FAIR PROCESSING NOTICEPERSONAL DATA PROCESSINGBY SUMITOMO MITSUI TRUST CLUB, CO., LTD

EFFECTIVE DATE: 2018/12/03

PURPOSE AND APPLICATION OF THIS NOTICE

Sumitomo Mitsui Trust Club, Co., Ltd ("Trust Club", ''we", or "us'', or "'our") routinely collects
and uses information relating to identifiable individuals ("personal data"), including data relating
to:1.

staff, managers, advisors, intermediaries, and other representatives of ourclients and prospective clients (“representatives”);

2.

the beneficial owners, partners, officers and directors of our legal entity,
partnership or fund clients and prospective clients;

3. the card members to which we provide services or to which may seek to provide
services; and4. other persons affiliated or associated with our clients and prospective clientsand their representatives.

We provide this fair processing notice (''notice") in accordance with our obligations under theEuropean Union's General Data Protection Regulations and other applicable data protection
laws, and as part of our commitment to processing personal data transparently.
CONTENTSThis notice provides information on:-

the Trust Club entity or entities responsible for processing your personal data;-

the personal data we collect from you and from third parties about you;-the purposes for which personal data is processed and our lawfu1 basis for doing so;-

how your personal data is shared by us; and-your rights in relation to our processing of your personal data, and how you can exercise
these rights.

CONTACT DETAILS

If you would like to contact us regarding the processing of your personal data, please contact to
our Customer Consulting Unit. or at the following address: Triton Square X 36F, 1-8-10 Harumi,
Chuo-ku, Tokyo, 104-6036, Japan
1. WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?

The Trust Club which contracts, or seeks to contract, with the entity, partnership, trust or
fund that you own, represent, are employed by or are otherwise associated with will be a data
controller of your personal data. In addition, where processing of personal data isundertaken by Trust Club or any entity controlled by, or under common control with,
Sumitomo Mitsui Trust Bank, Limited ( “Trust Club affiliates”) for their own purposes, theseaffiliates may also be data controllers of your personal data.
The list of Sumitomo Mitsui Trust Bank, Limited (“SMTB”) controllers where we areincluded as a controller are listed in the “Europe” section of the “Global Network” tableavailable here: www.smtb.jp/tools/english/company/global-network.html. Any of these
SMTB controllers can be contacted at euprivacy@smtb.jp.
This notice applies in conjunction with any other notices you receive from Trust Club
affiliates in connection with the processing of your personal data.
2. WHAT PERSONAL DATA DO WE PROCESS?
2.1. YOUR PERSONAL DATA

