Data Protection Policy

The personal data that we collect

We collect only the personal data that we need. If you choose not to provide the information that we need, we may not be able to accomplish our tasks in full, and that could have an impact on the service or product that we provide to you.

We collect personal data when you contact us through one of our off-line channels (e.g., request forms, telephone and e-mail) or when you use our website or any other online services that we make available to you.

Apart from managing our financial and investment products, we also collect personal data in the course of carrying out other activities, for example, if you:

• work with us as a supplier or service provider;
• take part in our request for proposal (RFP) process to bid on new projects;
• visit one of our offices or register to attend event that we organise or sponsor;
• are presented by third parties for legitimate marketing needs; or
• take part in a competition that we organise or sponsor.

We may also have occasion to request these personal data from persons authorised to act in your name.

Although most personal data that we collect cover the person subscribing to a product (or persons subscribing jointly), we may need to obtain information on third parties.
Some current examples:

• we may need to collect personal data from third parties authorised to act on behalf of a client. These could be an attorney or (in the case of a legal entity) other persons who work for this investor or who are otherwise authorised to represent the investor in any manner whatsoever;
• for property investments, we collect information on the owner of the property that we plan to acquire, particularly for the purpose of meeting our obligations in the area of combatting money laundering; we also collect data on the person(s) to whom this property is rented or who lives at the property (or, when the tenant is an organisation, on the key members of said organisation, such as its board directors or partners);
• when we make financial products available to a borrower, we may have to collect personal data on them. When financial products are made available to an organisation, we may have to collect data of a personal nature on the key members of said organisation, such as its directors, shareholders, partners and/or beneficial owners, as well as information on its managing partners, where applicable;
• when we establish relations with suppliers, it is also possible that we will collect personal data on their directors, shareholders and/or beneficial owners, as well as information on its managing partners, where applicable.

If you provide data of a personal nature on a third party, you must notify said third party formally and make sure that said third party is satisfied with the data provided to our company.

We treat such personal data in accordance with this Data Protection Policy. We therefore ask you to encourage the persons concerned to read this Policy if they wish to know more.

Personal data collected through intermediaries and third parties

Many clients invest in our products through a financial advisor or one of our distribution partners and, in doing so, they may provide us with personal data on this client. Other third parties (attorneys, fiduciaries, family members, etc.) may also disclose to us data of a personal nature. It is their responsibility to notify the person whose data are being shared that such data is being provided to us and to request their permission, if necessary.

Depending on the product, we may also disclose your data of a personal nature to the financial advisor who helped you to invest in our products or who is a stakeholder in your investment.

Transfer of data to organisations with which we work

We sometimes transfer data of a personal nature to trusted third parties who work with us in distributing our products and services, or to meet our legal and regulatory obligations, in particular:

• distribution partners and transfer agents who help us organise and administer our products;
• the attorneys and professional service firms who help us conduct due diligence in organising our products and who provide us with legal support regarding our products or in the event of litigation;
• suppliers of internal and external services, who support our information systems, real-estate management, marketing or other operating processes;
• fraud-prevention bodies to make checks of identity, detect and prevent fraud and combat financial crime;
• regulatory bodies that govern the manner in which we conduct our operations;
• investment exchanges, settlement systems and banks, clearinghouses and central counterparties? and securities custodians;
• providers of banking services, suppliers of systems and payment processing services, messaging services and correspondent services;
• suppliers of data and information pertaining to prices of units, securities and investments, exchange rates, interest rates and corporate actions, data on revenue and income and credit ratings.

To find out more about the transfer of your personal data, you may contact us through the procedures presented in this policy.

Use of these personal data to improve our products and services

We collect information through cookies and other similar technologies (for example, web beacons or links) when you visit our website. These tools are used either by ourselves or by third-party service suppliers, or by both at the same time, in order to improve our products and services, as well as their operations and performances, but also to make advertising more relevant. For example, we use some of these tools so you will not have to input your details each time you visit our website. This allows us to offer our services in the language you prefer.

We may also collect information on your use of other websites in order to provide advertising that, in our view, could be relevant to you, as well as to improve our own products and services, not to mention the operations and performances of our site Internet.

To find out more about these technologies and on the way in which we use the parameters of your browser to manage your confidentiality settings, refer to our Cookie policy.

When you invest directly in our product as an individual

In this case, we collect your details, data pertaining to your identity and payment details. We need such information to organise and administer your investment and your account with our company. We also need such information to verify your identity and prevent fraud. We collect such information when you request us to do so by filling out and submitting the form that can be downloaded from our website or emailed upon request.
Depending on the type of investment that you wish to make, we may need additional data, such as the origin of the assets or funds, so that we are in compliance with regulatory anti-money laundering controls. Administering your investment product requires providing you with constant service, accompanying you when you wish to make additional investments, making changes to our current investments or replying to any questions you may have regarding your existing investments. Please keep in mind that we do not collect, use, or transfer information pertaining to clients of the investment platform. Investment suppliers and platforms are responsible for processing all data of a personal nature that you submit. If you are a client with one of these suppliers or platforms, please refer to their Data Protection Policy or any equivalent document.

Important disclosures

This involves disclosing your data of a personal nature to credit agencies that conduct research on you on our behalf. We work with fraud-prevention bodies and reputable credit agencies to detect and prevent fraudulent practices and combat financial crime, in order to comply with our regulatory responsibilities. To find out more, refer to the section on credit agencies and fraud-prevention bodies.

When you invest in our product as an institutional or wholesale client

On this case, we collect identity details and data on attorneys, board directors, partners, authorised signatories, beneficial owners and other relevant contacts within your organisation who are authorised to represent you, in order to establish a relationship with you. We also collect information on your organisation, such as its commercial name, its employee headcount and the nature of its business. We collect such information in order to manage your investment product. We also use such information to conduct KYC (Know Your Customer) checks required by anti-money-laundering (AML) regulatory inspections and to prevent fraud.

Important disclosures

This entails disclosing data of a personal nature provided to credit agencies that conduct research on our behalf. We work with fraud-prevention bodies and reputable credit agencies to detect and prevent fraudulent practices and to combat financial crime in order to comply with our regulatory responsibilities. To find out more, refer to the sector regarding credit agencies and fraud-prevention bodies.

When you interact with us as a broker or financial advisor

In this case, we collect identity details, data, and professional information from you and key members of your organisation. We do so whenever any account is opened by an advisor or broker, in order to continue to operate said account, and to organise and manage your client’s investments. To conduct KYC (Know Your Customer) checks required by anti-money-laundering (AML) regulatory inspections and to prevent any fraud, we check your identity as a broker or financial advisor and the identity of key members of your organisation, such as board directors and/or partners. In the course of our contacts, you may be required to provide data of a personal nature that you present to us. It is your responsibility: (ii) to collect such information in a legal manner; and (ii) to ensure that the disclosure of such data of a personal nature is authorised.

Important disclosures

We use the personal and professional data that you have provided, as well as information that we have obtained from other sources, such as credit agencies. This entails the disclosure of data of a personal nature provided to the credit agencies that conduct research on our behalf. We work with fraud-prevention bodies and reputable credit agencies to detect and prevent fraudulent practices and combat financial crime, in order to comply with our regulatory responsibilities. To find out more, refer to the section on credit agencies and fraud-prevention bodies.