Sumitomo Mitsui DS AssetManagement (UK) Limited
Privacy Notice

Last Updated: 23 May 2024

Last

Privacy Notice

Table of Contents
1.

Scope ..................................................................................................................................................... 2

2.

About Us ................................................................................................................................................ 2

3.

What Personal Information We Collect, Why, and Lawful Basis ........................................................... 2

4.

Disclosure of Personal Data .................................................................................................................. 45.

Marketing and Opt-Out .......................................................................................................................... 4

6.

International Transfers ........................................................................................................................... 4

7.

Data Retention ....................................................................................................................................... 58.

Your Rights ............................................................................................................................................ 5

9.

How to Contact Us ................................................................................................................................. 5

10.

Cookie Policy ......................................................................................................................................... 5

11.

Update to our Notice .............................................................................................................................. 5

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Privacy Notice

1. Scope
Sumitomo Mitsui DS Asset Management (UK) Limited (the “Firm” or “we”) respects your concerns aboutprivacy.
This Privacy Notice (the “Notice”) describes how the Firm may collect, store, use and/or disclose (“process”)
Personal Data related to the Firm’s current clients and investors, prospective clients, website visitors, job
applicants, employees, third-party service providers and other parties whose information is provided to theFirm by any of the aforementioned parties, for example by the Firm’s current clients and investors (“you”).
This Notice describes how and why we process Personal Data and what rights you can exercise with respect
to your Personal Data.
This Notice applies when the Firm acts as the data controller within the meaning of the UK GDPR, as well as
when SMD-AM Funds (the “UCITS Fund”), the fund for which the Firm acts as the delegated investment
manager, act as a joint data controller together with Kroll (Luxembourg) Management Company S.à r.l., theUCITS Fund’s management company.
“Personal Data” shall have the meaning assigned to it under the UK General Data Protection Regulation(“UK GDPR”) and UK Data Protection Act 2018 (“UK DPA”) In the context of the UCITS Fund we manage,
Personal Data shall have the meaning assigned to is under the EU General Data Protection Regulation (EU)2016/679 (“EU GDPR”). The UK GDPR, UK DPA and EU GDPR are herein being referred to as the “DataProtection Legislation”.

2. About Us
The Firm is a UK UCITS manager managing on a delegated basis the UCITS Fund, a CSSF authorised fund.
The Firm also manages segregated mandates for institutional clients.
The Firm is registered in England and Wales (company registration number: 01660184). The Firm isregistered with the UK Information Commissioner’s Office (registration number: Z6469739).

3. What Personal Information We Collect, Why, and Lawful Basis
The Personal Data we collect relates to the individuals below.
Individuals

What personal information

Why do we collect thepersonal information

Lawful basis ofProcessing•••

Performance of acontract•

ConsentClients(Segregatedmandates)••••

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Personal identificationand contact information(such as name, postaladdress, email address,telephone number)
Financial information(such as accountinformation)
Data on transactions
Trading and settlement
information
Any other information
required to perform the••To process, manageand administer yourholding(s) in the Firm’s
separateaccounts/advisory
engagement(s)To respond to clients’inquiries
To send information,including client reports

Privacy Notice

requested services•

Generally, no Personal
Data as the Personal
Data are directed to BBH
Brown Brothers Harriman(Luxembourg) S.C.A.,
who acts as thecustodian, depositary
and transfer agent of theUCITS Fund•

Generally, no
Personally Data•

Generally, noPersonal Data•

Information to allow us toidentify and verify theidentity of theprospective client,including,if applicable, its
beneficial owner
Any information we may
obtain from third parties,
such as public
databases, third party
marketers, to allow us tomarket our business•To comply withapplicable legal andregulatory obligations,
including anti-money
laundering andterrorist financing laws
and regulations
To send promotional
material so as tomarket and improve
our business•

Performance of acontract•

Consent•

Legal andregulatory
obligation•

Legitimate
Interest•

Public interest

To allow prospective
clients and investors
to get in touch with us
To analyse visitors’
behaviours•

ConsentTo manage your job
application and assessyour qualifications
To comply with thepre-employment
screening obligation•

Performance of acontract•

Consent•

Legal andregulatory
obligation•

Legitimateinterest•

Public interest

UCITS
Investors

Prospective
clients andinvestors••
Websitevisitors

•
•
•

•
Job
ApplicantsandEmployees

•
•
•
•
•
•

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Information that is being
requested in the website
form located in theFirm’s website (i.e.,name and email
address)
IP address
Device, browser andgeographical information
Cookies•

