Notification Of Data Migration

Dear Client,

We would hereby like to inform you about the migration of our data and as a consequence the transfer of personal data in relation to your fund(s) administered by us.

With the aim of providing you with the best service, we are planning to transfer all data currently located in the Netherlands to our Microsoft Cloud environment in Switzerland.

Switzerland is considered to be a secure third country by the European Union, and the European Commission has confirmed this by adopting an adequacy decision, meaning that personal data can flow from the Netherlands to Switzerland without any further safeguards being necessary.

Moreover, the Microsoft Cloud environment has robust safeguards in place to ensure the safety and security of the data stored. The Cloud is also ISO 27001 certified, meaning that the data will be processed in a manner that ensures appropriate security of the personal data including protection against unauthorized or unlawful processing, accidental loss, and destruction or damage.

The security and control framework as well as the procedures for the management of access rights currently in place will remain unchanged. As a result of the migration to the Microsoft Cloud, the security protocols in relation to our mailboxes and e-mail communication will be enhanced.

The transfer of data will have no impact on the provisions included in the data protocol in place between you and Circle Partners. However, we have updated the data protocol and data privacy notice to reflect the transfer of data to a third country.

No action is required from your side and no action is required towards the investors in your fund.

These documents are available at www.circlepartners.com. If you wish to receive information on the new Cloud environment, please reach out to your Account Manager.

Kind regards,

Circle Partners

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