1. Introduction
1.1. Scope of this Notice
1.1.1. Colesco Private Debt Opportunities Fund I SCSp SICAV-RAIF (the “CPDOF Fund“) acting through and represented by its general partner Colesco Private Debt Opportunities Fund I SCSp SICAV-RAIF, and Colesco Circular & Climate Credit Impact Fund (the “C4IF Fund“), acting through and represented by its legal titleholder Stichting Colesco Circular & Climate Credit Impact Fund, are committed to protecting the privacy of all data subjects whose personal data come into their possession.
1.1.2. This data privacy notice (this “Notice“) sets out how we process personal data received from data subjects in compliance with EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data as may be amended from time to time (the “GDPR“) along with any implementing legislation and guidance from competent data protection authorities.
1.1.3. If you are one of the Data Subjects (as defined below), please read the information below carefully. It explains how and why personal data is processed by us, to whom it will be disclosed, and contains information about your rights which can be exercised (under certain conditions) in relation to such personal data.
1.2. How to contact us
1.2.1. If you require further information about the processing of your personal data, wish to exercise your rights under applicable data protection law, or have any questions, concerns or complaints regarding our processing of your personal data, please contact us at: info@colescocapital.com.
1.3. Definitions and interpretation
1.3.1. Unless otherwise stated in this Notice or if the context requires otherwise, capitalised terms used in this Notice shall have the meaning given to these terms in the Fund’s constitutive documents and agreements with each of the relevant Investors, Underlying Assets or their relevant representatives (as the case may be) (the “Fund Documents“).
1.3.2. For the purpose of this Notice:
- the terms “controller“, “personal data“, “processing“, and any other term expressly defined in article 4 of the GDPR has the meaning given to these terms in article 4 of the GDPR;
- the term “data subject” means any person who interacts with a Fund or Vehicle, among others, for example (i) investors or, if the investor is a legal entity, its directors, managers, beneficial owners, agents, employees and other representatives (the “Investors“), (ii) individuals whose personal data are processed in the context of the management of the assets of the Vehicle (the “Underlying Assets“) and (iii) persons providing consent to be contacted by us (the “Subscribers“);
- the term “Fund” means the CPDOF Fund or the C4IF Fund, as the context requires;
- the term “Vehicle” means Colesco Capital Collective S.à r.l. as the Vehicle for the CPDOF Fund (the “CPDOF Vehicle“) or Stichting Colesco Circular & Climate Credit Impact Fund as the Vehicle for the C4IF Fund (the “C4IF Vehicle“), as the context requires;
- any reference to “you” and “your” shall be construed to include, as appropriate, any and all data subjects; and
- any reference to “we” and “us” shall refer to the relevant Fund and/or the relevant Vehicle, as the context requires.
2. Identity of the controller of your personal data
2.1. The Fund is controller for the personal data processed on the Investors, the Subscribers and any other data subjects.
2.2. The Fund and the Vehicle are the joint controllers for the personal data processed on the Underlying Assets. The CPDOF Fund and the CPDOF Vehicle have concluded an arrangement pursuant to which CPDOF will serve as the contact point to data subjects for this processing and whereby the CPDOF Vehicle assumes the responsibility to inform the Underlying Assets, and the Fund the responsibility of inter alia managing the rights of data subjects, personal data breaches, international data transfers, and observing the retention period of the personal data.
2.3. In certain circumstances, third-party service providers to the Fund and/or the Vehicle (such as the persons referred to in Section 3.4 (Who we disclose personal data to and why)) may also act in a capacity as controller if and when processing personal data of the data subjects for the purposes of complying with their own legal and regulatory obligations or for their own legitimate interests (in particular in the context of AML and KYC related processes).
3. Personal data processing by us
3.1. What categories of personal Data do we collect
3.1.1. The categories of personal data, which we collect and process are listed in Appendix 1 of this Notice, and vary depending on the category of data subjects concerned.
