Summit Asset Managers Limited

Transcription

1 Irish Infrastructure Trust Privacy Ntice Intrductin This ntice sets ut details f hw and why Summit Asset Managers Limited, f Beresfrd Curt,, Dublin 1, Ireland, acting n behalf the Irish Infrastructure Trust (the Cmpany, we, us, ur ) and third parties acting n ur behalf cllect and prcess persnal infrmatin in cnnectin with investments in Irish Infrastructure Trust (the Fund ). We d this in cmpliance with ur bligatins under applicable data prtectin law. This ntice explains what persnal data is cllected, the purpses fr which it is used, the third parties t whm it may be disclsed and hw individuals can exercise their rights in relatin t their persnal data. This ntice applies t the cllectin and prcessing f persnal infrmatin relating t any individual investr in the Fund and persnal infrmatin relating t individuals assciated with crprate investrs in the Fund, such as a crprate investr s directrs, sharehlders, emplyees, prfessinal advisers and ther persnnel. References t yu and yur mean the relevant individuals wh are the subjects f the persnal data t which this ntice relates and yur cmpany means a crprate investr with which an individual is assciated. Crprate investrs shuld ensure that this ntice is prvided t any individual whse persnal data the crprate investr has prvided t us, such as its directrs, sharehlders, emplyees, and ther persnnel, as sn as practicable. Abut Us The Cmpany is the cntrller f the persnal data cllected via the applicatin frm and in cnnectin with ur dealings with yu r yur cmpany in relatin t investments in the Fund. The Cmpany engages third party service prviders t prcess such persnal data n behalf f the Cmpany and thse third parties act as prcessrs. If yu have any questins abut the use f yur persnal data by r n behalf f the Fund, please cntact us at the abve address. Persnal Data that we Prcess We cllect persnal data relating t yu that is prvided t us in the applicatin frm and in cnnectin with ur dealings with yu r yur cmpany in relatin t investments in the Fund, including yur name, signature, pstal address, address, fax number, date f birth, and ther cntact details. We may als cllect persnal data in relatin t yu in cnnectin with ensuring cmpliance with ur legal bligatins including yur PPS number; passprt number; phtgraphic identificatin and verificatin such as cpies f yur passprt; and address verificatin. Fr the purpses f carrying ut due diligence, we may als cllect infrmatin relating t yur status as an ultimate beneficial wner f an entity, r as a plitically expsed persn. We may cllect and prcess persnal data relating t yu in cnnectin with ur n-ging relatinship with yu r yur cmpany, such as via crrespndence and calls, and in

2 cnnectin with ur administratin f yu r yur cmpany s investment in the Fund. We may recrd telephne calls fr the purpses f recrd keeping, security and training. In additin, we may cllect persnal data relating t yu frm third party surces in cnnectin with cmplying with legislatin relating t anti-mney laundering, taxatin, and ther legislatin applicable t investment funds. We require yu t cmplete the mandatry fields identified in ur applicatin frm fr the purpse f entering int a cntract with yu r yur cmpany. Please nte that sme f the infrmatin required by ur applicatin frm is necessary in rder fr us t administer yur r yur cmpany s investment in the Fund and if yu r yur cmpany d nt prvide us with these required details, we may decline yur r yur cmpany s applicatin t becme an investr. Please be advised that yu may be cntractually bliged t ensure that certain infrmatin that we hld relating t yu is up t date pursuant t the applicatin frm. Purpses f Prcessing and Legal Basis Persnal data that yu r yur cmpany prvides in yur applicatin frm, r that we therwise btain in relatin t yu, will be prcessed fr the fllwing purpses: prcessing yur r yur cmpany s applicatin t becme an investr; establishing yur identity, and prviding, servicing and administering yur r yur cmpany s investment; cmplying with ur legislative and regulatry bligatins in cnnectin with ur dealings with yu r yur cmpany, including under applicable law regarding antimney laundering, taxatin, the regulatin f cllective investment schemes, r the prvisin f financial services; fr direct marketing purpses, subject t any preferences yu cmmunicate t us; if applicable, prcessing the fact that yu are a plitically expsed persn, t cmply with applicable legal bligatins; t cmmunicate with yu by way f ntice pursuant t applicable legislatin r the Fund s Trust Deed; maintaining apprpriate business recrds, including maintaining apprpriate registers f unithlders; statistical analysis and market research; internal training and management f persnnel; t respnd t r evaluate any queries r cmplaints in relatin t yur r yur cmpany s investment; internal and external audits and, where necessary, investigatins; establishing, exercising r defending legal claims.

