Disclosures

Overview 
Each of (i) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“EU GDPR”), (ii) the EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (“UK GDPR” and together with EU GDPR, “GDPR”), (iii) the Cayman Islands Data Protection Act (As Revised) (and any associated guidance and regulations, together, “DPA”), (iv) the Swiss Federal Act on Data Protection of 25 September 2020 (“FADP”), (v) the Singaporean Personal Data Protection Act of 2012 (No. 26 of 2012), as amended by the Personal Data Protection (Amendment) Act 2020 (“PDPA”), and (vi) the Personal Information Protection Law of the People’s Republic of China (“PIPL”, and together with GDPR, DPA, FADP and PDPA, and any associated ordinances and regulations, the “Data Protection Laws”) may be applicable, to the extent relevant, to the processing of personal data by each of Systematica Investments Services Limited, Systematica Investments UK LLP (“SIUK”), Systematica Investments Limited, Systematica Investments LP, Systematica Investments Holdings Limited, Systematica Investments GP Limited, including when acting through its Geneva branch, Systematica Investments US LLC, Systematica Investments Singapore Pte. Ltd and Systematica Investments Shanghai Co., Ltd (the “Systematica Entities”) in the course of their businesses, and certain other persons. This notice sets out information relating to those activities.

The Systematica Entities
To the extent applicable, the Systematica Entities are controllers of personal data for the purposes of the Data Protection Laws and will, in the course of each Systematica Entity’s business, process personal data. Information regarding such processing is set out herein.

Any person seeking information with respect to control or processing of personal data by any of the Systematica Entities or seeking to exercise any applicable rights afforded to them under the Data Protection Laws should contact the compliance department of SIUK at [email protected]

As applicable under the Data Protection Laws, any person wishing to is entitled to make a complaint with respect to any of the Systematica Entities’ control or processing of personal data. For example, under UK GDPR, such a complaint may be made to the Information Commissioner’s Office (“ICO”). The ICO is the UK supervisory authority for data protection issues. Contact details for the ICO may be found at www.ico.org.uk. Under DPA, such a complaint may be made to the Cayman Islands Ombudsman (“Ombudsman”). The Ombudsman is the Cayman Islands supervisory authority for data protection issues. Contact details for the Ombudsman may be found at www.ombudsman.ky.
The policies and procedures adopted by the Systematica Entities with respect to the control or processing of personal data may be amended from time to time. Similarly, the purposes for which the Systematica Entities may control or process personal data may change from time to time. If any changes would require a material amendment to the information set out herein, details of such changes will be made available in the current version of this document from time to time.

Summary of Personal Data
For the purposes of the applicable Data Protection Laws, personal data means any information about an individual from which that person can be identified, directly or indirectly. In the course of their business, the Systematica Entities may collect, use, store, transfer and process personal information from individuals, including former, current or prospective investors and other natural persons, and former, current and prospective employees, directors, officers or other representatives or agents of market counterparties, professional services and other service providers, trade associations, public bodies and other entities or undertakings. Such personal data is typically limited in scope, and includes, for example, the name and contact details of such individuals, as well as some technical data (such as internet protocol addresses), usage data and information about marketing and communication preferences.  On occasions, the Systematica Entities may also process personal data of such individuals which includes other identifiers such as date of birth, social security number, tax identification number, passport, national identity or driver’s licence number.  Personal data that the Systematica Entities collect may also include commercial information, such as records of products or services purchased, obtained or considered, or other purchasing histories or tendencies, including funds invested in, investments considered, or sources of wealth; and professional or employment-related information, such as investment experience, occupation, compensation, employer and title.

In addition, the Systematica Entities may also collect, use, store, transfer and process personal information concerning current or former applicants for positions of employment at or membership of, or current or former employees or members of, the Systematica Entities. Such personal data may include some or all of the following: name and contact details, information about employment and educational history, performance records, salary data, references, bank account details, identification data, tax information, social security numbers and information regarding immigration status. The Systematica Entities will endeavour to contact those former job applicants or former employees if the personal data processed in relation to the same is material, sensitive or particularly private in order to inform them of the continued processing of their personal data, the nature of that processing, the lawful basis upon which the processing is taking place, and their rights under the Data Protection Laws with respect to such processing.

In certain limited circumstances, the Systematica Entities may process special categories of personal data (which may include details about people’s racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about people’s health, genetic and biometric data and information about criminal convictions and offences).

Purposes for Collection and Use of Personal Data
The Systematica Entities will only process personal data in circumstances where they have established a lawful basis under the Data Protection Laws to do so. These circumstances include where the processing of the relevant data relates to a legitimate interest of the relevant Systematica Entity, further described below. In such circumstances the Systematica Entities will have established that the processing is necessary for the relevant purpose, and not inconsistent with the interests, rights or freedoms of a relevant data subject.
In accordance with the above, each Systematica Entity has determined that the lawful bases for its processing of personal data are the legitimate interests of the relevant Systematica Entity to undertake activities necessary and ancillary to the carrying on of an investment management business, including where necessary for the purposes of the relevant Systematica Entity carrying out its activities relating to any fund, vehicle or account in respect of which a Systematica Entity acts as investment manager, sub-investment manager, investment adviser or sub-investment adviser (the “Funds”), the administration of the Funds, the investment activities of the Funds, otherwise in furtherance of any contract entered into with respect to the activities of the Funds, to exercise and comply with the relevant Fund’s or Systematica Entity’s rights and obligations at law or under regulation where such obligations are not set out under the laws of any member state of the European Economic Area (“EEA”) or the United Kingdom, to establish, exercise or defend legal claims and in order to protect and enforce its (or another person’s) rights, property, or safety, or to assist others to do the same, and in order to provide information about its services and any investment products it offers.
In addition, each Systematica Entity may also control or process personal data where necessary to comply with legal or regulatory obligations applicable to them under the laws of the Cayman Islands, the United Kingdom, the European Union or any member state of the EEA or any other relevant jurisdiction, or in order to give effect to a contract, or to take necessary pre-contractual steps with a view to potentially entering into a contract (including in its capacity as an employer or a prospective employer), or where an individual has provided their consent to such processing, to the extent applicable.
Systematica Entities may from time to time control or process personal data for the purposes of operating their business, entering into contractual arrangements in the context of their investment management business, including in respect of the Funds marketing, and advertising the Funds and/or other investment vehicles and/or services related to the Systematica Entities. Any person who does not wish their personal data to be processed for marketing purposes may opt out of such processing by notifying the compliance department of SIUK at [email protected].
Any Systematica Entity will only use personal data for the purposes that it has been collected for, unless they reasonably consider that they need to use it for another reason and that reason is compatible with the original purpose of the control or processing. Any person requiring information with respect to any additional purpose for which personal data may be controlled or processed may obtain such information from the compliance department of SIUK. If a Systematica Entity needs to control or process personal data for an unrelated purpose, the relevant Systematica Entity will use its reasonable endeavours to notify affected persons and to explain the basis on which they are permitted to undertake the same.
The Systematica Entities may be legally obliged to process certain personal data in order to be able to perform services and business operations or to comply with contractual requirements. If individuals choose not to provide the Systematica Entities with the necessary personal data or to restrict the Systematica Entities from processing personal data, the Systematica Entities may not be able to meet their obligations or deliver the products or services requested. This may lead to cancellation of contracts; if this is the case, the relevant Systematica Entity will endeavour to contact the individuals to discuss this.