We believe that privacy is important to all of our Investors and we are committed to maintaining the confidentiality and security of our Investors’ information. Therefore, we shall protect information about our Investors by maintaining physical, electronic and procedural safeguards that meet or exceed those required by law.
- All CBIS employees may have a need to know this information to provide services to our Investors and therefore will have access to this information.
- We shall not disclose information about our Investors to external organizations unless authorized by our Investors, required by law or necessary to provide our services to our Investors.
- We shall not sell information about our Investors to anyone.
- We shall treat information about former Investors in the same manner we treat information about current Investors.
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Data Protection Notice
Investors should note that by completing the application form they have provided personal information, which may constitute “personal data” within the meaning of the Irish Data Protection Acts 1988 and 2003, the EU Data Protection Directive 95/46/EC, the EU ePrivacy Directive 2002/58/EC (as amended) and any relevant transposition of, or successor or replacement to, those laws (including, when they come into force, the General Data Protection Regulation (Regulation (EU) 2016/679) and the successor to the ePrivacy Directive) (together, the “Data ProtectionLegislation”).
Investors’ personal data will be used by CBIS, CBIS Global Funds plc, and/or CUIT for the following purposes:
- to manage and administer an investor’s holding in any of the Funds managed by CBIS, CBIS Global Funds plc, and/or CUIT and any related accounts on an ongoing basis;
- to carry out statistical analysis and market research as CBIS, CBIS Global Funds, and/or CUIT’s legitimate business interest;
- to comply with legal and regulatory obligations applicable to the investor and CBIS from time to time including applicable anti-money laundering and counter terrorist financing legislation. In particular, in order to comply with the information reporting regimes set out in Section 891C and Section 891E to Section 891G (inclusive) of the Taxes Consolidation Act 1997 (as amended) and regulations made pursuant to those sections), Shareholders’ personal data (including financial information) may be shared with the Irish Revenue Commissioners. They in turn may exchange information (including personal data and financial information) with foreign tax authorities (including the U.S. Internal Revenue Service and foreign tax authorities located outside the European Economic Area). Please consult the AEOI (Automatic Exchange of Information) webpage on www.revenue.ie for further information in this regard; and
- for any other specific purposes where the investor has given specific consent.
Investors’ personal data may be disclosed by the CBIS, CBIS Global Funds plc, and/or CUIT to its delegates, professional advisors, service providers, regulatory bodies, auditors, technology providers and any duly authorised agents or related, associated or affiliated companies of the foregoing for the same or related purposes.
Investors’ personal data may be transferred to countries which may not have the same or equivalent data protection laws as the EEA. If such transfer occurs, the Company is required to ensure that such processing of investors’ personal data is in compliance with Data Protection Legislation and, in particular, that appropriate measures are in place such as entering into model contractual clauses (as published by the European Commission) or ensuring that the recipient is “Privacy Shield” certified, if appropriate. For more information on the means of transfer of investors’ data or a copy of the relevant safeguards, please contact [email protected].
Pursuant to the Data Protection Legislation, investors have a number of rights which may be exercised in respect of their personal data, i.e.:
- the right of access to personal data held by CBIS, CBIS Global Funds plc, and/or CUIT;
- the right to amend and rectify any inaccuracies in personal data held by CBIS, CBIS Global Funds plc, and/or CUIT;
- the right to erase personal data held by CBIS, CBIS Global Funds plc, and/or CUIT;
- the right to data portability of personal data held by CBIS, CBIS Global Funds plc, and/or CUIT; and
- the right to request restriction of the processing of personal data held by CBIS, CBIS Global Funds plc, and/or CUIT; and
- the right to object to processing of personal data by CBIS, CBIS Global Funds plc, and/or CUIT.
These rights will be exercisable subject to limitations as provided for in the Data Protection Legislation. In certain circumstances it may not be feasible for the Company to discharge these rights, for example because of the structure of CBIS, CBIS Global Funds plc, and/or CUIT or the manner in which the Shareholder holds Shares in a Fund. Investors may make a request to the Company to exercise these rights by contacting [email protected].
Please note that personal data may be retained by CBIS, CBIS Global Funds plc, CUIT, the Administrator, the Transfer Agent, the Investment Manager, the Custodian, the Depositary and/or their agents for the duration of an investor’s investment and afterwards in accordance with the Company’s legal and regulatory obligations, including but not limited to the Company’s record retention policy.
The CBIS, CBIS Global Funds plc, and/or CUIT are data controllers within the meaning of the Data Protection Legislation and undertakes to hold any personal information provided by investors in confidence and in accordance with the Data Protection Legislation. For queries, requests or comments in respect of this notice or the way in which the CBIS, CBIS Global Funds plc, and/or CUIT uses investors’ personal data, please contact [email protected]. Investors have the right to lodge a complaint with the Office of the Data Protection Commissioner if they are dissatisfied with the manner in which their personal data is used by the CBIS, CBIS Global Funds plc, and/or CUIT.