Website Privacy & Security Statement ("Privacy Policy")

GENERAL

Thank you for appointing Stelac Advisory Services LLC ("we," "us," "our," "ours," "Stelac") as your investment advisor. This Privacy Policy ("the Policy") describes how we collect, use and share your personal information that we collect in connection with our investment services ("our Services").

For any data collected through our public website, please refer to the privacy policy posted on the website at http://stelac.com/privacy-policy/.

We will treat your personal information received through your use of the Services in accordance with this Policy and applicable law. Stelac is the entity which is responsible for the control and processing of personal information that we collect from you when we provide our Services. If you have any questions or concerns about Stelac's use of your personal information, please contact us at compliance@stelac.com.

WHAT IS "PERSONAL INFORMATION"?

In general, “personal information” means information that relates to an identified or identifiable individual. It includes (without limitation) direct identifiers such as your name, mailing address, telephone number, and e-mail address as well as information that we collect about you, such as your investment profile, trading history, investment portfolio, details of your occupation, income, next of kin, beneficiaries, any statements or reports we prepare for you and all communications that we may receive from you or send to you and information we receive from third parties (such as banks or credit agencies) that concerns you. Personal information includes “non-public personal information” as defined by the Gramm-Leach Bliley Act (“GLBA”) and Regulation S-P.

This Privacy Policy applies only to our processing of personal information from consumers (i.e., data about you, an individual, from which you can be identified). This Privacy Policy therefore does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot reasonably be linked to an individual (such as anonymized data or aggregated data which, in a given form, cannot directly or indirectly be used to identify you as an individual) ("Anonymized and Aggregated Data"). Similarly, this Privacy Policy does not apply to data of customers who are not natural persons (e.g. institutional investors or businesses).

We reserve the right to generate Anonymized and Aggregated Data extracted out of any databases containing your personal information and to make use of any such Anonymized and Aggregated Data as we see fit (including publishing such data and sharing it with third parties).

PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect the following personal information about you in connection with our Services:

(a) Information that you provide to us. We may ask you to provide us with information relating to you such as your name, address and contact details, bank account details, payment instructions, instructions regarding your investment preferences, information about your assets, occupation, income, family members or other beneficiaries and other information relating to our Services. We also collect identification documents and information from you as required by `Know Your Client' and other anti-money laundering rules.

(b) Information received from third parties. We may receive information about you from third parties. We receive information from credit rating agencies and may obtain information about you from public data sources, for example when we carry out screening searches on asset freezing and sanctions lists to meet legal compliance requirements. We also receive information about you from banks, fund managers, trustees and other third parties that act as managers, arrangers or custodians of your investments in relation to your investment portfolio.

(c) Information that we create in providing our Services. We prepare engagement letters, investment statements and reports about your investment portfolio, trading history and other activities which we keep in our records and provide to you from time to time.

(d) Communications. We retain communications that you may send to us or that we may send to you (through electronic or hard copy commutations) and other personal information you provide to us or that we create including notes of our meetings or telephone calls with you.

Where personal information is required to provide our Services or satisfy a legal obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide personal information may result in your subscription in the applicable fund being rejected, compulsorily redeemed, or withdrawn, as applicable. Where there is suspicion of unlawful activity, failure to provide personal information may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

We use personal information collected about you to administer our business and deliver our Services, including managing your investments, providing statements and reports and performing our contract with you. In addition, we use your personal information:

(a) to communicate with you in relation to our Services including (insofar as permitted under applicable law) to offer you our services and those of our affiliates and partners;

(b) to meet our legal obligations and the regulatory requirements to which we may be subject, for loss prevention purposes and to protect and enforce our rights and meet our obligations to third parties;

(c) for our internal business purposes including administration, accounting, billing, etc.;

(d) Where allowed by law, we may also process personal information to market our products and services to you via email or direct marketing.

DISCLOSURE TO THIRD PARTIES

Reason for Sharing: For our or our affiliates’ everyday business purposes: Financial service providers

We provide your personal information with third party financial service providers e.g. banks, fund managers, trustees and other third parties that act as managers, arrangers or custodians of your investments as necessary for us to provide agreed-upon services to you, including but not limited to process transactions, perform general account maintenance, to administer or services benefits (such as to provide statements or transactions records), in relation to payment processing, for credit reporting, for investor relations activities, and to respond to regulators or legal investigations and comply with applicable legal and regulatory requirements (e.g. anti money laundering).

Sharing: Stelac may share this information.

Limitations: You cannot limit Stelac’s ability to share.

Reason for Sharing: For our or our affiliates’ everyday business purposes: Non-financial companies

We may also use third parties to provide data processing, hosting, storage, emergency recovery services, and similar technology services to us. It may be necessary for these third parties to have access to personal information collected in relation to you.

If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution or other transaction, or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer records of your personal information in connection with such transaction. Where appropriate, we may seek your instructions and consent before sharing your data with a third party in the context of a change of ownership or legal structure.

To the extent permitted or required by applicable law, we may disclose information about you to third parties to: (i) enforce or apply the terms and conditions of our Services; (ii) comply with laws, subpoenas, warrants, court orders, legal processes or requests of government or law enforcement officials; (iii) protect our rights, reputation, safety or property, or that of our clients or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; or (vi) investigate, prevent or take action regarding known or suspected illegal activities; fraud; our rights, reputation, safety or property, or those of our clients or others; violation of our policies or agreements; or as otherwise required by law.

We may share any personal information that we process with non-financial companies we hire to help administer our business, to maintain the security of our information technology systems, or to provide marketing on our behalf (e.g. hosting providers, technology vendors, placement agents, or consultants). Companies we hire to provide services of this nature are not allowed to use your personal information for their own purposes and their use of your personal information is limited to the performance of the specific service we have requested.

