On this page there are four privacy notices which deal with the processing of Personal Information in different contexts.  Please note that multiple privacy notices below may be applicable to you. For ease of navigation, you can simply click on the desired Privacy Notice and you will be brought directly to that section.

• Privacy Notice – www.theAMX.com and other AMX websites
• Investor Privacy Notice - Asset Management Exchange Feeder ICAV Fund
• Investor Privacy Notice – Carne Global Fund Managers (Ireland) Limited in respect of the Asset Management Exchange CCF and the Asset Management Exchange UCITS CCF 
• Asset Manager Privacy Notice

Privacy Notice – www.theAMX.com and other AMX websites

Last updated December 2023

Introduction

This privacy notice describes how The Asset Management Exchange (“AMX”) in our capacity as controller generally collects and processes personal information collected through www.theAMX.com and other websites controlled by AMX, including www.AMXConnect.com and theamx.com/solutions/amx-zero/(“AMX Websites”). The Asset Management Exchange and AMX are trading names of Carne Global Fund Managers (Ireland) Limited, ( Carne International Financial Services (UK) Ltd  and The Asset Management Exchange (IP Co.) Limited . 

This privacy notice may be revised from time to time to reflect changes in law or changes in AMX’s business operation. 

1. About Us

This privacy notice only applies to AMX Websites and any other AMX website where a link to this privacy notice is provided.

Websites and specific web pages linked from AMX Websites may be subject to separate terms of use (including separate privacy notices). AMX is not responsible for those websites. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for satisfying yourself with such notices and using such websites in accordance with the applicable terms of use. AMX is not responsible for how your Personal Information is handled by such third-party websites.

2. Personal Data that we process

“Personal Information” or “personal data” is information that identifies you as an individual or relates to an identifiable individual.  The Personal Information we may collect through our websites includes:

1. your name, address, occupation and other contact information;
2. information regarding your dealings with us;
3. any interest you have in relation to our services or our practice areas (including job openings); 
4. any information you may voluntarily submit to us by completing any form on our websites; and
5. details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

We collect Personal Information in various ways:

1. from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;
2. from the content of surveys that you may complete on our website;
3. from setting up a user profile and facilitating your access to AMXConnect;
4. from ‘cookies’ and other similar tools deployed on our websites (for further information regarding cookies used on our websites, please visit the Cookie Notice at the bottom of this page. 

When you provide information as a client of an AMX entity in connection with it providing professional services to you. Such information may be collected through AMX Websites when clients access AMX client links within this website. Access will be subject to the terms of business AMX has with clients and any additional terms and conditions of use attached to those sites.

3. Purposes of processing

Personal data that you or your company provides to AMX, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in a Fund;
• processing your company’s application to become a Sub-Investment Manager in connection with a Fund;
• providing other services or products to your company;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• to facilitate your participation in interactive features you may choose to use on our websites;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• to correspond with you, notify you of events or changes to our services, or otherwise to respond to your queries and requests for information, which may include marketing to you, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
• maintaining appropriate business records, including maintaining appropriate registers of shareholders;
• statistical analysis and market research;
• audits, fraud monitoring and prevention;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; 
• establishing, exercising or defending legal claims; and
• to monitor website usage to help us enhance, improve or modify our websites and to identifying usage trends that help us determine the effectiveness of our promotional campaigns and help us to develop new products and services.

4. Legal basis for processing 

We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

1. for our legitimate interests, for example to provide services to our clients, to ensure that the services we provide are appropriate for our clients’ requirements, to improve our services, to enable us to comply with regulatory and governance requirements and to manage our business in an efficient way;
2. for the legitimate interests of our clients and other third parties, for example to ensure that any financial services we provide to clients are suitable, to verify that our services are only made available to certain categories of investor and to provide a high quality of service; and/or
3. to comply with our legal obligations, regulatory requirements and governance procedures.

When we process Personal Information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that the privacy of individuals is protected and to ensure that those legitimate interests are not overridden by the interests or fundamental rights and freedoms of individuals. 