3.2. Where we obtain personal data from
3.2.1. We collect information about you from a number of sources, including from you directly, as further detailed in Appendix 2 of this Notice.
3.3. Why we process personal data
3.3.1. We process your personal data for the purposes listed in Appendix 3 of this Notice and according to the legal basis indicated herein.
3.3.2. Where we rely on our legitimate interests to process your personal data, you may request that we provide you with our legitimate interest assessment where we have balanced our legitimate interests against your rights and freedoms and established that our legitimate interests prevail.
3.4. Who we disclose personal data to and why
3.4.1. Your personal data may be disclosed by us to the following entities for the purposes of providing (as appropriate and depending on) the services required by you and/or for complying with these entities’ legal and regulatory obligations (in particular in the context of AML and KYC related processes):
- the service providers to the Fund and/or the Vehicle, such as those referred to in the Fund Documentation (such as the Alternative Investment Fund Manager, the Depositary, the Administrator and the Investment Advisors such as Colesco Capital Ltd and Colesco Capital B.V.);
- the professional advisers of the Fund and/or the Vehicle (for example legal and tax counsels);
- other service providers of the Fund and/or the Vehicle (such as accountants, internal and external auditors, independent appraisers, notaries, banks, other financial institutions and payment services providers, and technology service providers such as DealCloud and iLevel);
- the operator of the Fund’s website, as well as any other IT service provider for the purpose of managing the access to the website, as well as when maintenance of/technical intervention on the website is performed;
- parties involved in connection with any business reorganisation, transfer, disposal, merger or acquisition on the level of the Fund and/or the Vehicle;
- the regulatory authorities entitled to receive personal data based on the activity performed; and
- other (potential or actual) investors and lenders.
3.4.2. The Fund and/or the Vehicle as well as the above recipients may further disclose your personal data to their affiliates and other third-party service providers on a need-to-know basis in order to process these data for the purposes listed in Appendix 3 of this Notice and for conducting internal investigations and reporting.
3.4.3. In addition, your personal data may be disclosed if required so by applicable law or judicial, regulatory, governmental or supervisory authority (for example, for the purposes of anti-money laundering, sanctions, terrorism financing, the prevention and detection of crime and applicable tax legislations (including FATCA/CRS laws)).
3.4.4. We will take all reasonable steps, as required by the GDPR, to ensure the safety, privacy and integrity of your personal data and will, as required by the GDPR, enter into contracts with such recipients to protect the privacy and integrity of your personal data supplied.
3.5. Transfers of personal data outside the EEA
3.5.1. In principle, the Fund, the Vehicle and the third-party providers listed in Section 3.4 (Who we disclose personal data to and why) might disclose and transfer your personal data to other entities of their group, affiliates and third-party service providers, which may be located outside of the European Economic Area (“EEA”) in countries which may not have the same level of data protection as the one afforded in the EEA.
3.5.2. In case personal data is transferred to third-parties located outside the EEA, the Fund and the Vehicle will ensure that your personal data is protected by either:
- an adequacy decision of the European Commission; or
- appropriate safeguards such as EU model contracts, binding corporate rules, approved code of conduct, approved certification mechanisms.
3.5.3. In case personal data is transferred to foreign law enforcement authorities, by request formulated using appropriate procedures, the Fund and the Vehicle will ensure that your personal data is protected additionally by a mutual legal assistance treaty, or equivalent mechanism.
3.5.4. You may contact us using our contact details in Section 1.2 (How to contact us) if you would like to know more about this topic or to obtain a copy of the safeguards mentioned in this Section 3.5 (Transfers of personal data outside the EEA), as applicable.
3.6. How long we keep personal data
3.6.1. In accordance with the GDPR principles and in particular article 5 of the GDPR, we do not keep your personal data for longer than is necessary for the purposes for which they are processed by us.
3.6.2. When we no longer require your personal data for our business use, we consider whether it is appropriate to delete it, for example where the relevant contract has been performed and our business relationship has ceased, or you have withdrawn your consent to the processing of your personal data (only when consent is relied upon as the legal basis for the processing).
