Privacy Notice

Version: September 2019

Ci Fund Services S.A. (hereinafter referred to as the Management Company) respects your privacy and is committed to protecting your personal data. This privacy notice (the “Privacy Notice”) relates to all personal data that you provide to the Management Company in the context of your use of the Management Company`s Website (regardless of where you visit the site from).
This Privacy Notice provides you with information on how the Management Company collects and processes your personal data. By using this website and services provided by the Management Company, you consent to the data practices described in this Privacy Notice.

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The Management Company collects, uses, stores and transfers different kinds of personally identifiable information which can be grouped together as follows:

a. Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
b. Contact Data includes home or work address, email address and telephone numbers.
c. Financial Data includes bank account details.
d. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
e. Profile Data includes your username and password, your interests, preferences and favorites.
f. Usage Data includes information about how you use our website, services.
g. Marketing and Communications Data includes your preferences in receiving marketing from your communication preferences.

The Management Company can also collects anonymous information, which is not unique to you and does not directly or indirectly reveal your identity.
The Management Company may collect or obtain personal data directly from you (for example by completing a form on the Management Company`s Website or attending one of our events or by going through our recruitment process) or indirectly because other people give that data to us (for example your employer or adviser or third party service providers that we use to help operate our business) or because it is publicly available.
The Management Company may also collect personal data from you because the Management Company combines personal data with other data made available to the Management Company. The Management Company may also infer personal data about you from the way you make use of the Management Company`s Website, for example, to improve your experience when you use the Management Company’s Website and ensure that it is functioning effectively, the Management Company (or its service providers) may use cookies (small text files stored in a user’s browser) which may collect personal data. Additional information on how the Management Company uses cookies and how you can control these can be found below.
The Management Company does not intentionally collect any particularly sensitive categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and, if collected, the Management Company does not use or disclose those sensitive personal data without your explicit consent.
The Management Company encourages you to review the privacy statements of websites you use to link to the Management Company so that you can understand how those websites collect, use and share your information. The Management Company is not responsible for the privacy statements or other content on websites outside of this Website.

Purpose for which the Management Company might use your personal data
The Management Company collects and uses your personal data for legitimate interests, such as to operate the Management Company`s Website. The Management Company also uses your personal data to inform you of products or services available from Management Company and its affiliates. The Management Company may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
Your personal data may also be processed for compliance with statutory and regulatory obligations of the Management Company or internal policy requirements and the order of a competent court, as well as (but not limited to) accounting, commercial communications, know-your-customer and anti-money laundering requirements, general management of the services or customer relationship purposes. The Management Company may also process your personal data for the purposes of Management Company’s legitimate interest to defend Management Company offices, IT infrastructure and also in connection with services the Management Company receive from professional advisors, such as lawyers and consultants or other service providers either to execute Management Company`s contractual obligations toward you or the Management Company’s clients or more generally for legitimate business interest personal data.
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Change of purpose
The Management Company will only use your personal data for the purposes for which the Management Company collected it, unless the Management Company reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose.
If the Management Company needs to use your personal data for an unrelated purpose, the Management Company will notify you and will explain the legal basis which allows the Management Company to do so.
Please note that, in exceptional circumstances, the Management Company may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law and for the purposes or in connection with the purposes set out above.

Transfer and disclosure of personal data
Your personal data may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Switzerland and choose to provide information to us, please note that we transfer the data, including personal data, to Switzerland and process it there.
Your consent to this Privacy Notice followed by your submission of such information represents your agreement to that transfer.
The Management Company does not sell, rent or lease personal data collected from the Management Company’s Website to third parties. External business partners may, from time to time, contact you on behalf of the Management Company about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is transferred to the third party. In addition, the Management Company where necessary, may share data with trusted partners to help the Management Company perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal data except to provide these services to the Management Company, and they are contractually required to maintain the confidentiality of your information.
Management Company will disclose your personal data, without notice, only if required to do so by law or if such action is reasonably necessary to: (a) defend claims; (b) protect and defend the rights or property of the Management Company; and, (c) act under emergency circumstances to protect the personal safety of users of the Management Company, or the public.
As provided for under the applicable data protection laws and regulations, you are entitled to request access, correct or erase your personal data or restrict the processing of your personal data, as well as the right to data portability.
To exercise these rights, please contact the Management Company (see below).
You also have the right to lodge a complaint with the competent data protection authority, being in Luxembourg the Commission nationale pour la protection des données.

Data retention
The Management Company will only retain your personal data for as long as necessary to fulfil the purposes the Management Company collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.