Preliminary NAV Calculation
Pursuant to Article 41 (2a) of the amended Law of 5 April 1993 on the financial sector (Obligation of Professional Secrecy) (“LFS”), and in accordance with approval provided by the Commission de Surveillance du Secteur Financier (“CSSF”), Harmonic Fund Services Luxembourg S.A. (“HFSLSA”) is permitted to outsource certain activities to Harmonic Fund Services Ireland Limited (“HFSIL”). HFSIL is authorized to perform the preliminary NAV calculation for certain undertakings for collective investment on behalf of clients of HFSSLA (the “Outsourced Services”). HFSLSA shall retain full oversight and overall responsibility for the Outsourced Services at all times. In this context certain investor data including detailed cash transactions and balances, portfolio trades and pricing, entity expenses and any other support needed in order to corroborate the evidence of any cash, trade or entity expense transaction may be transmitted from Luxembourg to Ireland.
Cloud Outsourcing
Pursuant to Article 41 (2a) of the amended Law of 5 April 1993 on the financial sector (Obligation of Professional Secrecy) (“LFS”), and in accordance with CSSF Circular 22/806 on outsourcing arrangements, Harmonic Fund Services Luxembourg S.A. (“HFSLSA”) is permitted to outsource its VMware servers function and data storage to Microsoft Corporation (“Microsoft”) through its affiliated resource operator, Harmonic Fund Services Canada Inc. The primary Microsoft data center provider is located in Dublin, Ireland, the secondary Microsoft data center provider is located in Amsterdam in the Netherlands and the third data center provider is in Ontario, Canada.
Microsoft is authorized to perform the VMware servers function and storage of clients’ data on the Cloud on behalf of HFSLSA (the “Outsourced Cloud Services”). All client and investor data in the possession of HFSLSA such as investor transactions, balances, AML/KYC data, personal data as defined in the General Data Protection Regulation (Regulation 2016/679)(“GDPR”), accounting data, portfolio trading and valuation data, emails, communications and other files will be transferred to Microsoft. HFSLSA shall retain full oversight and overall responsibility for the Outsourced Cloud Services at all times. In this context all client and investor data may be stored on the Microsoft cloud and thus transmitted from Luxembourg to the relevant Microsoft data centers in Ireland, the Netherlands and/or Canada.
LAST REVISED: 13 January, 2023