3.6.3. Frequently, however, there are legal or regulatory obligations, which require us to retain our business information and records (including personal data comprised within those) for a specified period. These could include tax laws, audit obligations, anti-financial crime law (money laundering, bribery and corruption, the facilitation of tax evasion), other regulatory requirements relating to our investment business.
3.6.4. Without limitation, the following retention periods apply:
- personal data contained in the documents listed by article 16 of the Luxembourg Commercial Code (namely accounting documents) will be kept for ten (10) years after the closing of the end of the financial year to which they relate; and
- personal data processed for AML and KYC purposes will in principle be retained for five (5) years after the end of the business relationship with you.
3.6.5. In general terms, we will retain your personal data according to the limitation period of article 189 of the Luxembourg Commercial Code, which provides for a general retention period of ten (10) years. In most cases, your personal data will be kept for ten (10) years following the termination of your relationship with the Fund or the Vehicle. Also, we may need to retain information and records for a certain period of time to protect our business, and defend ourselves against potential legal claims, or allegations of wrongdoing.
3.6.6. For each processing activity (including personal data processed as a result of that activity) we have considered carefully how long we will need to process the relevant personal data for the intended processing activity, and whether any legal and/or regulatory requirements stipulate a mandatory minimum retention period for the relevant information, documentation and records (including personal data) to be retained.
4. Your rights in respect of your personal data
4.1. Do you have to provide us with personal data?
4.1.1. Where we collect personal data directly from you, we will indicate:
- if the provision of your personal data is necessary for our compliance with a legal, regulatory or contractual obligation, or
- if the provision of your personal data is purely voluntary, in which case there will be no negative consequences for you if you do not wish to provide us with it.
4.1.2. Unless otherwise indicated, you should assume that we require the personal data for legal, regulatory or contractual purposes. If you do not wish to provide us with this personal data, it will affect our ability to provide our services to you.
4.2. Do you have to inform your representative(s) and/or beneficial owner(s)?
4.2.1. If you act for an undertaking, you shall inform all data subjects concerned (i.e., the representative(s), beneficial owner(s), and all individuals whose personal data you provide to us in connection with our relationship with the undertaking) about the processing of their personal data for the purposes listed in Appendix 3 of this Notice (as well as on their related rights, see Section 4 (Your rights in respect of your personal data) and, where necessary and appropriate, consent for the processing of the personal data must be obtained in advance. You shall provide the data subjects referred to in this Section with a copy of this Notice.
4.2.2. We assume that the undertakings contained herein have been complied with and that your representatives, your ultimate beneficial owner(s) and all individuals whose information you provide to us in connection with our relationship with you, have, where necessary given such consent and have been informed of the processing of their personal data for the purposes described in this Notice.
4.3. Your rights in respect of your personal data
4.3.1. You have certain rights under the GDPR, including:
- the right to access your personal data, free of charge, including the right to ask for a copy of your personal data where it does not adversely affect the rights and freedoms of others (please note that if you request any further hard copies later on, we may charge you a reasonable fee based on administrative costs); and
- the right to have incomplete or inaccurate personal data corrected (including by means of providing a supplementary statement).
- (in limited circumstances) the right to object to the use of your personal data (where processing is based on the Fund’s or the Vehicle’s legitimate interest);
- (in limited circumstances) the right to restrict the use of your personal data;
- (in limited circumstances) the right to require us to erase/delete your personal data; however, please note that if we process your personal data in particular to comply with a legal obligation (see Appendix 3 of this Notice), we will not be able to respond positively to your request to erase/delete your personal data.
- (in limited circumstances) the right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format and the right to transmit those data to another data controller; however, please note that this right to data portability only arises where: (a) the processing is based on consent or on a contract; and (b) the processing is carried out by automated means, and (c) it does not adversely affect the rights and freedoms of others. This data portability right also only applies to the data that you have provided to us.