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above. We may also disclose your Personal Information to independent third parties as follows:

1. to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website, our marketing activities and other services;
2. to third parties involved with events that you register for, to facilitate your participation in those events;
3. if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
4. in order to enforce or apply our website terms of use, or to protect the rights, privacy, safety or property of AMX, our clients, affiliates or other parties;
5. in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
6. in accordance with the separate terms and conditions of use that may attach to AMX website links.

6. Cross border transfer

In connection with the above purposes we may transfer your Personal Information outside the European Economic Area and the United Kingdom, including to the United States  and other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission.

Further details of the measures that we have taken in this regard and the territories to which your Personal Information may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

If you would like to exercise your data protection rights, you may contact us using the details found in the “Contact” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to undertake any services or requests that you initiated prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the UK Information Commissioner’s Office, at www.ico.org.uk concerns and/or the Irish Data Commissioner’s Office at www.dataprotection.ie , as applicable. We ask that you please attempt to resolve any issue with us first by contacting us – please see section 11 below for our contact information.

9. Children and minors

Our websites and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

10. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

11. Contact

If you have any questions or comments regarding this privacy notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

Investor Privacy Notice - Asset Management Exchange Feeder ICAV

Last Updated: December 2023

Introduction

This privacy notice describes how and why Asset Management Exchange Feeder ICAV of Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576, Ireland (the “Company”, “we”, “us”, “our”) in our capacity as data controller and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange Feeder ICAV (the “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel.

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

1. About us

The Company, as controller of the personal data collected via the subscription application form, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal Data that we Process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details. 

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in the Fund;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• for direct marketing purposes, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
• maintaining appropriate business records, including maintaining appropriate registers of shareholders;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • preventing, investigating or detecting theft, fraud or other criminal activity;
  • pursuing our corporate and social responsibility objectives;
• where you are an individual investor, that this is necessary to take steps at your request prior to entering into our contract with you and for the performance of our contract with you;
• in certain limited circumstances, your consent.

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Administrator;
• to Carne Global Fund Managers (Ireland) Limited the Fund’s AIFM;
• to the Fund’s distributors;
• to the Fund’s depositary;
• to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
• to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
• to other members of our corporate group.

6. Cross border transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and the United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

 AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.  We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller; and

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and Minors

Our website and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy notice

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

Investor Privacy Notice - Carne Global Fund Managers (Ireland) Limited  in respect of the Asset Management Exchange CCF and the Asset Management Exchange UCITS CCF

Last Updated: December 2023

Introduction

This notice describes how and why Carne Global Fund Managers (Ireland) Limited  , acting on behalf of Asset Management Exchange CCF (the “Company”, “we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange CCF and Asset Management Exchange CCF (each, a “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel..

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

1. About us

The Company, as the controller of the personal data collected via the subscription application form, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal data that we process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details. 

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in the Fund;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• for direct marketing purposes, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Deed of Constitution;
• maintaining appropriate business records, including maintaining appropriate registers of unitholders;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • preventing, investigating or detecting theft, fraud or other criminal activity;
  • pursuing our corporate and social responsibility objectives;
• in certain limited circumstances, your consent.

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Administrator;
• to Carne Global Fund Managers (Ireland) Limited , the Fund’s investment manager;
• to the Fund’s distributors;
• to the Fund’s depositary;
• to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
• to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
• to other members of our corporate group.

6. Cross border transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and the United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission. 

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to request that we restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;

in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and minors

Our website and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, AMX via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7N.

Manager privacy notice

Last Updated: December 2023 
Employees of Current and Prospective Sub-Investment Managers for the AMX Platform

Introduction

This notice describes how and why The Asset Management Exchange (“we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with its engagement with current and prospective sub-investment managers (“Sub-Investment Managers”) for the Asset Management Exchange CCF, Asset Management Exchange UCITS CCF and the Asset Management Exchange Master ICAV (the “Funds”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to employees of Sub-Investment Managers. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a Sub-Investment Manager with which an individual is associated.

1. About us 

The Company, as the controller of the personal data collected via our dealings with you and your company, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal Data that we Process

We collect personal data relating to you in connection with our dealings with you or your company, including your name, signature, email address, and other contact details. 

