GQG PARTNERS PRIVACY NOTICE FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, SWITZERLAND AND THE UNITED KINGDOM

Last Updated: August 29, 2021

This Privacy Notice applies to you if you are a resident of the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”). GQG Partners LLC and its subsidiaries and affiliated companies (“GQG,” “we,” or “us,”) provide this Privacy Notice as a supplement to our global GQG Partners Privacy Policy. This Privacy Notice applies only to our processing that is within the scope of the European Union General Data Protection Regulation (“EU GDPR”) and the UK General Data Protection Regulation (“UK GDPR”).

We are a data controller with respect to the data collected by our Services, by our customer service team, when you engage with us on social media, when you participate in one of our contests, sweepstakes, promotions, or surveys, when you attend one of our events, or when you otherwise interact with us. As a data controller, we will decide the ways in which and purposes for which we process data about you. We may process data about you ourselves or through others acting as data processors on our behalf. We have an establishment in the UK but not in the EEA.

If you have any questions about this Privacy Notice, you can contact us or our EU/UK representative using the details set out in the Contact Us section below.

Legal Basis for Processing

We collect and process data about you in accordance with the information provided in the global GQG Partners Privacy Policy. As required by the EU GDPR and the UK GDPR, our legal grounds, or “lawful basis,” for processing data include the following:

  • To perform our responsibilities under our contract with you (e.g., providing the Services you requested).
  • When we have a legitimate interest in processing data about you to operate our business or protect our interests (e.g., to provide, maintain, and improve our Services, conduct data analytics, and communicate with you).
  • To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
  • When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing data about you, you may withdraw such consent at any time by contacting us using the details in the Contact Us section below.

No Requirement to Provide Us Data about You

Our Services may collect, sometimes automatically, certain data, as described in our global GQG Partners Privacy Policy. We may be unable to provide parts of our Services, if you prevent us from collecting this data.

Transfer of Data Outside of the EEA, Switzerland, and the UK

As we are headquartered in the United States and have operations and service providers in the United States and other countries, we and our service providers may process any data we collect about you in the United States, Australia, and other jurisdictions outside of the EEA, Switzerland, and the UK.

We may also transfer data about you to countries within the EEA or to other countries that the European Commission and the United Kingdom have determined offer an adequate level of protection in respect of personal data.

Where required by the EU GDPR and the UK GDPR, we will put in place, or require a processor to put in place, appropriate safeguards to protect transferred personal data, such as the standard contractual clauses approved by the European Commission. If you require further information about this, you can request it using the details set out in the Contact Us section below.

Data Retention

Generally, we will keep information relevant to our dealings with you for at least seven (7) years following the last date of activity. Additionally, we will retain data about you for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements and our legitimate interests in maintaining such data in our records. In doing this, we will consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, data about you may be anonymized, so that it can no longer be associated with you, in which case it is no longer personal data.

Once we no longer require data about you for the purposes for which we collected it, we will securely destroy, aggregate, or anonymize the data in accordance with applicable laws and regulations.

Data Subject Requests

Requests and Complaints

If you are a resident of the EEA, Switzerland, or the UK, you may, under certain circumstances, make data subject requests in relation to the data we hold about you. These data subject requests include the ability to:

  • request access to data about you (commonly known as a “data subject access request”) and request certain information in relation to its processing;
  • request rectification of data about you;
  • request the erasure of data about you;
  • request the restriction of processing of data about you;
  • object to the processing of data about you; and
  • request the transfer of data about you to another party.

If you want to make one of the above requests, please email your request to us at websupport@gqgpartners.com.

You may also make a complaint at any time to the national supervisory authority for data protection issues where you reside. Contact details for your Data Protection Authority can be found using the links below:

Fees

We typically do not charge you a fee to respond to one of the above requests. However, we may charge a reasonable fee if your request is manifestly unfounded or excessive, or we may refuse to comply with the request in such circumstances.

What we may need from you

Before responding to your request, we may ask you to provide specific information to us to help us verify your identity and ensure your ability to make the request. The information we request may include your name, email address, phone number, or company.

Changes to This Privacy Notice

Our practices with respect to data about you may vary from time to time, and we may update this Privacy Notice at any time. If we make changes, we will notify you by revising the date at the top of this notice and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). The latest version of this Privacy Notice will be made available to you on our website, and we encourage you to review this Privacy Notice regularly to stay informed about our data practices with respect to data about you and the choices available to you.

Contact Us

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of data about you. If you require any further information, contact us using the following contact details: Compliance Officer, GQG Partners LLC, 450 East Las Olas Boulevard, Suite 750, Fort Lauderdale, FL 33301 USA (+1 754-218-5500) (gqgcompliance@gqgpartners.com).

Alternatively, with respect to our UCITS funds, GQG Global UCITS ICAV, you may contact its representative in the EU for data protection matters, using the following contact details: Company Secretary, GQG Global UCITS ICAV, 3 Georges Dock, IFSC, Dublin 01 X5X0 Ireland.