3 The legal grunds that we rely n t prcess yur persnal data are: that this is necessary t cmply with ur legal bligatins; that this is necessary fr the purpses f ur legitimate interests r the legitimate interests f a third party t whm we prvide yur persnal data. We will nt prcess yur persnal data fr these purpses if ur r the third party s legitimate interests shuld be verridden by yur wn interests r fundamental rights and freedms. The legitimate interests pursued by us in this regard include: cnducting ur business in a respnsible and cmmercially prudent manner and dealing with any disputes that may arise; preventing, investigating r detecting theft, fraud r ther criminal activity; pursuing ur crprate and scial respnsibility bjectives; where yu are an individual investr, that this is necessary t take steps at yur request prir t entering int ur cntract with yu and fr the perfrmance f ur cntract with yu. Recipients f Data We may disclse yur persnal data t varius recipients in cnnectin with the abve purpses, including: t the Administratr; t Irish Life Investment Managers Limited, the Fund s investment manager; AMP Capital Investrs (UK) Limited, the Funds investment manager; t the Fund s distributr(s); t the Fund s Mney Laundering Reprting Officer; t the Revenue Cmmissiners and ther tax authrities as required by applicable law, including FATCA r CRS; t the Central Bank f Ireland, auditrs, r ther cmpetent regulatry authrities and bdies as requested r required by law; t ther third parties wh we engage t prvide services t us, such as prfessinal advisers, auditrs and IT service prviders; t credit reference agencies in rder t carry ut mney laundering and identity checks and t cmply with legal bligatins; t ther members f ur crprate grup.

4 Transfers Abrad In cnnectin with the abve purpses we may transfer yur persnal data utside the Eurpean Ecnmic Area, including t a jurisdictin which is nt recgnised by the Eurpean Cmmissin as prviding fr an equivalent level f prtectin fr persnal data as is prvided fr in the Eurpean Unin. If and t the extent that we d s, we will ensure that apprpriate measures are in place t cmply with ur bligatins under applicable law gverning such transfers, which may include: (a) entering int a cntract gverning the transfer which cntains the standard cntractual clauses apprved fr this purpse by the Eurpean Cmmissin; (b) in respect f transfers t the United States f America, ensuring that the transfer is cvered by the EU-US Privacy Shield framewrk; r (c) transferring yur persnal data pursuant t binding crprate rules. Further details f the measures that we have taken in this regard and the territries t which yur persnal data may be transferred are available by cntacting us at ur address set ut at the beginning f this ntice Retentin We will retain yur persnal data fr the duratin f yur r yur cmpany s investment in the Fund and fr such a perid f time after the investment ends as is necessary t cmply with ur bligatins under applicable law and, if relevant, t deal with any claim r dispute that might arise. Yur Rights Yu have the fllwing rights, in certain circumstances and subject t applicable exemptins, in relatin t yur persnal data: the right t access the persnal data that we hld abut yu, tgether with ther infrmatin abut ur prcessing f that persnal data; the right t require us t rectify any inaccuracies in yur persnal data; the right t require us t erase yur persnal data; the right t request that we n lnger prcess yur persnal data fr particular purpses; the right t bject t ur use f yur persnal data r the way in which we prcess it; and where the legal basis fr prcessing is that it is necessary fr the perfrmance f a cntract with yu, the right t receive yur persnal data, which yu prvided t us, in a structured, cmmnly used and machine-readable frmat r t require us t transmit that data t anther cntrller. In rder t exercise any f the rights set ut abve, please cntact us at the address set ut at the beginning f this ntice.

5 Cmplaints If yu are nt happy with the way we have used yur infrmatin r addressed yur rights, yu have the right t ldge a cmplaint with the Irish Data Prtectin Cmmissin (inf@dataprtectin.ie) r yur lcal supervisry authrity. Directrs: Gerry Keenan (Chairman) Patrick Burke Alisn Letters Jhn O Cnnell Clm O Neill Frank O Rirdan Registered Office: Dublin 1 Registered in Ireland number Summit Asset Managers is regulated by the Central Bank f Ireland