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your company’s application to become a Sub-Investment Manager in connection with the Funds;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company;
• for direct marketing purposes, subject to any preferences you communicate to us;
• maintaining appropriate business records;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your company;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • promoting our business, and operating as the investment manager in relation to the Funds;
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • pursuing our corporate and social responsibility objectives;
• in certain limited circumstances, your consent.

5. Recipients of Data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Funds’ Administrator;
• to Carne Global Fund Managers (Ireland) Limited , the Funds’ AIFM or UCITS management company;
• to the Funds’ distributors;
• to the Funds’ depositary;
• to auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to other members of our corporate group.

6. Cross Border Transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to request that we restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint to us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and Minors

Our website and services relating to the Company or Fund are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

Cookie Notice

Full details of our cookie usage are available by visiting the Cookie Notice at the bottom of this page. 

On this page there are four privacy notices which deal with the processing of Personal Information in different contexts.  Please note that multiple privacy notices below may be applicable to you. For ease of navigation, you can simply click on the desired Privacy Notice and you will be brought directly to that section.

• Privacy Notice – www.theAMX.com and other AMX websites
• Investor Privacy Notice - Asset Management Exchange Feeder ICAV Fund
• Investor Privacy Notice – Carne Global Fund Managers (Ireland) Limited in respect of the Asset Management Exchange CCF and the Asset Management Exchange UCITS CCF 
• Asset Manager Privacy Notice

Privacy Notice – www.theAMX.com and other AMX websites

Last updated December 2023

Introduction

This privacy notice describes how The Asset Management Exchange (“AMX”) in our capacity as controller generally collects and processes personal information collected through www.theAMX.com and other websites controlled by AMX, including www.AMXConnect.com and theamx.com/solutions/amx-zero/(“AMX Websites”). The Asset Management Exchange and AMX are trading names of Carne Global Fund Managers (Ireland) Limited, ( Carne International Financial Services (UK) Ltd  and The Asset Management Exchange (IP Co.) Limited . 

This privacy notice may be revised from time to time to reflect changes in law or changes in AMX’s business operation. 

1. About Us

This privacy notice only applies to AMX Websites and any other AMX website where a link to this privacy notice is provided.

Websites and specific web pages linked from AMX Websites may be subject to separate terms of use (including separate privacy notices). AMX is not responsible for those websites. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for satisfying yourself with such notices and using such websites in accordance with the applicable terms of use. AMX is not responsible for how your Personal Information is handled by such third-party websites.

2. Personal Data that we process

“Personal Information” or “personal data” is information that identifies you as an individual or relates to an identifiable individual.  The Personal Information we may collect through our websites includes:

1. your name, address, occupation and other contact information;
2. information regarding your dealings with us;
3. any interest you have in relation to our services or our practice areas (including job openings); 
4. any information you may voluntarily submit to us by completing any form on our websites; and
5. details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

We collect Personal Information in various ways:

1. from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;
2. from the content of surveys that you may complete on our website;
3. from setting up a user profile and facilitating your access to AMXConnect;
4. from ‘cookies’ and other similar tools deployed on our websites (for further information regarding cookies used on our websites, please visit the Cookie Notice at the bottom of this page. 

When you provide information as a client of an AMX entity in connection with it providing professional services to you. Such information may be collected through AMX Websites when clients access AMX client links within this website. Access will be subject to the terms of business AMX has with clients and any additional terms and conditions of use attached to those sites.

3. Purposes of processing

Personal data that you or your company provides to AMX, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in a Fund;
• processing your company’s application to become a Sub-Investment Manager in connection with a Fund;
• providing other services or products to your company;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• to facilitate your participation in interactive features you may choose to use on our websites;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• to correspond with you, notify you of events or changes to our services, or otherwise to respond to your queries and requests for information, which may include marketing to you, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
• maintaining appropriate business records, including maintaining appropriate registers of shareholders;
• statistical analysis and market research;
• audits, fraud monitoring and prevention;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; 
• establishing, exercising or defending legal claims; and
• to monitor website usage to help us enhance, improve or modify our websites and to identifying usage trends that help us determine the effectiveness of our promotional campaigns and help us to develop new products and services.