Professional information,
which includes:
Resume/CV
Current/past
employment history
Education history
Professional
designations andqualifications
Work authorization
statusAny other voluntary
information provided by
the job applicant oremployee, for example
gender, sexual
orientation

•

•

•

Privacy Notice•
Third party
serviceproviders

Contact information(such as name, postaladdress, email address)••

To comply withapplicable legal andregulatory obligations,
including anti-money
laundering andterrorist financing laws
and regulations
To interact with thirdparty service
providers, including tosend queries andinformation so theproviders can performthe requested services•

Performance of acontract•

Consent•

Legal andregulatoryobligation•Legitimateinterest•

Public interest

4. Disclosure of Personal Data
We may disclose Personal Data to our parent company, Sumitomo Mitsui DS Asset Management Company,Limited, headquartered in Tokyo, Japan, to whom the portfolio management is delegated, and other groupcompanies, including Sumitomo Mitsui DS Asset Management (Hong Kong) Limited.
We may disclose Personal Data to third-party service providers to us and the UCITS Fund we manage on adelegated basis, including legal counsel, auditors, IT service providers, third-party email marketers, and othercounterparties. The UCITS Fund we manage may disclose Personal Data to Kroll (Luxembourg)Management Company S.à.r.l., who acts as its management company, and Brown Brothers Harriman(Luxembourg) S.C.A. (“BBH”), who acts as its custodian, transfer agent, administrator, and depositary. BBH
may in turn disclose Personal Data to its agents or other third parties, where necessary, to carry out theservices under the applicable investor service agreement with the UCITS Fund.
We may use third-party web analytics service providers on our sites, such as those of Google Analytics, tohelp us analyse how visitors use our website. The information processed for this purpose include user
engagement information (for example page views), device, browser and geographical information e.g.,
information based on IP address).
We may disclose Personal Data if (i) required by law or legal process, (ii) to law enforcement authorities,
regulators and/or other government entities and/or other competent authorities based on a lawful disclosure
request, (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or inconnection with an investigation of suspected or actual fraudulent or illegal activity; or (iv) to tax authorities.

5. Marketing and Opt-Out
Marketing, including by electronic means, requires express consent for you to receive marketing. You canunsubscribe from such marketing communications either by clicking on the opt-out link in the marketing
communication you will receive from us or third parties or by contacting us as set out in the “How to Contact
Us” section of this Notice.

6. International Transfers
To be able to provide cross-border services, we may transfer Personal Data outside of the UK to countries
that provide an adequate level of protection, for example, Luxembourg, Japan.
We may also transfer Personal Data to countries that do not provide an adequate level of protection, such as
the United States of America and Hong Kong. In such cases, the Firm will ensure that appropriate safeguards

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Privacy Notice

are in place for any such transfer such as the EU Standard Contractual Clauses adopted by the European
Commission, or the UK Appendix (or the UK International Data Transfer Agreement) adopted by theInformation Commissioner’s Office.

7. Data Retention
We will retain your Personal Data for as long as necessary to manage your investment, meet legal andregulatory obligations and carry out the purposes set out above (whichever is longer), and afterwards inaccordance with the Firm’s legal and regulatory obligations.

8. Your Rights
You have the following rights in connection with the processing of your Personal Data.
You have the right of access to the Personal Data and right to request the rectification of inaccurate Personal
Data we hold about you.
You have the right to request erasure, restriction of processing, portability, right to object, and to not be
subject to a decision based on automated processing.
You can also lodge a complaint about our processing with the appropriate regulator.
If you wish to exercise any of your rights, please contact us as set out below.

9. How to Contact Us
If you have any questions or comments about this Notice, you may contact us at mb_ukprivacy@smdam.co.jp.
You may also write us at:

Sumitomo Mitsui DS Asset Management (UK) Limited
Attn: Legal & Compliance
100 Liverpool Street
London EC2M 2ATUnited Kingdom

10. Cookie Policy
Please see our separate Cookie Policy.

11. Update to our Notice
We may update this Notice from time to time. The updated Notice will be indicated in “Last updated” date at
the top of this Notice. For any material changes to this Notice you will be notified either by us prominently
posting a copy the updated Notice or by directly sending you a notification as to the updates made to thisNotice.

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