4.3.2. You may withdraw your consent to be contacted by us at any time by contacting us using our contact details in Section 1.2 (How to contact us) or, in respect of marketing communications, by using the unsubscribe link included in our marketing communications.
4.3.3. You have the right to object to our use of your personal data for direct marketing purposes at any time.
4.3.4. You are hereby informed that no automated decision-making or profiling is conducted.
4.3.5. If you would like to exercise such rights, you may contact us using our contact details in Section 1.2 (How to contact us). We will respond to you as soon as reasonably possible.
4.3.6. In addition, you also have the right to ask questions or lodge a complaint about our processing of your personal data with the relevant data protection authority. You can complain in the EEA Member State where you live or work, or that of the place where the alleged breach of the GDPR has taken place. In Luxembourg, the relevant data protection authority is the Commission Nationale pour la Protection des Données (CNPD). In the Netherlands, the relevant data protection authority is the Autoriteit Persoonsgegevens.
5. Amendments to this Notice
5.1. This Notice is kept under regular review and may be updated from time to time and the applicable version can be found on the Fund’s website.
5.2. This Notice was last updated on 16 July 2026.
Appendix 1 – Categories of personal data processed
| Type of personal data | Investors | Underlying Assets |
|---|---|---|
| first name, last name, residential address, e-mail address, telephone number and other contact details, including those of representatives and contact persons | X | X |
| date and place of birth, your citizenship and profession | X | X |
| copies of your identity card/passport number or other national identifier | X | X |
| tax details (i.e. tax identifier, tax residence, status under dividends and interests withholding tax rules, FATCA rules, CRS rules, DAC6 and any other tax rules) | X | |
| financial details and situation (i.e. bank account number, data on transactions, financial information including origin of wealth, etc.) | X | |
| knowledge, investment experience and investment objectives | X | |
| publicly available information | X | X |
| functions and powers | X | X |
| KYC / AML related data (as the case may be) | X | X |
| pictures of yourself as provided on an ID or passport | X | X |
| Personal data contained in the copy of your declaration of honour, of beneficial owner declarations and similar documents | X | X |
| authentication information (e.g. passwords, user ID) | X | X |
| other personal data generated while you visit the Fund’s website (incl. IP addresses, country, region, city, approximate latitude and longitude, screen resolution of your device, files that were accessed and downloaded, etc.) | X | X |
Appendix 2 – Where we obtain your personal data
| Investors | Underlying Assets | |
|---|---|---|
| Information that you provide us with | ||
| in the Subscription Agreement, and any other forms and any associated documentation that you complete when opening an Investor account with the Fund and subscribing for an investment in Interests of the Fund | X | |
| in correspondence and conversations | X | X |
| when you make transactions with respect to the Fund, including without limitation the cases where you subscribe, redeem and convert Interests in the Fund and/or tell us where to transfer money to, among others, payments of dividends and redemption proceeds | X | |
| when you submit or we otherwise receive information in view of the negotiation and/or execution of the Fund transactions or any event potentially leading thereto | X | |
| when you submit information to us in view of establishing a business relationship with us | X | X |
| when you visit or access the Fund’s website | X | X |
| when you submit your contact details when accepting to be contacted by Colesco Capital and send information about Colesco Capital, including news, publications, market insights, event invitations and other marketing communications that may be of interest | X | X |
| publicly available and accessible registries and third-party sources | X | X |
| Information that we obtain from others | ||
| Bankruptcy or other public registers | X | X |
| tax authorities, including those that are based in and outside the EEA | X | X |
| governmental and competent regulatory authorities to which we have regulatory reporting obligations | X | X |
| fraud prevention and detection agencies and organisations | X | X |
| cookies from our website provider and generated by your visit of the Fund’s website | X | X |
Appendix 3 – Purposes and legal basis to process your personal data
Important note: Given the specific purposes for which the Fund envisages processing your personal data, the Fund does not anticipate obtaining your consent to do so. If we were to rely on consent to process your personal data, we will contact you to obtain this consent. In case consent is relied upon to legitimate a data processing, you will have the right to withdraw this consent at any time.
