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Data Protection Notice

This notice is to make you aware of how the personal data that you provide to BBH is processed. In this notice, “BBH” means one or more of the following BBH entities with which you are contracted: Brown Brothers Harriman Trustee Services (Ireland) Limited, Brown Brothers Harriman Fund Administration Services (Ireland) Limited, Brown Brothers Harriman Investor Services Limited (UK), Brown Brothers Harriman (Luxembourg) S.C.A.

BBH as Data Controller processes personal data in compliance with General Data Protection Regulation (EU/2016/679) (“GDPR”).

As a client which provides BBH with the personal data of individuals associated with you in connection with your business relationship with us, the information in this notice is relevant to such individuals, and we request that you make this information available to them.

By continuing to provide us with personal data, you confirm that:

  1. All personal data that you provide to BBH has been collected, processed and provided to BBH in compliance with applicable laws, including the GDPR;
  2. All such personal data is accurate, relevant, limited to what is necessary for the purposes for which you provide it, and, as applicable, up-to-date; and
  3. When you provide personal data to BBH for the express purpose of being forwarded to a jurisdiction that does not have equivalent protections for personal data as those in the EU, you have informed the relevant individuals whose personal data you are providing to us in accordance with GDPR and obtained specific, unambiguous and freely given consent from them.

GDPR Compliance

BBH will process any personal data that you provide in accordance with the GDPR. BBH has implemented technical and organizational measures to provide an appropriate level of security for such personal data. BBH shall act as a Data Controller under the GDPR with respect to such processing.

 

Purposes and Legal Basis of Processing

  1. To perform its obligations under its agreement(s) with you;
  2. To communicate with you and to otherwise maintain and develop our business relationship, including providing you information about our products and services; and
  3. To comply with applicable laws, rules and regulations, including, but not limited to, those relating to anti-money laundering, sanctions screening and taxation.

BBH

Will only process personal data for the purposes for which it has been provided to us, unless otherwise permitted by applicable law.

The legal bases upon which BBH will process personal data are BBH’s legitimate interest in operating its business and to comply with laws, rules and regulations to which BBH is subject.

Recipients of Personal Data

In processing personal data for the purposes identified above, we may transfer or disclose such personal data to the following entities and their personnel and agents:

  1. BBH’s affiliates;
  2. BBH’s agents, network and service providers, including those providing audit, legal, tax, sub custody and information technology services; and
  3. Regulatory agencies with jurisdiction over BBH, as required by applicable law.

BBH will comply with the GDPR when transferring personal data to a recipient outside of the European Economic Area.

 

Storage Limitation

BBH will retain personal data only for as long as is reasonably necessary for the purpose for which it was provided, except to the extent BBH is required to retain such personal data for a longer period of time by applicable laws, rules and regulations.

 

Individuals’ Rights

Individuals have a right to obtain a copy of, and the right to rectify any inaccuracies in, the personal data BBH holds about them by making a request to us in writing. Such individuals also have certain rights under the GDPR to request erasure, restriction, and portability, and to not be subject to a decision based on automated processing (including profiling). An individual seeking to assert any such rights should contact BBH using the email address set out below. BBH will respond to such a request in writing, or orally, if requested, as soon as practicable, but in any event within the time frame prescribed by applicable law.

Individuals also have the right to lodge a complaint with the relevant data protection supervisory authority if they are unhappy with how BBH personal data is processing their personal data.

 

Contact

Please address requests to BBH by email at DPO@bbh.com.

 

This publication is provided by Brown Brothers Harriman & Co. and its subsidiaries ("BBH") to recipients, who are classified as Professional Clients or Eligible Counterparties if in the European Economic Area ("EEA"), solely for informational purposes. This does not constitute legal, tax or investment advice and is not intended as an offer to sell or a solicitation to buy securities or investment products. Any reference to tax matters is not intended to be used, and may not be used, for purposes of avoiding penalties under the U.S. Internal Revenue Code or for promotion, marketing or recommendation to third parties. This information has been obtained from sources believed to be reliable that are available upon request. This material does not comprise an offer of services. Any opinions expressed are subject to change without notice. Unauthorized use or distribution without the prior written permission of BBH is prohibited. This publication is approved for distribution in member states of the EEA by Brown Brothers Harriman Investor Services Limited, authorized and regulated by the Financial Conduct Authority (FCA). BBH is a service mark of Brown Brothers Harriman & Co., registered in the United States and other countries. © Brown Brothers Harriman & Co. 2019. All rights reserved.