4. Legal basis for processing 

We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

1. for our legitimate interests, for example to provide services to our clients, to ensure that the services we provide are appropriate for our clients’ requirements, to improve our services, to enable us to comply with regulatory and governance requirements and to manage our business in an efficient way;
2. for the legitimate interests of our clients and other third parties, for example to ensure that any financial services we provide to clients are suitable, to verify that our services are only made available to certain categories of investor and to provide a high quality of service; and/or
3. to comply with our legal obligations, regulatory requirements and governance procedures.

When we process Personal Information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that the privacy of individuals is protected and to ensure that those legitimate interests are not overridden by the interests or fundamental rights and freedoms of individuals. 

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above. We may also disclose your Personal Information to independent third parties as follows:

1. to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website, our marketing activities and other services;
2. to third parties involved with events that you register for, to facilitate your participation in those events;
3. if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
4. in order to enforce or apply our website terms of use, or to protect the rights, privacy, safety or property of AMX, our clients, affiliates or other parties;
5. in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
6. in accordance with the separate terms and conditions of use that may attach to AMX website links.

6. Cross border transfer

In connection with the above purposes we may transfer your Personal Information outside the European Economic Area and the United Kingdom, including to the United States  and other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission.

Further details of the measures that we have taken in this regard and the territories to which your Personal Information may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

If you would like to exercise your data protection rights, you may contact us using the details found in the “Contact” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to undertake any services or requests that you initiated prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the UK Information Commissioner’s Office, at www.ico.org.uk concerns and/or the Irish Data Commissioner’s Office at www.dataprotection.ie , as applicable. We ask that you please attempt to resolve any issue with us first by contacting us – please see section 11 below for our contact information.

9. Children and minors

Our websites and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

10. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

11. Contact

If you have any questions or comments regarding this privacy notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

Investor Privacy Notice - Asset Management Exchange Feeder ICAV

Last Updated: December 2023

Introduction

This privacy notice describes how and why Asset Management Exchange Feeder ICAV of Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576, Ireland (the “Company”, “we”, “us”, “our”) in our capacity as data controller and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange Feeder ICAV (the “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel.

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

1. About us

The Company, as controller of the personal data collected via the subscription application form, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal Data that we Process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details. 

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in the Fund;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• for direct marketing purposes, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
• maintaining appropriate business records, including maintaining appropriate registers of shareholders;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • preventing, investigating or detecting theft, fraud or other criminal activity;
  • pursuing our corporate and social responsibility objectives;
• where you are an individual investor, that this is necessary to take steps at your request prior to entering into our contract with you and for the performance of our contract with you;
• in certain limited circumstances, your consent.

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Administrator;
• to Carne Global Fund Managers (Ireland) Limited the Fund’s AIFM;
• to the Fund’s distributors;
• to the Fund’s depositary;
• to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
• to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
• to other members of our corporate group.

6. Cross border transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and the United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

 AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.  We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller; and

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and Minors

Our website and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy notice

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

Investor Privacy Notice - Carne Global Fund Managers (Ireland) Limited  in respect of the Asset Management Exchange CCF and the Asset Management Exchange UCITS CCF

Last Updated: December 2023

Introduction

This notice describes how and why Carne Global Fund Managers (Ireland) Limited  , acting on behalf of Asset Management Exchange CCF (the “Company”, “we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange CCF and Asset Management Exchange CCF (each, a “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel..

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

1. About us

The Company, as the controller of the personal data collected via the subscription application form, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal data that we process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details. 

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in the Fund;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• for direct marketing purposes, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Deed of Constitution;
• maintaining appropriate business records, including maintaining appropriate registers of unitholders;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • preventing, investigating or detecting theft, fraud or other criminal activity;
  • pursuing our corporate and social responsibility objectives;
• in certain limited circumstances, your consent.

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Administrator;
• to Carne Global Fund Managers (Ireland) Limited , the Fund’s investment manager;
• to the Fund’s distributors;
• to the Fund’s depositary;
• to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
• to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
• to other members of our corporate group.

6. Cross border transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and the United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission. 

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to request that we restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;

in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and minors

Our website and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, AMX via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7N.