| Purposes of processing | Legal basis (under the GDPR) | Data Subjects | Controller |
|---|---|---|---|
| 1. Own functions of the Fund | |||
| Carry out the Fund’s activity, i.e. collecting monies from investors for investment purposes, in accordance with the Luxembourg laws and regulations and the terms of the Fund documentation (e.g. prospectus, instrument of incorporation, subscription documents, KIID/PRIIP KID (if any), relevant agreements with service providers and other relevant documents of the Fund such as internal procedures/policies, factsheet, etc.) (the “Fund Documentation”) | Necessary for the performance of a contract (article 6(1)(b)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Place the shares and accept subscription, redemption, conversion and/or transfer orders placed by investors in the Fund, issue, redeem convert and/or accept transfer of shares accordingly | Necessary for the performance of a contract (article 6(1)(b)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Market the Fund and ensure that facilities are available in the country of registration for making payments to shareholders, placing, repurchasing or redeeming shares and making available the information which Fund is required to provide | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Persons related to the Underlying Assets | Fund and Vehicle |
| Convene and hold general meeting (including also drafting and holding of proxies and attendance lists), arranging for publication of the convening notices and the minutes of the meeting | Necessary for the purposes of the legitimate interests (article 6(1)(f)) |
Investors any other as the case may be |
Fund |
| Ensure corporate actions are validly taken, communicated and implemented (e.g. mergers, liquidations, launch/creation of new share class, sub-fund, suspension of voting rights if applicable, modification of Fund Documentation as applicable, etc.) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) |
Representatives of the AIFM Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Ensure the appointment, initial due diligence and ongoing supervision by the Fund over the Management Company and, in particular, ensure that the Fund is being managed in the best interests of the investors (monitoring of the portfolio management, risk management, administrative and marketing services provided by the management company as well as other day-to-day management services provided by the Management Company (if any), spot checks, review the Management Company’s reports, etc.) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Ensure the appointment, and to the extent as applicable the initial due diligence and ongoing supervision of, any parties contracting directly with the Fund (e.g., depositary, auditor, lending agents, derivatives counterparties, etc.) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Processing of data for the sake of the drafting and approval of the Fund’s documentation (e.g. prospectus, instrument of incorporation, subscription documents, KIID/PRIIP KID (if any), relevant agreements with service providers and other relevant documents of the Fund such as internal procedures/policies, factsheet, etc.) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Release, publish and disseminate the Fund Documentation and any other relevant information to be published/made available in accordance with applicable laws and regulations | Necessary for compliance with a legal obligation (article 6(1)(c)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Issue the annual, semi-annual reports, the report of the approved statutory auditor (“réviseur d’entreprises agréé”), the management report and any other reports of the Fund | Necessary for compliance with a legal obligation (article 6(1)(c)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Release the annual, semi-annual reports, the report of the approved statutory auditor, the management report and any other reports of the Fund | Necessary for compliance with a legal obligation (article 6(1)(c)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Processing of data in accordance with FATCA/ CRS legislation applicable to the Fund | Necessary for compliance with a legal obligation (article 6(1)(c)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| 2. Delegated functions of the Fund | |||
| Portfolio management function | |||
| Review, negotiate and execute agreements relating to transactions in underlying assets (e.g. for portfolio and risk management purposes in relation to real estate and infrastructure funds) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Persons related to the Underlying Assets | Fund and Vehicle |
| Appoint local facility and paying agency agents in the country of registration for making payments to shareholders, repurchasing or redeeming shares and making available the information which data subjects shall receive | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Representatives of paying agents | Fund |
| Marketing function | |||
| Distribute the Fund (respectively, ensure distribution of the Fund) to investors | Necessary for the performance of a contract (article 6(1)(b)) | Investors | Fund |
| Sale support (communication with potential and existing clients) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Investors | Fund |
