Holborn Tax Services Limited (‘Holborn’) is committed to the principles of lawful, fair and transparent processing of personal data, and will only use your personal data in order to administer the U.K. tax reporting services that you are asking us to provide to you.

Holborn is a ‘Data Controller’ as defined by current applicable Data Protection legislation and is registered as such with the Information Commissioner in the Isle of Man.

Information on our processing activities and the rights that are provided to you under Isle of Man Data Protection legislation are noted below.

Processing information fairly and lawfully

Holborn processes your personal data only where:

• We have a legitimate interest to do so; or
• A contract has been entered into that allows us to; or
• It is in the vital interests of you as the data subject; or
• You have given your explicit consent; or
• We are required to by our Regulators; or
• We have received a court order.

We will not process personal data unless one of the above conditions apply.

What data do we collect?

Holborn will only collect personal data that is essential to administer the services that you have asked us to provide and to comply with regulatory and statutory requirements. We believe in providing transparency regarding the data we are collecting and why we are collecting it so that you, as a data subject, can make informed decisions as to whether you want your data to be processed or not.

The data that we collect may include:

• Full name, marital status/title, date of birth, place of birth, country of residence, nationality, national identity number and/or other governmental identification number(s);
• Personal and/or business contact details, including address, telephone numbers and email addresses;
• Financial information (including bank account details of the source of funds to pay our fees and your relationship to that account);
• Your employment/retirement status, salary details, the name of your employer or description of your business/occupation, and the related industry or sector of employment that this applies to;
• Whether you are, have been or are connected to a person who may be considered a Politically Exposed Person (‘PEP’).

Please note that certain categories of data are classed as sensitive personal data. They include:

• Details of racial or ethnic origin;
• Political opinions;
• Religious or philosophical beliefs;
• Trade Union membership;
• Health and medical information;
• Sex life or orientation;
• Criminal records (including alleged offences, spent convictions or court orders).

In the unlikely event that Holborn may need to obtain information from you that may fall within any of the above special categories of data, we will always obtain your explicit consent before acquiring or processing such information.

Why is your data processed?

Holborn collects your personal data for the purpose of:

• Creation and ongoing administration of the U.K. tax reporting service that you have asked us to provide to you;
• Dealing with any queries and/or complaints in relation to this service;
• Ensuring Holborn’s compliance with legal, regulatory, and good governance obligations.

Where we process and store your data

Your data will be processed and held securely in physical or electronic format within the offices and servers of Holborn in the Isle of Man.

We may also make your personal data available to other parties (individuals, companies or tax authorities) who are providing relevant services for one of the above data processing purposes, such as professional or legal advisors, investment administrators or managers, banking institutions, tax reporting authorities or for the preparation of accounts or other financial information, etc.

Data Sharing

Holborn is located in and operates out of the Isle of Man; however you should be aware that we may, on occasion, be required to share your data with external providers outside of the Isle of Man or European Economic Area (“EEA”). In territories outside the Isle of Man or EEA, laws and practices relating to the protection of personal data may be weaker than those within the Isle of Man or EEA. We will take all reasonable steps to ensure that your personal data receives the same level of protection as it would have had it stayed in the Isle of Man or EEA.

Your personal data may also be released to other external parties if authorised by you, or as required or permitted by law, or to comply with a judicial proceeding, court order, request from a regulator or any other legal process served on Holborn.

Our basis for processing your data

The processing of your personal data is necessary for Holborn to administer the U.K. tax reporting service that we have been asked to provide on your behalf.

We will proceed on the basis that, for the purposes set out above, you expressly consent to the processing (including the disclosures and transfers described above) of your personal data by the directors and officers of Holborn, or related third parties as set out above.

Retaining Information

Holborn will only retain your personal information during the lifetime of our business relationship with you plus any statutory retention period required in the Isle of Man.

All personal data held past these specified retention periods will be destroyed.

Your Rights

As detailed within Data Protection Legislation, each Data Subject is afforded several rights. In accordance with these rights Holborn will, upon request:

• Provide you with all the personal data we hold about you, in a machine-readable format;
• Provide you with access to any or all the data that we hold about you, and provide you with details about why we have the data;
• Correct any information about you that you notify us is incorrect;
• Unless we are required to continue doing so by legislation, stop, or where applicable, restrict the processing of data about you;
• Remove all records about you from our systems, providing that there is not a legal reason to retain it. If there is a legal reason we will inform you of it and provide you with details about how much longer we are required to retain your data for.

You can exercise these rights by contacting the Data Protection Officer at 29/31 Athol Street, Douglas, Isle of Man, IM1 1LB.

Please notify us as soon as possible if there has been a change in your details (e.g. if your personal circumstances, home address, source of funds details, etc., change).

Marketing

Holborn will only contact individuals who have consented to receiving marketing information, or requested direct communication for marketing purposes, and only in relation to our services. Should you no longer wish to receive marketing communications from us:

• an unsubscribe facility is available within any marketing email sent to you to allow you to request that no further marketing contact is received by you from Holborn; or
• you can reply to the individual who has contacted you requesting that no further marketing contact is made to you from Holborn.

After either of these has occurred, Holborn will not directly contact you in this regard again unless you provide a subsequent request to start receiving marketing material from us.