Manager privacy notice

Last Updated: December 2023
Employees of Current and Prospective Sub-Investment Managers for the AMX Platform

Introduction

This notice describes how and why The Asset Management Exchange (“we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with its engagement with current and prospective sub-investment managers (“Sub-Investment Managers”) for the Asset Management Exchange CCF, Asset Management Exchange UCITS CCF and the Asset Management Exchange Master ICAV (the “Funds”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to employees of Sub-Investment Managers. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a Sub-Investment Manager with which an individual is associated.

1. About us 

The Company, as the controller of the personal data collected via our dealings with you and your company, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal Data that we Process

We collect personal data relating to you in connection with our dealings with you or your company, including your name, signature, email address, and other contact details. 

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your company’s application to become a Sub-Investment Manager in connection with the Funds;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company;
• for direct marketing purposes, subject to any preferences you communicate to us;
• maintaining appropriate business records;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your company;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • promoting our business, and operating as the investment manager in relation to the Funds;
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • pursuing our corporate and social responsibility objectives;
• in certain limited circumstances, your consent.

5. Recipients of Data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Funds’ Administrator;
• to Carne Global Fund Managers (Ireland) Limited , the Funds’ AIFM or UCITS management company;
• to the Funds’ distributors;
• to the Funds’ depositary;
• to auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to other members of our corporate group.

6. Cross Border Transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to request that we restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint to us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and Minors

Our website and services relating to the Company or Fund are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

On this page there are four privacy notices which deal with the processing of Personal Information in different contexts.  Please note that multiple privacy notices below may be applicable to you. For ease of navigation, you can simply click on the desired Privacy Notice and you will be brought directly to that section.

• Privacy Notice – www.theAMX.com and other AMX websites
• Investor Privacy Notice - Asset Management Exchange Feeder ICAV Fund
• Investor Privacy Notice – Carne Global Fund Managers (Ireland) Limited in respect of the Asset Management Exchange CCF, the Asset Management Exchange UCITS CCF and the Asset Management Exchange UCITS ICAV.

Privacy Notice – www.theAMX.com and other AMX websites

Last updated December 2023 

Introduction

This privacy notice describes how The Asset Management Exchange (“AMX”) in our capacity as controller generally collects and processes personal information collected through www.theAMX.com and other websites controlled by AMX, including www.AMXConnect.com and theamx.com/solutions/amx-zero/(“AMX Websites”). The Asset Management Exchange and AMX are trading names of Carne Global Fund Managers (Ireland) Limited, ( Carne International Financial Services (UK) Ltd  and The Asset Management Exchange (IP Co.) Limited . 

This privacy notice may be revised from time to time to reflect changes in law or changes in AMX’s business operation. 

1. About Us

This privacy notice only applies to AMX Websites and any other AMX website where a link to this privacy notice is provided.

Websites and specific web pages linked from AMX Websites may be subject to separate terms of use (including separate privacy notices). AMX is not responsible for those websites. These third-party websites will be governed by different terms of use (including privacy notices) and you are solely responsible for satisfying yourself with such notices and using such websites in accordance with the applicable terms of use. AMX is not responsible for how your Personal Information is handled by such third-party websites.

2. Personal Data that we process

“Personal Information” or “personal data” is information that identifies you as an individual or relates to an identifiable individual.  The Personal Information we may collect through our websites includes:

1. your name, address, occupation and other contact information;
2. information regarding your dealings with us;
3. any interest you have in relation to our services or our practice areas (including job openings); 
4. any information you may voluntarily submit to us by completing any form on our websites; and
5. details of your visits to and usage of our website including the date and time of your visit, the internet address from which you visited and the resources on our website that you viewed.

We collect Personal Information in various ways:

1. from any form you may complete and submit through our websites, for example information collected from the “Contact Us” page of our website;
2. from the content of surveys that you may complete on our website;
3. from setting up a user profile and facilitating your access to AMXConnect;
4. from ‘cookies’ and other similar tools deployed on our websites (for further information regarding cookies used on our websites, please visit the Cookie Notice at the bottom of this page.

When you provide information as a client of an AMX entity in connection with it providing professional services to you. Such information may be collected through AMX Websites when clients access AMX client links within this website. Access will be subject to the terms of business AMX has with clients and any additional terms and conditions of use attached to those sites.

