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Data Protection Notice

This notice is to make you aware of how the personal data that you provide to ABLS is processed. In this notice, “ABLS” means one or more of the following ABLS entities with which you are contracted: ABLS, ABLS

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

As a client which provides ABLS 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 ABLS has been collected, processed and provided to ABLS 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 ABLS 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

ABLS will process any personal data that you provide in accordance with the GDPR. ABLS has implemented technical and organizational measures to provide an appropriate level of security for such personal data. ABLS 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.

ABLS

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 ABLS will process personal data are ABLS’s legitimate interest in operating its business and to comply with laws, rules and regulations to which ABLS 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. ABLS’s affiliates;
  2. ABLS’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 ABLS, as required by applicable law.

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

 

Storage Limitation

ABLS will retain personal data only for as long as is reasonably necessary for the purpose for which it was provided, except to the extent ABLS 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 ABLS 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 ABLS using the email address set out below. ABLS 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 ABLS personal data is processing their personal data.

 

Contact

Please address requests to ABLS by email at [email protected].

 

This publication is provided by ABLS & Co. and its subsidiaries ("ABLS") 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 ABLS is prohibited. This publication is approved for distribution in member states of the EEA by ABLS Investor Services Limited, authorized and regulated by the Financial Conduct Authority (FCA). ABLS is a service mark of ABLS & Co., registered in the United States and other countries. © ABLS & Co. 2020. All rights reserved.