Privacy Centre

We process your Personal Information based on:

• Your provision of consent (where applicable),
• Your contract with us,
• exceptions to the consent requirement as outlined in the law; or
• in line with legal or regulatory requirements or guidance.

We collect Personal Information necessary to provide information, products, or services of your choice. With limited exceptions, we collect your Personal Information directly from you through our website, emails, phone, fax, physical forms, internal systems, marketing campaigns or lists, etcetera. From time to time, we utilize publicly accessible information where necessary to verify information provided by you.

When you disclose to us the Personal Information of another person for use in connection with our products or services, for example, a beneficiary or a family contact, you must be authorized to entrust that Personal Information to us.

We process your Personal Information for the following purposes and, where applicable, for secondary purposes that are compatible (meaning reasonable, necessary, and proportionate) with the ones listed below:

• Overseeing compliance with legal and regulatory obligations on an ongoing basis. This includes, for example, responsibilities related to prevention of tax avoidance and fraud, Know Your Client (KYC), Anti-Money Laundering, and Anti-Terrorism Financing (AML/ATF), which trigger, among others, a suitability assessment to analyze risks involved in a potential business relationship. We must also comply with legal and regulatory disclosures involving the user or transfer of your Personal Information to the requesting authority.
• Initiating, establishing, and managing a business relationship and the termination of that relationship.
• Providing you information, products, and services of your choice, maintaining those products or services, and identifying and sharing with you information, products, or services that may interest you.
• Managing any requests derived from your business relationship with us (like purchases, redemptions, distributions, reinvestments, transfers, fees, and commissions payable). Depending on the context, this may include liaising with different financial institutions and providers, and exchanging Personal Information with them, as well as involving other entities within the Skyline Group of Companies (for example, as required for our finance department to process different transactions).
• Connecting you with plan trustees and, where needed, assisting you in setting up your account.
• Sending you or making available account statements and organizing and communicating with you about investor educational seminars.
• Connecting you with our partners (i.e., insurance providers) pursuant to referral agreements, where you express interest in knowing more about their products or services (note that this process may involve the disclosure of Personal Information).
• Additionally, we process your Personal Information for business purposes like record-keeping, data governance, analyses of our products and services, risk analysis, and for conducting data analytics in general, as well as in connection to the oversight and management of the security and resilience of our networks, systems, and physical premises.

In line with the Processing of your Personal Information for the purposes listed above, we conduct different sets of tasks (“Processing Activities”) that are required to provide you information, products, and services. Those Processing Activities dictate the Personal Information we collect, use, and disclose.

The following table highlights some of our Processing Activities and the categories of Personal Information we process or may process (depending on the context) pursuant to each Activity.

Note that Processing Activities and Personal Information collected, used, and disclosed may change occasionally.

Marketing Administration

Sales Administration

Operations Management and Finance

Compliance Management

Other Information of Relevance

1. Service Providers: We use service providers for different purposes. We require them to abide by applicable legislation and implement security controls to safeguard your Personal Information.

   Some of the categories of service providers with whom we share your Personal Information include marketing management, advertising partners, as well as technology vendors, analytics providers, credit bureaus, consultants, auditors, and record-keeping providers.

   In addition to service providers, you have relationships with third parties with whom we need to exchange your Personal Information for processing transactions. Moreover, where you express interest, we will connect you to our partners for the provision of additional products or services, in which case disclosure of Personal Information will be required.

2. Other Companies within the Group: If we determine that Processing of Personal Information by another entity within the Skyline Group of Companies would allow us to provide the service or product in a way that guarantees a better user experience for you, or where the expertise required to deliver you products or services lies with other entity within Skyline Group of Companies, we will grant them limited access, on a need-to-know basis, to the Personal Information they require to do so.
3. Government Bodies or Authorities, Courts, Police, and Compliance with Legal or Regulatory Obligations: Where required to disclose information per legal or regulatory requirements; asked to comply with an order or similar request, or to collaborate on matters subject to investigation, we will disclose your Personal Information to the extent permitted by law or, where available, in line with applicable case law (like court, tribunal, board, or commission decisions) when no law regulates the order or request. In addition, we will disclose your Personal Information when necessary to comply with legal or regulatory obligations.
4. Access Requests by Third Parties: In some cases, third parties submit requests for access to Personal Information which are processed in accordance with parameters provided by the law.