3. Purposes of processing

Personal data that you or your company provides to AMX, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in a Fund;
• processing your company’s application to become a Sub-Investment Manager in connection with a Fund;
• providing other services or products to your company;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• to facilitate your participation in interactive features you may choose to use on our websites;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• to correspond with you, notify you of events or changes to our services, or otherwise to respond to your queries and requests for information, which may include marketing to you, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
• maintaining appropriate business records, including maintaining appropriate registers of shareholders;
• statistical analysis and market research;
• audits, fraud monitoring and prevention;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; 
• establishing, exercising or defending legal claims; and
• to monitor website usage to help us enhance, improve or modify our websites and to identifying usage trends that help us determine the effectiveness of our promotional campaigns and help us to develop new products and services.

4. Legal basis for processing 

We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:

1. for our legitimate interests, for example to provide services to our clients, to ensure that the services we provide are appropriate for our clients’ requirements, to improve our services, to enable us to comply with regulatory and governance requirements and to manage our business in an efficient way;
2. for the legitimate interests of our clients and other third parties, for example to ensure that any financial services we provide to clients are suitable, to verify that our services are only made available to certain categories of investor and to provide a high quality of service; and/or
3. to comply with our legal obligations, regulatory requirements and governance procedures.

When we process Personal Information to meet our legitimate interests or those of a third party, we put in place robust safeguards to ensure that the privacy of individuals is protected and to ensure that those legitimate interests are not overridden by the interests or fundamental rights and freedoms of individuals. 

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above. We may also disclose your Personal Information to independent third parties as follows:

1. to third party service providers such as entities providing customer service, email delivery, auditing, hosting our website, our marketing activities and other services;
2. to third parties involved with events that you register for, to facilitate your participation in those events;
3. if we are obliged to disclose your Personal Information under applicable law or regulation, which may include laws outside your country of residence;
4. in order to enforce or apply our website terms of use, or to protect the rights, privacy, safety or property of AMX, our clients, affiliates or other parties;
5. in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
6. in accordance with the separate terms and conditions of use that may attach to AMX website links.

6. Cross border transfer

In connection with the above purposes we may transfer your Personal Information outside the European Economic Area and the United Kingdom, including to the United States  and other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission.

Further details of the measures that we have taken in this regard and the territories to which your Personal Information may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

If you would like to exercise your data protection rights, you may contact us using the details found in the “Contact” section below.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to undertake any services or requests that you initiated prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. Where that is the case, we will implement reasonable measures to ensure that this data remains secure and is not accessed or used in any way.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the UK Information Commissioner’s Office, at www.ico.org.uk concerns and/or the Irish Data Commissioner’s Office at www.dataprotection.ie , as applicable. We ask that you please attempt to resolve any issue with us first by contacting us – please see section 11 below for our contact information.

9. Children and minors

Our websites and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

10. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

11. Contact

If you have any questions or comments regarding this privacy notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

Investor Privacy Notice - Asset Management Exchange Feeder ICAV

Last Updated: December 2023

Introduction

This privacy notice describes how and why Asset Management Exchange Feeder ICAV of Riverside One, Sir John Rogerson’s Quay, Dublin 2, D02 X576, Ireland (the “Company”, “we”, “us”, “our”) in our capacity as data controller and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange Feeder ICAV (the “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel.

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

1. About us

The Company, as controller of the personal data collected via the subscription application form, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal Data that we Process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details. 

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in the Fund;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• for direct marketing purposes, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Instrument of Incorporation;
• maintaining appropriate business records, including maintaining appropriate registers of shareholders;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • preventing, investigating or detecting theft, fraud or other criminal activity;
  • pursuing our corporate and social responsibility objectives;
• where you are an individual investor, that this is necessary to take steps at your request prior to entering into our contract with you and for the performance of our contract with you;
• in certain limited circumstances, your consent.

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Administrator;
• to Carne Global Fund Managers (Ireland) Limited the Fund’s AIFM;
• to the Fund’s distributors;
• to the Fund’s depositary;
• to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
• to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
• to other members of our corporate group.

6. Cross border transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and the United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa.  If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission.

