All persons who have access to the information listed below are subject by the law to a professional secrecy obligation or bound by a confidentiality agreement in accordance with the Luxembourg law of 5 April 1993 on the financial sector, as amended.
Data transfer for outsourcing and sub-outsourcing purposes
| Service Provider | Purpose of client data sharing | Country of establishment | Type of information transmitted | Sub-Outsourcing | Location of sub-outsourcing(s) |
|---|---|---|---|---|---|
| FIS | Client accounting solution offering investor related functionalities for transfer agent and registrar services. | USA | No access to data by the cloud provider. Cloud computing model solution (Software as a Service). | No | N/A |
| AtozMa Services | Intra-group outsourcing. Support to client related operational tasks: fund accounting, transfer agency, registrar, company secretary services, domiciliation. | Morocco | Access to Atoz Fund Services own IT environments without data transfer allowed externally. Access to customers’ corporate records including shareholder communications, accounting and payment processing information, KYC clients and investors files. | No | N/A |
| Arcad | Provision of Internal audit services. | Luxembourg | Policies, procedures, KYC clients and investors files for sampling testing. | No | N/A |
| Trustteam (f.k.a. System Solutions) | Cloud hosting and platform services, Internet, security and firewall services, collaboration services, endpoint as a service. | Luxembourg | Hybrid cloud model solution. | Yes | EU (Ireland / Luxembourg / Belgium) |
| Atoz Services S.A. | Support to finance and accounting operational tasks. | Grand Duchy of Luxembourg | Name, surname(s), address (private and/or professional), identity card/passport, country of residence and tax residence, date and place of birth, nationality(ies), profession, contact details, preferred language, banking and payment information, national identification number. | No | N/A |
Data transfer OTHER THAN for outsourcing and sub-outsourcing purposes
| Service Provider | Purpose of client personal data sharing | Type of client personal data transmitted | Country of the data processing |
|---|---|---|---|
| KYC 360 | Name screening tool | Name, Family name, date of birth, country of birth | Jersey, Channel Islands |
| Yousign | Electronic signature solution | Name of the client, e-mail address | France |
| Atoz | Administrative, billing and business purposes | name, surname(s), address (private and/or professional), identity card/ passport, country of residence and tax residence, date and place of birth, nationality(ies), profession, contact details, preferred language, banking and payment information, national identification number, | Grand Duchy of Luxembourg |
| Atoz Services S.A. | Administrative and business purposes | name, surname(s), address (private and/or professional), identity card/ passport, country of residence and tax residence, date and place of birth, nationality(ies), profession, contact details, preferred language, national identification number, | Grand Duchy of Luxembourg |
| Atoz Governance Services | Administrative, billing and business purposes | name, surname(s), address (private and/or professional), identity card/ passport, country of residence and tax residence, date and place of birth, nationality(ies), profession, contact details, preferred language, banking and payment information, national identification number, | Grand Duchy of Luxembourg |