IFDS entity that is data controller for the service relevant to you, please refer to the section How to exercise your rights or contact us.

Please note we may amend this Notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please check these pages regularly for the latest version of this Notice.

We may collect the following Personal Data information:

• Identity Information such as first name, middle name, last name, marital status, title, date of birth, gender, national identification number (such as ID card, passport, social security or driver licence number), signature, or other identifiers.
• Contact information including billing address, email address or telephone numbers
• Demographic information such as postcode, age, race, national origin, citizenship, marital status, sex (including gender), preferences, and interests
• Professional or employment-related information such as education, current employment and employment history.
• Contractual information collected as part of the products and services we provide to you or interactions with you as service provider.
• Financial information such as bank account details
• Other information relevant to customer surveys and/or offers

We collect your Personal Data in a variety of ways and from various sources. For example, we may collect your Personal Data:

• Through direct interactions with you, in person, when you call, mail or email us or fill out a form;
• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they have engaged us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients while providing services to them.
• From affiliates and third party service providers acting on our behalf in connection with the services we perform.
• From publicly available sources, including social media, to the extent that you manifestly choose to make your profile publicly visible.
• Directly and indirectly from activity on our websites. For example, from submissions through our website or website usage details collected automatically.
• From automated technologies or interactions that collect technical data about your equipment, browsing actions and patterns. This information is collected by using cookies, server logs or other similar technologies.

The Personal Data that we collect from you may include sensitive Personal Data. Sensitive Personal Data are categories of information requiring a higher level of protection under the GDPR. It may include, but is not limited to, racial or ethnic origin; political opinions; religious, philosophical, or other similar beliefs; membership of a trade union or profession or trade association; physical or mental health; biometric data; or sexual orientation. 

We do not collect, use, share or otherwise process sensitive Personal Data or criminal records unless permitted to do so by law. For example, we may collect, use, share or otherwise process your sensitive Personal Data or criminal records to perform Know Your Customer (KYC) checks in order to comply with applicable Anti-Money Laundering (AML) laws.

We use Personal Data for the following purposes:

• To fulfil our contractual obligations. For example, to open, manage and administer your account in relation to services for which clients have engaged us, for employment or job applications related purposes.
• To comply with our legal obligations, for example for record keeping or record retention purposes, for reporting to tax authorities, to perform KYC checks to comply with applicable AML laws or to prevent and detect fraud or financial crime. In certain jurisdictions, IFDS may have a regulatory obligation to retain client and Fund investor data following termination of contractual services with Management Companies. It is IFDS policy to put such data beyond use at the earliest possible opportunity until the expiry of the period to which the legal obligation applies. The rights outlined below are not applicable to data which has been put beyond use.
• For purposes for which you have provided your consent.
• For purposes that are compatible with the original purpose as was described to you at the time of collection.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• For our legitimate interest, as a commercial organization, provided our use is proportionate and respects your privacy rights. Such legitimate interests may, for example, include:
– To provide you with information on products or services that you request from us.
– To enforce our rights arising from any contracts entered between us, including for billing purposes.
– To operate our business in a prudent manner in accordance with industry standards and compliance with legal or regulatory obligations, which may include, monitoring and recording calls and electronic communications for processing and verification of instructions, responding to inquiries, investigation and fraud prevention purposes, crime detection, prevention, investigation and prosecution purposes, for governance purposes and to obtain advice from our advisors.

If you do not provide us with your Personal Data when requested, it may prevent us from being able to carry out the above tasks.

We adopt appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on our Site. We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Sensitive and private data exchange between the Site and the User (you) happens over an SSL secured communication channel and is encrypted and protected with digital signatures.

We may disclose your Personal Data to our affiliates, service providers with whom we have contracted to perform services on our behalf, and other third parties to whom you or your representatives have authorized us to disclose your Personal Data for our business purposes or other services that we provide to you. When we do so, we will make sure that your Personal Data is used in a manner consistent with this notice, or enter into a contract that describes the business purpose and requires the recipient to keep that Personal Data confidential and not use it for any purpose except for performing the contract.

We may also use or disclose your Personal Data:

• To regulators, government agencies or law enforcement authorities.
• If we are required to do so by law or if we reasonably believe that such disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity,
• When disclosure is necessary to protect our rights or to comply with a judicial or regulatory requirement or to pursue our legitimate interest or the vital interests of a person.

As part of the IFDS global operating model, we may share some of your Personal Data, with the entities (including our affiliates and our service providers) which are located/operating outside of the jurisdiction in which the Personal Data was collected. Your Personal Data may be transferred, stored, and processed outside the country of origin. For such transfers, we have the relevant legal safeguards in place, including (for example) contractual arrangements based on sets of standard contractual clauses that have been pre-approved by the European Commission (or otherwise consistent with the requirements of the relevant jurisdiction) to ensure adequate protection, or in certain circumstances we may rely on one of the exceptions under GDPR that allows us to perform these transfers. This reflects our commitment to protecting your Personal Data regardless of where your Personal Data resides. Personal Data stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.

We do not sell, trade, or rent your personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding your visit with our business partners, trusted affiliates, and advertisers for the purposes outlined above.