Sharing: Stelac may share this information.

Limitations: You cannot limit Stelac’s ability to share.

Reason for Sharing: For affiliate marketing purposes

Stelac does not disclose, and does not intend to disclose, personal information to non-affiliated third parties for marketing purposes.

Sharing: Stelac does not share this personal information.

Limitations: You can limit Stelac’s ability to share.

Reason for Sharing: For non-affiliate Marketing purposes

Stelac does not disclose, and does not intend to disclose, personal information to non-affiliated third parties for marketing purposes.

Sharing: Stelac does not share this personal information.

Limitations: You can limit Stelac’s ability to share if this occurs in the future.

Reason for Sharing: Information About Former Clients

Stelac does not disclose, and does not intend to disclose, personal information of persons who are no longer our clients to non-affiliated third parties.

Sharing: Stelac does not share this personal information.

Limitations: You can limit Stelac’s ability to share if this occurs in the future.

As mentioned above, we may create Aggregate or Anonymized Data. This Anonymized and Aggregated Data does not personally identify you and helps us to measure the success of the Services and to improve your experience. We reserve the right to make use of any such Anonymized and Aggregated Data in our sole discretion.

WHY CAN’T I LIMIT ALL SHARING?

U.S. Federal law gives you the right to limit only: (i) sharing for affiliates’ everyday business purposes relating to your creditworthiness; (ii) affiliates from using your information to market to you; and (iii) sharing for nonaffiliates to market to you. U.S. state laws, other applicable Data Protection Laws, and individual companies may give you additional rights to limit sharing.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

SECURITY

We use physical, electronic and procedural safeguards to protect your personal information, and the measures required under applicable Data Protection Laws. These measures include computer safeguards and physical safeguards, such as secure file storage, access management, and similar security measures at our offices. We do not guarantee that our safeguards will always work. Information sent to us using electronic communication channels may not be secure in transmission.

YOUR EEA/UK/SWISS PRIVACY RIGHTS

Clients based in the European Economic Area, United Kingdom, and Switzerland have the following legal rights in respect of their personal information:

(a) The right to require Stelac to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;

(b) The right to require Stelac to rectify inaccurate information without undue delay;

(c) Where Stelac has relied on the 'consent' basis for processing that information (see 'Legal Basis for Processing Your Personal Information' below), the right to withdraw their consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal;

(d) The right to request the erasure of their information in certain circumstances. You can make a request for erasure where:

i. the information is no longer necessary in relation to the purpose for which it was collected;

ii. where the processing of the information is based on the client's consent (and the other circumstances described in the 'Legal Basis for Processing Your personal information' section above no longer apply), if the client withdraws his or her consent; or

iii. where the personal information is processed by Stelac solely on the basis of our `legitimate interest' referred to in `Legal Basis for Processing Your Personal Information' below (and the other legal basis set out in that section do not apply), if the client objects to the processing of his or her personal information and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defense of legal claims).

(e) The right to require Stelac to restrict its processing of a client's personal information in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, Stelac will only process that information with the express consent of the client, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;

(f) Where data is processed based on client's consent or to fulfil a contractual obligation, the client has the right to receive his or her personal information from Stelac in a structured, commonly used and machine-readable format;

(g) The right to object to the processing of personal information where:

i. Stelac relies solely on the `legitimate interest' basis for processing that data, in which case we will be legally required to stop processing the client's information unless we have compelling legitimate grounds for the processing which override the client's privacy rights and interests; or

ii. the information is used for direct marketing purposes, in which case we will immediately stop processing the client's information for such purposes;

(h) Clients have the right to lodge a complaint with a competent supervisory authority.

The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.

To exercise your rights in your personal information, please contact us at: compliance@stelac.com. we may verify your identity as required by law before we fulfill your request.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

Insofar as it concerns the data of individuals in the European Union, we rely on the following lawful basis for the processing of your personal information (as relevant):

(a) The fulfilment of our contractual obligations to you under our contract(s) between us or in response to your request ahead of contracting with us or retaining our Services;

(b) Our legitimate interests in (among other things) administering and delivering the Services, improving and maintaining the Services, protecting the security or integrity of our systems, protecting our business or reputation, taking precautions against legal liability, dealing with our assets in the event of a business change, protecting and defending our legal rights or property, or for resolving disputes, investigating and attending to inquiries or complaints with respect to our Services;

(c) Your express consent, which you are free to withdraw at any time by way of email to compliance@stelac.com; and

(d) For compliance with legal obligations to which we are subject.

COUNTRY OF PROCESSING

We carry out our business from the United States of America (USA) and our data collection and processing activities take place predominantly in the USA. We may store and otherwise process data (including personal information) through third party service providers which may be located or which may operate in other countries. In cases where we transfer personal information to jurisdiction that have not been determined to provide “adequate” protections by your home jurisdiction, we will put in place appropriate safeguards to ensure that your personal information are properly protected and processed only in accordance with applicable law. Those safeguards may include the use of EU standard contractual clauses, reliance on the recipient’s Binding Corporate Rules program, or requiring the recipient to certify to a recognized adequacy framework. You can obtain more information about transfer measures we use for specific transfers by contacting us using the information above.

YOUR RESPONSIBILITIES

It is important that the personal information we hold about you is accurate and current. If you provided us with any details of personal information, please keep us informed if such details change by emailing us at compliance@stelac.com.

AMENDMENT

We may amend this Policy from time to time. We will provide you with a new version if any material changes are made to this Policy.

HOW TO CONTACT US

If you have any questions about this Policy or our use of your personal information, please email us at compliance@stelac.com.