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Investors and Related Parties
Where the ICAV needs to process Personal Data in connection with a registered shareholder’s contract with the ICAV or in anticipation of an applicant for shares becoming a registered shareholder, or where the ICAV has a legal obligation to collect certain Personal Data relating to an Individual (for example, in order to comply with AML obligations), the ICAV will not be able to deal with the registered shareholder or applicant for shares if the Individual does not provide the necessary Personal Data and other information required by the ICAV.
Personal Data means any information which the ICAV has or obtains, or which an Individual provides to the ICAV or the ICAV’s service providers, such as his / her name, address, email address, date of birth etc, from which that Individual can be directly or indirectly personally identified, and may include information such as identification and account numbers, tax identifiers and residency information, and online identifiers. Some of this Personal Data may be sensitive Personal Data, such as data revealing racial or ethnic origin, political opinions, or trade union membership (“Sensitive Personal Data”).
Use of Personal Data and Basis of Processing
The ICAV will use the Personal Data:
1、for the purposes of performing the contract with a registered shareholder, or in anticipation of an applicant for shares becoming a registered shareholder, namely:
a、for the purposes of providing services to the registered shareholder, and setting up and administering the applicant’s or registered shareholder’s account(s), as the case may be;
b、for the collection of subscriptions and payment of redemptions, distributions and dividends;
2、for compliance with the ICAV’s legal obligations, including:
a、anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes, including OFAC and PEP screening for these purposes and to comply with UN, EU and other applicable sanctions regimes;
b、compliance with applicable tax and regulatory reporting obligations;
Recipient of the Personal Data
In any case where the ICAV shares Personal Data with a third party data controller (including, as appropriate the ICAV’s service providers), the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
Last updated September 2018