This privacy notice is issued by South Street Asset Management Limited which acts as the data controller and is for individuals outside our organisation who we interact with, including clients, investors, visitors to our websites and vendors.

We gather and process your personal data in accordance with this privacy notice and in compliance with relevant data protection requirements. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.

The purposes and reasons for processing your personal data are detailed below:

• Entering into, and providing services associated with investment management and contacting you regarding said services.
• Carrying out “Anti-Money Laundering”, “Know Your Client” and other compliance and risk management checks.
• Contacting you about new or existing products and services, or other information that we think is relevant using the contact information that you have provided.
• Operating our Website including providing content to you and interacting with you.

South Street Asset Management Limited may process your personal data to meet our legal and/or contractual obligations. We collect personal data from a variety of sources:

• Provided directly by you;
• Collected in the course of providing you with investment management services;
• Provided by third parties such as clients, employers or where you purchase our services through such third party;
• We may also create personal data about you, such as records of your interactions with South Street Asset Management Limited;
• Collected when you visit our website.

The personal data that we collect about you may include:

• Name;
• Contact information including telephone numbers and email addresses;

You should be aware that in order to provide our services we may need to share your personal or sensitive personal data within the organisation or outside South Street Asset Management Limited. The privacy of your personal data is paramount and will not be disclosed unless there is a justified purpose for doing so.

We may disclose your personal data to third-parties to provide the below services or business functions:

• Providers of services which may identify or prevent financial crime;
• Counterparty banks;
• Custodians;
• Technology providers;
• Government, legal, tax and regulatory, or similar authorities;
• Accountants, auditors, financial and tax advisors, lawyers and other outside professional advisors.

We consider that disclosing your personal data to the above entities/third-parties is within our legitimate interests to be able to provide you with our products and services.

We NEVER sell personal data to third parties.

The periods for which we keep your information will vary according to the purpose for which we use the information.

Unless there is a specific legal requirement to keep your information, we will not keep it for longer than necessary for the purposes for which the data was collected or for which it is to be further processed.

One of the aims of the General Data Protection Regulation (GDPR) is to empower individuals and give them control over their personal data.

The GDPR gives you the following rights:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• Rights in relation to automated decision making and profiling
• The right to object
• The right to data portability

Please contact the South Street Data Protection Officer (DPO@southstreetam.co.uk) if you would like to:

• request copies of your personal data held by us (a subject access request) or discuss your other rights;
• report a data security breach (e.g. if you think your personal data has been lost or disclosed inappropriately);
• complain about how we have used your personal data; or, if you
• have a query about how your data is used by us.