Access to Client Data

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 of the outsourcing service provider

Type of information transmitted

Sub-Outsourcing

Location of sub-outsourcing(s)

Arcad

Provision of Internal audit services

Luxembourg

Policies, procedures, KYC clients and investors files for sampling testing

No

N/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)

 

 

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

Cloud based e-signature solution that allows users to send, track and manage signature processes

Name of the client, e-mail address.
Documents are temporarily stored in the YouSign environment but the service provider does not have logical access to confidential data

France