Privacy Policy

This privacy Notice (the “Privacy Notice”) is issued by NS Partners (“NS Partners”). This Privacy Notice explains how
Personal Data (as defined below) is processed at NS Partners and individuals’ rights in relation to their Personal Data
processed by NS Partners.

Any question regarding the processing of Personal Data by NS Partners may be sent to the addresses below:

NS Partners Data Protection Officers, DPO
Rue de Saint-Jean 98 11, Boulevard de la Foire 22 Upper Brook Street Old Devonshire Post Office
Building
1201 Genève 1528 Luxembourg London W1K7PZ 29 Middle Road
Devonshire DV06
Bermuda
dpo-ch@nspgroup.com dpo-lux@nspgroup.com dpo-london@nspgroup.com dpo-bermuda@nspgroup.com

 

1. How do we handle your personal data?

This Privacy Notice deals with the way we process (i.e., collect, use, store, transmit or otherwise handle
or process) personal data. This Privacy Notice does not replace, and is subject to, our applicable
contractual general business conditions.
NS Partners takes technical and organizational measures against unauthorized access to, or processing
of, Personal Data and accidental loss or destruction of Personal Data, in accordance with NS Partners’
internal security procedures.

2. What personal data do we process?

“Personal data” include any information that may enable one to identify directly (e.g., first name, surname) or indirectly
(e.g., passport number or data combination) a natural person.
Personal data of Data Subjects we process may include:

  • Identification data, e.g., names, addresses, telephone numbers, email addresses, business contact
    information;
  • Personal characteristics, e.g., date of birth, country of birth;
  • Professional information, e.g., employment and job history, title, representation authorities;
  • Identifiers issued by public bodies, e.g., passport, identification card, tax identification number, national
    insurance number, social security number;
  • Financial information, e.g., financial and credit history information, bank details;
  • Transaction/investment data, e.g., current and past investments, investment profile, investment preferences
    and invested amount, quantity and value of shares held, role in a transaction (seller/buyer of shares),
    transaction details;
  • Sensible personal data, e.g., information regarding health or administrative or criminal proceedings;
  • Cookie information, e.g., cookies and similar technologies on websites and in emails.

3. For what purposes and on what legal bases do we process personal data?

As a general comment, we process personal data in relation to (i) the performance of a contract to which
you are a party or a Related Person is a party (as well as to take pre-contractual steps at your or a Related
Person’s request), (ii) our obligation to comply with legal or regulatory requirements, (iii) the pursuit of
our legitimate interest (including that of other NS Partners entities) and (iv) the performance of a task
carried out in the public interest (e.g., to prevent or detect offences).
We also collect and process personal data in relation to our duty to comply with legal and regulatory
obligations we are subject to, including to:
  • provide offering documentation to Data Subjects about products and services;
  • carry out any other form of cooperation with, or reporting to, competent administrations, supervising authorities,
    law enforcement authorities and other public authorities (e.g., in the field of anti-money laundering and
    combatting terrorism financing (“AML-CTF”)), for the prevention and detection of crime under tax law (e.g.,
    reporting of name, address, date of birth, tax identification number (TIN), or Foreign Account Tax Compliance
    Act (“FATCA”) or other tax legislation to prevent tax evasion and fraud as applicable);

The provision of personal data may be mandatory, e.g., in relation to our compliance with legal and regulatory
obligations to which we are subject. Please be aware that not providing such information may preclude us from
maintaining a Business Relationship with, and/or from providing services to you.

4. What sources do we use to collect your personal data?

We collect or receive personal data:

  • directly from the Individuals concerned, e.g., when contacting us or on the basis of a (pre-) contractual
    documentation directly sent to us; and/or
  • indirectly from other external sources, including any publicly available sources (e.g., UN or EU sanctions lists),
    information available through subscription services (e.g., Bloomberg) or information provided by other third
    parties.

5. Do we share your personal data with third parties?

Subject to its regulatory obligations, NS Partners may have to transfer Personal Data to third parties,
including third parties based abroad, e.g. (but not limited to) sub-contractors, other counsel or
accountants, as well as third parties involved in client matters. Where NS Partners transfers Personal
Data to third parties, NS Partners does so in accordance with applicable data protection rules and takes
appropriate safeguards to ensure the protection of the Personal Data. Additional information on this
topic may be requested by sending an email to dpo-ch@nspgroup.com, dpo- lux@nspgroup.com, dpo-
london@nspgroup.com or dpo-bermuda@nspgroup.com.

6. What are your rights in connection with data protection?

Subject to applicable regulations, the data subject has the right to:
  • access and obtain a copy of his/her Personal Data;
  • request the rectification of his/her Personal Data when they are inaccurate or incomplete;
  • request the erasure of his/her Personal Data, e.g., when they are no longer necessary for the purposes for
    which they were collected or processed, or when the data subject withdraws the consent necessary for the
    processing (subject to point 7 below);
  • object on legitimate grounds to the processing of his/her Personal Data;
  • request the limitation of the processing of his/her Personal Data;
  • receive information on the safeguards which NS Partners may have implemented for transferring Personal Data
    to jurisdictions which do not ensure an adequate level of data protection (if applicable); and
  • lodge a complaint with a competent data protection supervisory authority.
The data subject may also, at any time and without justification, object to the processing, by NS Partners,
of his/her Personal Data for marketing purposes.

7. How long are your personal data kept or stored?

NS Partners retains Personal Data for as long as reasonably necessary for NS Partners (i) to fulfill the
purposes mentioned above or (ii) until the Individual concerned withdraws his/her consent, provided
that NS Partners is not permitted to continue to hold such Personal Data for another reason (e.g., for
purposes of an investigation). Destruction of Personal Data takes place in accordance with the terms of
NS Partners’ internal data backup procedures.
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