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.

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Important Information for Non-U.S. Residents

You are required to read the following important information, which, in conjunction with the Terms and Conditions, governs your use of this website. Your use of this website and its contents constitute your acceptance of this information and those Terms and Conditions. If you do not agree with this information and the Terms and Conditions, you should immediately cease use of this website. The contents of this website have not been prepared for the benefit of investors outside of the United States. This website is not intended as a solicitation of the purchase or sale of any security or other financial instrument or any investment management services for any investor who resides in a jurisdiction other than the United States1. As a general matter, Brown Brothers Harriman & Co. and its subsidiaries (“BBH”) is not licensed or registered to solicit prospective investors and offer investment advisory services in jurisdictions outside of the United States. The information on this website is not intended to be distributed to, directed at or used by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. Persons in respect of whom such prohibitions apply must not access the website.  Under certain circumstances, BBH may provide services to investors located outside of the United States in accordance with applicable law. The conditions under which such services may be provided will be analyzed on a case-by-case basis by BBH. BBH will only accept investors from such jurisdictions or countries where it has made a determination that such an arrangement or relationship is permissible under the laws of that jurisdiction or country. The existence of this website is not intended to be a substitute for the type of analysis described above and is not intended as a solicitation of or recommendation to any prospective investor, including those located outside of the United States. Certain BBH products or services may not be available in certain jurisdictions. By choosing to access this website from any location other than the United States, you accept full responsibility for compliance with all local laws. The website contains content that has been obtained from sources that BBH believes to be reliable as of the date presented; however, BBH cannot guarantee the accuracy of such content, assure its completeness, or warrant that such information will not be changed. The content contained herein is current as of the date of issuance and is subject to change without notice. The website’s content does not constitute investment advice and should not be used as the basis for any investment decision. There is no guarantee that any investment objectives, expectations, targets described in this website or the  performance or profitability of any investment will be achieved. You understand that investing in securities and other financial instruments involves risks that may affect the value of the securities and may result in losses, including the potential loss of the principal invested, and you assume and are able to bear all such risks.  In no event shall BBH or any other affiliated party be liable for any direct, incidental, special, consequential, indirect, lost profits, loss of business or data, or punitive damages arising out of your use of this website. By clicking accept, you confirm that you accept  to the above Important Information along with Terms and Conditions.

 
1BBH sponsors UCITS Funds registered in Luxembourg, in certain jurisdictions. For information on those funds, please see bbhluxembourgfunds.com


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