| Communicate marketing material with existing and potential investors | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Investors | Fund |
| Send information about Colesco Capital, including news, publications, market insights, event invitations and other marketing communications that may be of interest | The data subject has given consent (article 6(1)(a)) | Subscribers | Fund |
| Appoint distributors and sub-distributors to facilitate the distribution and marketing strategy of the Fund including performing initial due diligence on distributors and sub-distributors to perform delegated tasks (completion of due diligence questionnaire, conflict of interest assessment form, gathering of the relevant legal documentation, e.g. organizational chart of the delegate, negotiation and execution of the relevant service agreement, SLA, operating memorandum with delegates for terms of service and monitoring purposes) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Representatives of distributors or sub-distributors | Fund |
| Ensure supervision, oversight and effective monitoring over the marketing agents (spot checks, reporting, regulatory notification, inquiries and instructions to the delegates) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Representatives of marketing agents | Fund |
| Administration Services | |||
| Ensure maintenance of the unlimited and limited partners register (registre des associés) | Necessary for compliance with a legal obligation (article 6(1)(c)) | Investors | Fund |
| Identification of beneficial owners in compliance with the AML/CTF legislation (spot check, reporting) | Necessary for compliance with a legal obligation (article 6(1)(c)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Ensure that subscriptions/redemptions/conversion and transfer are handled according to the Fund’s documentation (e.g. prospectus, instrument of incorporation, subscription documents, KIID/PRIIP KID (if any), relevant agreements with service providers and other relevant documents of the Fund such as internal procedures/policies, factsheet, etc.)(spot check, reporting) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Ensure valuation of the Fund’s assets, ensure calculation of the NAV and bookkeeping services (external valuer, spot check, reporting) | Necessary for compliance with a legal obligation (article 6(1)(c)) | Persons related to the Underlying Assets | Fund and Vehicle |
| Appoint the central administration and perform initial and on-going due diligence on the administration to perform delegated tasks (completion of due diligence questionnaire, conflict of interest assessment form, gathering of the relevant legal documentation, e.g. organizational chart of the delegate, negotiation and execution of the relevant service agreement, SLA, operating memorandum with delegates for terms of service and monitoring purposes) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Representatives of central administrators | Fund |
| Complaint handling | |||
| Handle investors complaints and inform the regulator and the Fund | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Investors | Fund |
| Defense of legal claims | Necessary for the purposes of the legitimate interests (article 6(1)(f)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Day-to-day management services | |||
| Communicate with investors for general and specific requests resulting from regulatory obligations (e.g. regulatory reporting) | Necessary for compliance with a legal obligation (article 6(1)(c)) | Investors | Fund |
| Communicate with investors for general and specific requests (e.g. request to obtain specific portfolio holdings) | Necessary for the performance of a contract (article 6(1)(b)) | Investors | Fund |
| Data protection and cybersecurity obligations | |||
| Processing of Personal Data in accordance with GDPR and other legislation requiring notification and recording of personal data breaches and similar IT incidents. | Necessary for compliance with a legal obligation (article 6(1)(c)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Processing of Personal Data in compliance with obligations under the GDPR along with any implementing legislation (including responding to data subject access requests along with the exercise of other data subjects rights). | Necessary for compliance with a legal obligation (article 6(1)(c)) |
Investors Persons related to the Underlying Assets |
Fund Fund and Vehicle |
| Performing transactions for the portfolio management of Underlying Assets | |||
| Review, negotiate and execute agreements relating to transactions in underlying assets (e.g. for portfolio and risk management purposes in relation to real estate and infrastructure funds) | Necessary for the performance of a contract (article 6(1)(b)) | Persons related to the Underlying Assets | Fund and Vehicle |
| Other services performed under the delegated functions | |||
| Perform initial due diligence on any counterparties to investment transactions for non-traditional assets (e.g. real estate, private equity, infrastructure assets) (completion of Due Diligence Questionnaire, know-your-counterparty process) | Necessary for the purposes of the legitimate interests (article 6(1)(f)) | Persons related to the Underlying Assets | Fund and Vehicle |