Fair Privacy Notice

Fair Privacy Notice

Who we are: EdenTree Investment Management Limited (“EdenTree”, “we”, “us”) is the controller of your personal data for the purposes described in this notice.

Why we use your data: to open and administer your investment account, meet legal/regulatory obligations (including anti-money laundering checks), prevent fraud, and run/improve our business and systems.

Who we share it with: we share data with our fund administrator/transfer agent (Northern Trust) and other suppliers and authorities where needed to operate accounts and meet legal obligations.

International transfers: sometimes data may be transferred outside the UK/EEA; where this happens we use appropriate safeguards (details are in our full Privacy Policy).

How long we keep it: typically 5 years after an investment account is closed, unless law/regulation requires longer

Your rights & complaints: you have rights over your data and you can complain to us or the ICO (details below). From 19 June 2026, we must provide a DP complaints process, acknowledge within 30 days, and respond without undue delay.

More detail: this notice is a summary. For the full detail (including role-specific sections), see our Privacy Policy.

1. What personal data we collect (high level)

Depending on your relationship with us (e.g., investor, intermediary, website user), we may collect:

• Identity & contact details: name, date of birth, address, email, telephone.
• Account & investment information: account details, distributions/redemptions and related records needed to service the account.
• Verification and financial crime information: information needed for AML/sanctions checks, including identity documents and screening outcomes.
• Communications and complaints: records of communications with us (including complaints/enquiries).

Where we get it from: usually from you (or your adviser/representative), and sometimes from administrators, verification/fraud prevention providers, regulators/authorities, and public sources where relevant.

2. How we use your data (purposes and lawful bases)

Data protection law requires us to explain why we use your data and the lawful basis we rely on.

Purposes and lawful bases (summary table)

Special category / criminal offence data: we do not normally collect “special category” data. We may process limited criminal-offence related information where required for AML/sanctions screening, using the relevant legal conditions.

3. Who we share your data with

We share personal data only where necessary for the purposes above, including with:

• Our fund administrator/transfer agent: Northern Trust (and its approved subcontractors/affiliates where necessary).
• Service providers supporting the funds and our business: e.g., auditors, professional advisers, IT and technology providers.
• Regulatory, law enforcement and tax authorities: where we must comply with legal obligations.

For more detail on categories of recipients, see the full Privacy Policy.

4. International transfers (outside the UK/EEA)

In some circumstances, personal data may be transferred outside the UK/EEA (for example, where a supplier or group company is located overseas, or where systems are hosted abroad).

Where we transfer data internationally, we put safeguards in place to protect it (for example, approved contractual protections or transfers to countries/arrangements recognised as providing adequate protection). Details are in our full Privacy Policy.

5. How long we keep your data

We keep personal data only for as long as needed for the purposes above and to meet legal/regulatory requirements. Typically, we retain personal data for 5 years after the closure of an investment account, unless we need to keep it longer (e.g., for legal or regulatory reasons).

6. Your rights

You have rights under data protection law, including to:

• request access to your personal data;
• ask for correction (rectification);
• request erasure (in some circumstances);
• request restriction of processing;
• request data portability (in some circumstances);
• object to processing based on legitimate interests (including direct marketing); and
• withdraw consent where we rely on consent.

To exercise any of these rights, contact us using the details below. We will explain if we cannot comply with a request (for example, where we are required by law to keep certain records).

7. Data protection complaints

If you have concerns about how we handle your personal data, you can make a data protection complaint to us. We will:

• provide a way for you to complain (e.g., by email, post, or other stated methods);
• acknowledge receipt within 30 days; and
• respond and tell you the outcome without undue delay, keeping you informed as appropriate.

You also have the right to complain to the Information Commissioner’s Office (ICO) (the UK supervisory authority for data protection). We encourage you to contact us first so we can try to resolve your issue quickly.

8. Marketing preferences

Where we send marketing communications, you can opt out at any time by using the “unsubscribe” link in emails or by contacting us. Even if you opt out of marketing, we may still send service messages that are necessary to administer your account or meet legal obligations.

9. Contact us / DPO

If you want more information, to exercise your rights, or to raise a data protection complaint, contact our Data Protection Officer:
Email: compliance@edentreeim.com
Address: Data Protection Officer, Benefact House, 2000 Pioneer Avenue, Gloucester Business Park, Brockworth, Gloucester GL3 4AW
Phone: 0345 607 3274

10. Full Privacy Policy

This notice is a summary. For full detail about how we use personal data (including more detailed categories, sources, recipients, international transfer safeguards and your rights), please read our full Privacy Policy (last updated: May 2026).