We are committed to protecting the security of your Personal Data. We use reasonable technical and organization measures, in compliance with applicable law, to protect your Personal Data from unauthorized access, unlawful processing and against accidental loss, destruction or damage.

We will retain your Personal Data for as long as necessary to fulfil the purpose for which it was collected, such as providing our services, or as required by applicable laws or regulations. This period may extend beyond the termination of our relationship with you. We retain clients and their investors’ Personal Data for 10 years for Luxembourg and 7 years for Ireland following termination of our contractual relationships. We retain terminated Luxembourg employees’ Personal Data for 10 years and retain Ireland employees’ Personal Data for 8 years for Ireland following termination of the employment contractual relationship. For candidates who are unsuccessful in their job applications at IFDS, their Personal Data will be retained for 12 months, such period may be extended to allow reasonable time to process deletion.

Depending on the jurisdiction, and subject to certain exceptions, you may have specific rights regarding your Personal Data. This section describes such rights and how you may exercise them.

• Access to your Personal Data

You have the right to request that we disclose certain information to you how we use your Personal Data. Once we receive and verify your request, we will disclose to you (depending on your request or unless an exception applies):

– The categories of Personal Data we have collected about you.
– The categories of sources from where the Personal Data was collected.
– Our purpose for collecting or sharing your Personal Data.
– The categories of third parties with whom we share your Personal Data.
– The specific pieces of Personal Data we have collected about you.
– Where specifically required, we will provide specific pieces of Personal Data we have collected about you in a structure, commonly used or in machine-readable format, and to have it transmitted directly to another person or entity (data portability).

• Request that your Personal Data be rectified where it is inaccurate or incomplete

• Request that your Personal Data be rectified where it is inaccurate or incomplete

• Request restriction or object to the processing of your Personal Data for certain circumstances

• Lodge a complaint with your local data protection authority

• Withdraw your consent

If we are relying on your consent to use or share your Personal Data, you have the right to fully or partially withdraw your consent, subject to certain exceptions defined in applicable laws and regulations. Please note however that this will not affect the lawfulness of the processing before its withdrawal. 

If you wish to exercise your rights under GDPR, or have questions about how your Personal Data is processed, please contact our Data Protection Office as follows:

International Financial Data Services (Luxembourg) S.A.
Data Protection Office
IFDS_DPO@StateStreet.com

International Financial Data Services (Ireland) Limited
Data Protection Office
IFDS Ireland_DPO@StateStreet.com

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Our Site may use cookies to enhance your experience. Your web browser places cookies on your hard drive for record-keeping purposes and sometimes to track information about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

The table below explains the cookies we use and why.

Most web browsers allow some control of cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org (opens in a new window).

You may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Permission to print and copy documents or graphics from this Site is granted for personal and non-commercial use only and is expressly conditional upon your agreement that all prints or copies shall contain or refer to the copyright or proprietary notices in the IFDS web site. The format and contents of the information shall not be altered in any way, and you will indemnify IFDS for damages and expenses, including attorneys’ fees, it incurs related to your use of such materials and your breach of these requirements. No permission is granted to print and copy documents created by the parties other than IFDS and appearing on this web site, unless so indicated and subject to the restrictions indicated.

IFDS makes no representations and hereby disclaims all warranties, expressed or implied, as to the timeliness, accuracy, completeness, or suitability for any purpose of the information contained in the documents and related graphics published by IFDS, its web site or elsewhere on the Internet. The IFDS web site and all such information are provided as is, as available. The information on the web site shall not constitute any representation, warranty, or other commitment by IFDS or any of its affiliates with respect to any of the products or services described.

In no event shall IFDS be liable for any damages whatsoever, whether actual, special, incidental, direct, indirect, punitive, exemplary, or consequential arising out of the use of the web site or any of the information or materials contained therein or accessible there from, including without limitation loss of profits or data, or the risks of the stock market.

Should any user of the web site or viewer of documents or graphics copied or printed there communicate with IFDS about the web site, or the documents, graphics or information contained therein, IFDS shall have no obligation of any kind with respect to such communication, which shall be deemed non-confidential, and IFDS shall be free to use and distribute the information contained in such communication for any purpose whatsoever, unless IFDS and the party responding otherwise agree in writing.

Unless otherwise stated, copyrights and all similar rights in all material presented on the IFDS web site, including graphical images, are owned by IFDS. Publication of materials on the web site does not constitute the placing of such materials in the public domain.

No license, assignment, or permission is granted herein, expressly, implicitly, or otherwise to use any trade name, trademark, or service mark of IFDS or of any other party.

References on this web site, or links to or from this web site to mutual funds/variable annuities, financial advisors, or any other entity which may offer securities or other investments for sale do not constitute any offer to sell any such securities or investments, nor do such links constitute any endorsement, referral or other recommendation of any kind.

By using this Site, you accept to comply with and be bound by this Notice and terms of service. If you do not agree with any part of this Notice and/or terms of service, please do not use our Site. Your continued use of the Site following the posting of changes to this Notice will be deemed your acceptance of those changes.

If you have any questions about this Privacy Notice, the practices of this Site, or your dealings with this Site, please contact us.

Last review date: March 2024