Privacy Policy

Last updated: January 2025

1. Introduction

Burgess Fund Management Designated Activity Company ("Burgess Fund Management", "we", "us" or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you visit our website, contact us, or otherwise interact with us.

We process personal data in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR") and the Irish Data Protection Acts 1988 to 2018, to the extent applicable to our activities.

2. Who we are

Burgess Fund Management DAC is a designated activity company (limited by shares) registered in Ireland with company number 754553, with its registered office at 94 Upper Leeson Street, Dublin 4, Co. Dublin, D04 A9N9, Ireland. For the purposes of applicable data protection law, we act as a "data controller" in respect of the personal data described in this policy.

3. Contact details

If you have any questions about this policy or our use of your personal data, you can contact us by:

• Post: Burgess Fund Management DAC, 94 Upper Leeson Street, Dublin 4, Co. Dublin, D04 A9N9, Ireland; or
• Email: via the contact form on our Contact page.

4. The personal data we collect

Depending on how you interact with us, we may collect the following categories of personal data:

• Identity data — your name, title, and, where relevant, your role or job title.
• Contact data — your email address, postal address, company name, and telephone number.
• Correspondence data — the content of enquiries, messages and any other information you choose to provide to us.
• Technical data — internet protocol (IP) address, browser type and version, time zone setting, operating system, and information about your use of the website.
• Usage data — information about how you navigate and interact with our website, collected through cookies and similar technologies.

5. Special categories of personal data

We do not generally seek to collect special categories of personal data (such as information about your health, race, religion or political opinions). Please do not provide such information to us unless we specifically request it and you provide your explicit consent.

6. How we collect your personal data

We may collect personal data:

• Directly from you, when you contact us, submit an enquiry through our website, or correspond with us;
• Automatically, as you navigate our website, through cookies and similar technologies (see our Cookie Policy); and
• From third parties or publicly available sources, such as company registers, where this is necessary and lawful.

7. How we use your personal data

We may use your personal data to:

• Respond to your enquiries and provide information you have requested;
• Operate, maintain and improve our website and its functionality;
• Understand how visitors use our website and monitor its performance;
• Maintain the security of our website and systems;
• Comply with our legal, accounting, tax and regulatory obligations; and
• Establish, exercise or defend legal claims.

8. Legal bases for processing

Under the GDPR, we rely on one or more of the following legal bases when processing your personal data:

• Legitimate interests — where processing is necessary for our legitimate interests (or those of a third party), such as responding to enquiries, operating our website and ensuring its security, provided those interests are not overridden by your rights and interests;
• Legal obligation — where processing is necessary to comply with a legal or regulatory obligation to which we are subject;
• Consent — where you have given consent for a specific purpose (for example, certain cookies); and
• Contract — where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.

9. Sharing and disclosure

We do not sell your personal data. We may share your personal data with:

• Service providers and processors who assist us in operating our website and business (for example, hosting and IT providers), under contractual confidentiality and security obligations;
• Professional advisers, such as legal, audit and compliance advisers;
• Regulatory authorities, law enforcement or other bodies where required by law; and
• Third parties in the context of a corporate transaction, such as a merger, acquisition or restructuring.

10. International transfers

We generally process personal data within the European Economic Area (EEA). Where personal data is transferred outside the EEA, we ensure appropriate safeguards are in place in accordance with the GDPR, such as standard contractual clauses or an adequacy decision.

11. Data security

We implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. Access to personal data is limited to those who require it for legitimate purposes and who are subject to confidentiality obligations.

12. Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, tax or regulatory requirements. When personal data is no longer required, we securely delete or anonymise it.

13. Your rights

Subject to certain conditions and exceptions, you may have the following rights in respect of your personal data:

• Access — to request a copy of the personal data we hold about you;
• Rectification — to request that we correct inaccurate or incomplete personal data;
• Erasure — to request that we delete your personal data in certain circumstances ("right to be forgotten");
• Restriction — to request that we restrict processing of your personal data;
• Portability — to receive your personal data in a structured, commonly used and machine-readable format, or to have it transmitted to another controller;
• Objection — to object to processing based on our legitimate interests; and
• Withdraw consent — to withdraw your consent at any time where processing is based on consent.

To exercise any of these rights, please contact us using the details in section 3. We may ask you to verify your identity before responding. We will respond within the timeframes required by applicable law.

14. Automated decision-making

We do not use your personal data to make decisions based solely on automated processing that produce legal or similarly significant effects concerning you.

15. Complaints

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Data Protection Commission (Ireland), which is the supervisory authority for data protection in Ireland. Further information is available at www.dataprotection.ie.

16. Children

Our website is not directed at children, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

17. Third-party links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

18. Changes to this policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "last updated" date. Where appropriate, we will notify you of material changes.

19. Contact us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at:

Burgess Fund Management DAC
94 Upper Leeson Street, Dublin 4, Co. Dublin, D04 A9N9, Ireland