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

 AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise.  We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller; and
• .

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and Minors

Our website and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy notice

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

Investor Privacy Notice - Carne Global Fund Managers (Ireland) Limited  in respect of the Asset Management Exchange CCF, the Asset Management Exchange UCITS CCF and the Asset Management Exchange UCITS ICAV

Last Updated: December 2023

Introduction

This notice describes how and why Carne Global Fund Managers (Ireland) Limited  , acting on behalf of Asset Management Exchange CCF (the “Company”, “we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with investments in Asset Management Exchange CCF ,Asset Management Exchange CCF (each, a “Fund”) and the Asset Management Exchange UCITS ICAV. (each, a “Fund”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to any individual investor in the Fund and personal information relating to individuals associated with corporate investors in the Fund, such as a corporate investor’s directors, shareholders, employees, professional advisers and other personnel. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a corporate investor with which an individual is associated. Corporate investors should ensure that this notice is provided to any individual whose personal data the corporate investor has provided to us, such as its directors, shareholders, employees, and other personnel..

We also refer you to our CRS Customer Information Notice contained in our subscription application form and the information under the heading “FATCA & CRS Self-Certification” and “Individual (Controlling Person’s) Self-Certification” in the subscription application form which contain certain further information relating to our use of your personal information.

1. About us

The Company, as the controller of the personal data collected via the subscription application form, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal data that we process

We collect personal data relating to you that is provided to us in the subscription application form and in connection with our dealings with you or your company in relation to investments in the Fund, including your name, signature, postal address, email address, fax number, date of birth, and other contact details. 

We may also collect personal data in relation to you in connection with ensuring compliance with our legal obligations including PPS number, passport number, photographic identification and verification such as copies of your passport and address verification. For the purposes of carrying out due diligence, we may also collect information relating to your status as an ultimate beneficial owner of an entity, or as a politically exposed person.

We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls, and in connection with our administration of you or your company’s investment in the Fund. We may record telephone calls for the purposes of record keeping, security and training.

In addition, we may collect personal data relating to you from third party sources in connection with complying with legislation relating to anti-money laundering, taxation, and other legislation applicable to investment funds.

Please note that some of the information required by our subscription application forms is necessary in order for us to administer your or your company’s investment in the Fund. The Administrator has the discretion to decline an application for investment in the Fund in the event that the required details are not provided.

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your or your company’s application to become an investor in the Fund;
• establishing your identity, and providing, servicing and administering your or your company’s investment;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company, including under applicable law regarding anti- money laundering, taxation, the regulation of collective investment schemes, or the provision of financial services;
• for direct marketing purposes, subject to any preferences you communicate to us;
• if applicable, processing the fact that you are a politically exposed person, to comply with applicable legal obligations;
• to communicate with you by way of notice pursuant to applicable legislation or the Fund’s Deed of Constitution;
• maintaining appropriate business records, including maintaining appropriate registers of unitholders;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your or your company’s investment;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • preventing, investigating or detecting theft, fraud or other criminal activity;
  • pursuing our corporate and social responsibility objectives;
• in certain limited circumstances, your consent.

5. Recipients of data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Administrator;
• to Carne Global Fund Managers (Ireland) Limited , the Fund’s investment manager;
• to the Fund’s distributors;
• to the Fund’s depositary;
• to the Revenue Commissioners and other tax authorities as required by applicable law, including FATCA or CRS;
• to the Central Bank of Ireland, auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to credit reference agencies in order to carry out money laundering and identity checks and to comply with legal obligations; and
• to other members of our corporate group.

6. Cross border transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and the United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission. 

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your personal data for the duration of your or your company’s investment in the Fund and for such a period of time after the investment ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to request that we restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;

in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and minors

Our website and services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, AMX via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7N.

Manager privacy notice

Last Updated: December 2023
Employees of Current and Prospective Sub-Investment Managers for the AMX Platform

Introduction

This notice describes how and why The Asset Management Exchange (“we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with its engagement with current and prospective sub-investment managers (“Sub-Investment Managers”) for the Asset Management Exchange CCF, Asset Management Exchange UCITS CCF and the Asset Management Exchange Master ICAV (the “Funds”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.