Trust Club and Trust Club affiliates will, depending on the relationship we have with you andthe products and services we provide (or seek to provide), process certain personal data
relating to you and people connected to you, including the data listed below:
A. PROFESSIONAL AND PERSONAL DETAILS- primarily we process yourname, details of the client you are employed by, represent, own or are otherwise
associated with, your role at such client and your professional contact details. We
may also process additional information in order to be able to liaise with you in
connection with this role, such as information to identify you and evidence yourauthority to represent our client.
B. INFORMATION USED FOR BACKGROUND CHECKS, MONITORING
AND COMPLYING WITH LAWS AND REGULATIONS - if you are aprincipal this may include date of birth, nationality, country of residence/domicile,documents required for anti-money laundering checks and monitoring (including a
copy of your passport or national identity card), records of any required disclosures,and of restrictions on your ability to invest (such as any insider status or political
exposure), and other details of your affiliations and/or of our relationship with you
as necessary to enable us to meet applicable laws and regulations, including
regulatory reporting requirements and identifying any conflicts of interest.
Where required or authorised by applicable laws, this may involve processing data
relating to any political affiliations you may have, as well as criminal convictions or
allegations of offences.
C. RECORDS CONNECTED WITH PROVIDING PRODUCTS AND SERVICES TOOUR CLIENTS OR PROSPECTIVE CLIENTS- such as notesfrom interactions, meetings and conversations that you have with us or our affiliates(including records of your instructions to us and, to the extent permitted or requiredby law, recordings of telephone calls), records of correspondence, and/or oursettlement, financial or other services made available electronically by Trust Club to you
and/or the Trust Club client or prospective client you represent (including datatransmitted by your browser and automatically recorded by our server). This also
includes account details, records of agreements, payments, investments, trades andother transactions that contain your name or other personal data, and any identifiers
that we or our affiliates assign to records associated with you.
In some cases we may obtain your personal data from Trust Club affiliates or from third parties.
Depending on the products and services we provide to you, this may include trade ortransaction counterparts, credit reference agencies, public registers (such as beneficial
ownership registers), financial crime screening databases, fraud prevention agencies, andpersons or entities instructed by you to provide us with your personal data.
2.2. DATA RELATING TO THIRD PARTIES - RELEVANT TO PRINCIPALS
If you are a principal, in addition to processing data on your representatives, if any (asdiscussed in this notice), we may process personal data of persons connected to you but withwhom Trust Club does not directly communicate, such as dependants and family members.
Before you provide data relating to third parties, you should ensure you are permitted to do so
and provide them with the relevant information contained in this notice, and draw theirattention in particular to the following:
A. Trust Club and Trust Club affiliates may process data such as family information, academic
information, former employment history and references when provided to us. Insome instances we may therefore receive personal data about and from third parties.
This may include recruitment agencies, financial crime screening databases, fraud
prevention agencies, and persons or entities instructed by you to provide us with yourpersonal data.
B. Where we process data revealing political opinions or religious beliefs, we process
this data on the basis that it: (i) has manifestly been made public (to the extent thisapplies); or otherwise (ii) is on the basis that this processing is necessary for the
purposes of carrying out our obligations and exercising our specific rights in the fieldof employment; or otherwise (iii) is on the basis that processing is necessary forreasons of substantial public interest on the basis of European Union or Member
State law or on the basis of other applicable laws.
3. FOR WHAT PURPOSES AND ON WHICH LEGAL BASES DO WE PROCESSPERSONAL DATA?
3.1. PURPOSES FOR PROCESSING
Trust Club and Trust Club affiliates process your personal data for specific purposes and process
only the personal data relevant for achieving that purpose. Depending on our relationship withyou and the products and services that we are providing, we may process your personal data for
the following purposes and for compatible purposes:
A. ACCOUNT OPENING - processing data about you that we require in connection
with opening our client's account, such as identity verification information. This
may include review and processing application and account opening documents and,if you are a principal, conducting background prudential and regulatory compliancechecks.
B. PROVIDING PRODUCTS AND SERVICES TO OUR CLIENTS ORPROSPECTIVE CLIENTS - processing personal data to ensure the proper
provision of our products and services to our clients. This includes identity
verification, transaction processing and keeping appropriate records and registers(such as documenting agreements and recording instructions).
C. MANAGING OUR RELATIONSHIP WITH OUR CLIENTS AND
CONNECTED PARTIES - including compiling and utilising internal reports andnotes, managing the client file, conducting risk reviews, allowing you to access our
websites and secure online platforms and other technological services, and, whereapplicable, managing any agreement or arrangement between us and our clients andconnected parties.
D. COMMUNICATING WITH YOU- processing data required to communicate withyou in person, by telephone, mail and email (including issuing statements andreports), keep records of our communications with you, and manage any complaints.
E. CARRYING OUT OPERATIONAL AND ADMINISTRATIVE FUNCTIONS –including carrying out billing-related and payment administration, staff and accessmanagement, preparing business reports and accounts, operating information
technology systems, archiving and backing up data, and transferring personal data.
F. HELPING US TO IMPROVE OUR PRODUCTS, SERVICES AND
OPERATIONS - including conducting market research, analysis of client andprospective client preferences, transactions and market trends, evaluating potential
new products and services, evaluating the effectiveness of our marketing, as well as
testing new systems and upgrading existing systems. To the extent permitted by law,
this may include monitoring emails and your use of our settlement, financial or otherservices made available to you electronically by Trust Club to assess, maintain andimprove the quality of our services.
G. PRUDENTLY MANAGING OUR BUSINESS AND PROTECTING AND
ENFORCING OUR RIGHTS - including assessing, monitoring and managing
financial, reputational and other risk, conducting audits of our business, liaising with
our regulator, protecting data used by our business and establishing, enforcing anddefending against legal claims.
H. MARKETING - such as direct marketing of products and services that we think may
be of interest to our clients or prospective clients, including on behalf of Trust Club
affiliates and strategic partners.
I. MEETING OUR LEGAL. REGULATORY AND COMPLIANCEOBLIGATIONS AND PREVENTING "FINANCIAL CRIME - this includes
performing prudential and regulatory compliance checks on an ongoing basis, accountand transaction monitoring, transaction reporting, tax reporting, monitoring ourmanagement of client accounts and client interactions, making disclosures to, andcomplying with requests from public authorities, regulators, tax authorities,
governmental bodies or law enforcement agencies, and investigating and preventing
fraud and other crime. To the extent permitted or required by law, this may include
recording telephone conversations and monitoring emails and your use of our settlement,
financial or other services made available to you electronically by Trust Club.
Not providing such data that is required for such purposes may have legal or
regulatory consequences, depending on the circumstances.
We may also process data for other purposes we notify to you from time to time.

