Privacy Policy

Data Protection Policy

Effective 10 May 2024

We, FBS-FUND GENERAL PARTNER G.P. SarI, recognize the importance of privacy and the sensitivity of personal data. As required under EU Personal Data Protection Act (“PDPA”), the purpose of this Data Protection Policy is to inform you of how we collect, use and/or disclose your personal data submitted by you when you apply for or subscribe to or realize unit(s) of fund(s) managed by us (“unit(s)”) (collectively known as “unitholder”), when you use our electronic services through online platforms (such as website) and/or interact with us including through meetings, telephone conversations or through any correspondence with us.
By interacting with us, by accessing and using our website, by submitting information to us or by becoming our unitholder, you agree and consent to us collecting, using and disclosing your personal data in the manner contemplated in this Data Protection Policy.
This Data Protection Policy may be updated from time to time. We would advise you to check this Data Protection Policy on our website at www.fbsgeneralpartner.com from time to time for updates. By continuing to be our unitholder, to use our website or to communicate with us after any updates to this Data Protection Policy, it would confirm and indicate your acceptance to the updates to this Data Protection Policy.

What Personal Data Do We Collect?

Personal data generally means any information that identifies you. Your personal data is collected, processed, used and/or disclosed by us when you submit your application to subscribe, redeem, cancel, and switch the unit(s), when you access our website or interact with us and, from time to time, thereafter.
The type of personal data collected, processed, used and/or disclosed by us includes:
1. name, date of birth, country of birth, residential address, nationality, passport number, banking details, signatures and all such other information stipulated in the application form for the unit(s);
2. contact details including addresses, email addresses, telephone and facsimile numbers.
3. such other information relevant or required:
a) in relation to or in connection with you applying for, subscribing to or realizing the
unit(s); and
b) to comply with legal and regulatory requirements; and
4. any additional information provided by you or by third parties about you.
Source of Personal Data
Personal data collected will mainly be from you. However, some personal data may also be collected by us from other available sources including but not limited to credit reporting agencies, government department or agencies, public registries, publications and events.

How We Use Your Personal Data?

Your personal data is collected, used and/or disclosed by us for purposes relating to your subscription or holding of unit(s), which may include but not limited to the following:
1. to verify your identity.
2. to correspond with you.
3. maintaining the register.
4. processing applications for subscriptions, realizations and switching of units, and payments to holders.
5. monitoring late trading and market timing practices.
6. complying with applicable anti-money laundering and anti-terrorist financing laws, regulations and rules.
7. complying with any legal, governmental or regulatory requirements of any relevant jurisdiction (including any disclosure or notification requirements);
8. complying with the requirements or directions of any regulatory authority.
9. providing client-related services, including customer support and dissemination of notices and reports; and
10. any other purposes relating to any of the above.

Disclosure of Your Personal Data to Third Parties
Subject to the provisions of any applicable law, we may be required to disclose your personal data to third parties. Third parties to whom your personal data may be disclosed by us are as follows:

1. FBS_FUND’s related corporations.
2. any persons required for purposes relating to or in connection with you applying for, subscribing or being a unitholder including but not limited to regulatory bodies.
3. any person for the purposes of compliance with legal and regulatory requirements.
4. our data processors i.e. third party would we engage to process personal data on our behalf including but not limited to our trustees and registrar for unitholders, the agents or distributors, corporate secretarial companies, website service provider, computing services, archival storage, banks and financial institutions;
5. our professional advisors and financiers including but not limited to legal advisors, tax advisors, financial advisors, valuers, auditors and insurance brokers; and
6. any other party to whom you authorize us to disclose your personal data to.

We may share your personal data with our related corporations and third parties listed whether in or outside Luxembourg. When doing so, we will require them to ensure that your personal data disclosed to them are kept confidential and secure.

Data Security

We will take all reasonable efforts to protect your personal data, including the use of encryption technology. We can however not completely guarantee the security of any personal data we have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, Trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
While we strive to protect your personal data, we cannot ensure the security of the information you transmit to us via the internet or when you use our electronic services, and we urge you to take every precaution to protect your personal data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

Third-Party Sites

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

Data Access and Data Correction

If you wish to request:
a) for access to your personal data.
b) for your personal data to be corrected or updated; or
c) to withdraw your consent or limit the use of your personal data,

Please submit your written request to Data Protection Officer, see Contact Us.

An administrative charge may be imposed for any request above. Further, we reserve the right to refuse your requests for any reasons permitted under law.
If you withdraw your consent to any or all of your personal data, depending on the nature of your request, it may result in us not being able to communicate or correspond with you, not able to grant you access to our online platforms and/or reject your application to subscribe for the unit(s).

Disclaimer

Where you provide any third party information to us including but not limited to family information, it is our assumption that such information is accurate, up to date and complete and that you have obtained the necessary consent of such third party to disclose the same.

Governing Law

This Data Protection Policy and your use of this website shall be governed by the laws of Luxembourg, and shall be subjected to the exclusive jurisdiction of the courts of Luxembourg.