This notice applies to the collection and processing of personal information relating to employees of Sub-Investment Managers. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a Sub-Investment Manager with which an individual is associated.

1. About us 

The Company, as the controller of the personal data collected via our dealings with you and your company, determines the purposes and means of processing of personal data. The Company engages third party service providers to process such personal data on behalf of the Company and those third parties act as processors. In some circumstances, Northern Trust International Fund Administration Services (Ireland) Limited (the “Administrator”) may act as a data controller when processing personal data. If you have any questions about the use of your personal data on behalf of the Fund, please contact us via one of the methods set out at the end of this notice. If you have any questions about the use of your personal data by the Administrator, acting on its own behalf, you should contact the Administrator.

2. Personal Data that we Process

We collect personal data relating to you in connection with our dealings with you or your company, including your name, signature, email address, and other contact details. 

3. Purposes of processing

Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:

• processing your company’s application to become a Sub-Investment Manager in connection with the Funds;
• complying with our legislative and regulatory obligations in connection with our dealings with you or your company;
• for direct marketing purposes, subject to any preferences you communicate to us;
• maintaining appropriate business records;
• statistical analysis and market research;
• internal training and management of personnel;
• to respond to or evaluate any queries or complaints in relation to your company;
• internal and external audits and, where necessary, investigations; and
• establishing, exercising or defending legal claims.

4. Legal basis for processing

The legal grounds that we rely on to process your personal data are:

• that this is necessary to comply with our legal obligations;
• that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
  • promoting our business, and operating as the investment manager in relation to the Funds;
  • conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
  • pursuing our corporate and social responsibility objectives;
• in certain limited circumstances, your consent.

5. Recipients of Data

AMX may disclose your Personal Information to any company affiliated or associated with AMX for the uses and purposes set out above.   We may disclose your personal data to various recipients in connection with the above purposes, including:

• to the Funds’ Administrator;
• to Carne Global Fund Managers (Ireland) Limited , the Funds’ AIFM or UCITS management company;
• to the Funds’ distributors;
• to the Funds’ depositary;
• to auditors, or other competent regulatory authorities and bodies as requested or required by law;
• to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
• to other members of our corporate group.

6. Cross Border Transfers 

In connection with the above purposes we may transfer your personal data outside the European Economic Area and United Kingdom, including to the United States or other jurisdictions which are not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. Such jurisdictions include those jurisdictions in which funds managed by AMX are marketed such as Australia, Canada and South Africa. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission

Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.

7. Security and retention

AMX maintains appropriate technical and organizational security measures to protect the security of your data against loss, misuse, unauthorised access, disclosure or alteration. These measures are aimed at ensuring the ongoing integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will retain your Personal Information for as long as is necessary for the provision of any services we provide to you. When we no longer need your Personal Information in connection with any services, we will retain your Personal Information for a period of time that reasonably allows us to comply with our regulatory obligations or governance requirements and to defend legal claims. We may retain aggregated or anonymised data (which is not treated as Personal Information under this privacy notice) for longer.

8. Your Rights

You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:

• the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
• the right to require us to rectify any inaccuracies in your personal data;
• the right to require us to erase your personal data;
• the right to request that we restrict processing of your personal data for particular purposes;
• where the legal basis for processing is consent, the right to withdraw your consent at any time;
• the right to object to our use of your personal data or the way in which we process it;
• in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

In order to exercise any of the rights set out above, please contact us via one of the methods set out below.

9. Complaints

If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint to us, with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Children and Minors

Our website and services relating to the Company or Fund are not directed to individuals under the age of sixteen (16), and we do not knowingly collect personal information from minors under the age of 16. 

11. Changes to our privacy policy

From time to time, we may change our privacy notice and post those changes to our website located at www.theAMX.com or other AMX Websites. The effective date of this privacy notice, as indicated at the beginning of this privacy notice, indicates the last time this privacy notice was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the notice. We will post a notice on our website alerting users about any recent changes to the privacy notice which we believe to be significant.

12. Contact Details

Should you have any questions in relation to this notice, please contact us via dpo@carnegroup.com, via our website or by post at Carne Group, 85 Gresham Street, London, EC2V 7NQ.

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