3.2. LEGAL BASIS FOR PROCESSING
The personal data processing described in this notice may be:
A. necessary in order to comply with our legal obligations under certain laws;
This applies to regulatory compliance checks referred to in part A and I of section
3.1, record keeping described in part D of' section 3.1, reporting and creation of
accounts referred to in part E of section 3.1 business management and regulatory
liaison activities referred to in part G of section 3.1, and the processing describedin part I of section 3.1, in each case where carried out in respect of the relevantlaws.
B. necessary for entry into, or performance of, a contract with you; orWhere you act as an intermediary, this relates to processing to manage our agreementwith you, referred to in part C of section 3.1.
C. necessary for the legitimate interest of Trust Club or others, where these are notoverridden by your interests or fundamental rights and freedoms (as described below);

D. in limited circumstances and to the extent the legal bases for processing set out above
do not apply, processed with your consent (which we obtain from you from time totime).
The 'legitimate interests' referred to in section 3.2.C above are:-the processing purposes described in sections 3.1.A to 3.1.I (inclusive) of this notice,to the extent the processing is not necessary in order to (i) comply with our legal
obligations under certain laws or (ii) to enter into any contract with you and fu1fi1 ourobligations thereunder (for example, where you provide intermediary services);-

meeting and complying with our accountability requirements and regulatory
obligations globally; and-exercising our fundamental rights and freedoms, including our freedom to conduct abusiness and our right to property.

DATA RELATING TO POLITICAL OPINIONS AND CRIMINAL CONVICTIONSAND OFFENCES
In addition, if you are a principal, we may:
A. process data revealing your political opinions as part of our anti-money laundering
checks. We process this on the basis that you have manifestly made such data public(to the extent this applies) or on the basis that this processing is necessary for reasonsof the substantial public interest in preventing financial crime; andB. process personal data relating to criminal convictions and offences as authorised byapplicable law.

In limited circumstances we may process any of the personal data we hold to the extent
necessary to defend, establish and exercise legal claims.
4. YOUR CONSENT
To the extent Trust Club is relying on your consent to process your personal data, you havethe right to withdraw your consent to such processing at any time. You can do this bycontacting our Customer Service Dept.
5. SHARING PERSONAL DATA, INCLUDING INTERNATIONAL TRANSFER
Due to the size and complexity of Trust Club’s operations it is not possible to name each ofour data recipients in this notice. However, Trust Club only shares your personal data withthe categories of data recipients listed below. Depending on our relationship with you, wemay share your personal data with:
A. the Trust Club client you represent;
B. Trust Club affiliates,
C. external custodians and strategic partners to Trust Club and Trust Club affiliates;
D. payment recipients and providers, beneficiaries, account nominees, intermediaries, andcorrespondent and agent banks;
E. market counterparties, and parties interested in or assuming risk in connection with atransaction (such as issuers of investments), shareholders selling securities in any
offering, co-managers, lead managers, underwriters, bookrunners, financial advisers or
any other relevant agent or advisor, including any agent or advisor to any of the above;
F. swap or trade repositories, swap data repositories or global trade repositories (or similar
facilities or institutions), and stock exchanges;
G. clearing houses, and clearing or settlement systems; and specialised payment network,
companies or institutions such as SWIFT;
H. service providers who provide a service to or operate a system on behalf of Trust Clubor the institutions or entities referred to in this section 5 (including non-affiliatedcompanies);
I. Trust Club’s lawyers, auditors and accountants and others providing professional advice;
J. relevant governmental, regulatory, supervisory, law enforcement, prosecuting, tax orsimilar authority or industry body under applicable laws or regulations of any relevant
jurisdiction;
K. your agents, representatives and other persons acting on your behalf or to whom you
instruct or authorise us to disclose your data;
L. with prospective purchasers and assignees in the event our business, or any part thereof,is sold or re-organised, or in the event that any product entered into with a client is sold,transferred or assigned in whole or in part;M. any other person or entity Trust Club reasonably thinks customary, necessary oradvisable for the processing purposes described in this notice or to whom Trust Club is
obliged by applicable law or regulation to make the disclosure; andN. to any other party where we have first obtained your prior consent.
Such data sharing may involve the transfer of personal data to any country in which TrustClub or a Trust Club affiliate conducts business or has a service provider or to other countries
for law enforcement purposes (including, without limitation, Japan, the United States ofAmerica and other countries whose data privacy laws are not as stringent as those in effect in
the United Kingdom, Switzerland or the European Union).
Trust Club will ensure that appropriate safeguards are in place to protect your personal data
and that transfer of your personal data is in compliance with applicable data protection laws.
Where required by applicable data protection laws, Trust Club has ensured that service
providers (including other Trust Club affiliates sign standard contractual clauses as approvedby the European Commission or other supervisory authority with jurisdiction over the
relevant data exporter. You can obtain a copy of any standard contractual clauses in place
which relate to transfers of your personal data by contacting our Customer Service Dept.
6. DIRECT MARKETING
You are entitled by law to object to the use of your personal data for direct marketing
purposes, including profiling to the extent that it is related to such direct marketing. You
can opt-out of receiving further any marketing emails by clicking the "unsubscribe'' link in
any such emails, or by contacting to our Customer Service Dept. or by writing to us at theaddress listed in the CONTACT DETAILS section.
7. DATA SUBJECT RIGHTS
You are entitled by law to the following rights in respect of your personal data:
A. INFORMATION AND ACCESS: You have the right to be provided with certain
information about Trust Club's processing of your personal data and access to that data
(subject to exceptions).
B. RECTIFICATION: If your personal data changes, we encourage you to inform us of
the change. You have the right to require inaccurate or incomplete personal data to be
updated or corrected.

C. ERASURE: You have the right to require that your data be erased in certain
circumstances, including where it is no longer necessary for us to process this data in
relation to the purposes for which we collected or processed the data, or if we consent
processed this data on the basis of your consent and you have since withdrawn thisconsent.
D. DATA PORTABILITY: Where we process your personal data on the basis of yourconsent, or where such processing is necessary for entering into or performing ourobligations under a contract with you, you may have the right to have the datatransferred to you or another controller in a structured, commonly used and machinereadable format, where this is technically feasible.
E. RIGHT TO OBJECT TO CERTAIN DATA PROCESSING: To the extent that
Trust Club is relying upon the lawfu1 basis of legitimate interest to process your personaldata, then you have the right to object to such processing, and Trust Club must stop suchprocessing unless we can either demonstrate compelling legitimate grounds for theprocessing that override your interests, rights and freedoms or where Trust Club needs
to process the data for the establishment, exercise or defence of legal claims. Normally,
where Trust Club relies upon legitimate interest as a basis for processing we believe that
we can demonstrate such compelling legitimate grounds, but we will consider eachcase on an individual basis.
F. RIGHT TO RESTRICTION OF PROCESSING: You have the right to restrict
Trust Club 's processing of your personal data while your request for data rectification
or objection to personal data processing is being considered, if we no longer need toprocess your data but you need that data in connection with a legal claim, or if ourprocessing is unlawfu1 but you do not want us to erase the data. If this right applies,
we will continue to store your data but will only further process it with your consent,
for the establishment, exercise or defence of legal claims, to protect the rights ofanother person, or for reasons of important public interest.
G. RIGHT TO WITHDRAW CONSENT: To the extent that Trust Club is relying upon
your consent to process personal data, you have the right to withdraw such consent at
any time. Please see section 4 of this notice.
H. COMPLAINT: You also have the right to lodge a complaint with a supervisory
authority, in particular that in your European Member State of residence, whereapplicable.
If you wish to exercise any of these rights you may do so by contacting our Customer Service
Dept. Alternatively you can send a written request to the Trust Club withwhich you have a relationship, clearly marked "Individual Rights - GDPR", using the details

set out in the CONTACT DETAILS section. The letter should be accompanied, in the caseof a request for further information and/or access, by a copy of your passport or other validmeans of identification. We may provide additional ways for you to exercise your rights fromtime to time.
8. RETENTION OF PERSONAL DATA
Trust Club and Trust Club affiliates retain personal data for varying time periods in order toassist us in complying with legal and regulatory obligations, to enable compliance with any
requests made by regulators or other relevant authorities and agencies, to enable us toestablish, exercise and defend legal rights and claims, and for other legitimate businessreasons.
Trust Club and Trust Club affiliates retain your personal data for the period of time required
for the purposes for which it was collected or to comply with legal, regulatory and Trust Club
policy requirements. This will usually be the period of your relationship or contract with TrustClub plus a period reflecting the length of time for which legal claims may be made following
the termination of such relationship or contract. Data will be kept for a shorter or longer
period of time if so required by law or a Trust Club policy or if the data becomes subject to alegal hold (for example, following a communication from our regulator).
9. SECURITY
Trust Club is committed to data security and we use appropriate technical and organizational
measures to protect personal data. Our information security policies and procedures areclosely aligned with widely accepted international standards and are reviewed regularly andupdated as necessary to meet our business needs, changes in technology, and regulatory
requirements.
10. UPDATES TO THIS NOTICE
The information in this notice may change from time to time - for example, the categories of
personal data that Trust Club collects, the purposes for which it is used and the ways in which
it is shared may change. This notice may be updated from time to time.