Wellington Management Funds (Luxembourg) - Wellington Downside Alpha Opportunities Fund USD S AccU

Privacy Statement of Swiss Fund Data AG

This Privacy Statement explains how Swiss Fund Data AG (hereinafter «Swiss Fund Data») collects, uses and discloses (hereinafter referred to together as «processes») personal user data (hereinafter «Personal Data») of visitors to this website (hereinafter «User»), and the means by which this is done. The Privacy Statement also describes how Swiss Fund Data safeguards the confidentiality of the Personal Data processed.

The User agrees to Swiss Fund Data processing Personal Data in accordance with the Privacy Statement. Legal or contractual duties to maintain confidentiality to which Swiss Fund Data is subject in relation to the User's Personal Data are not affected by this Privacy Statement.

Swiss Fund Data may amend the Privacy Statement unilaterally at any time. The most recent version is published online by Swiss Fund Data.

Type of collected Personal Data

Swiss Fund Data processes Personal Data about the User if the latter

• visits websites of Swiss Fund Data,
• applies for or uses products or services offered by Swiss Fund Data online; this includes, in particular, registration for the MyFunds service, request specific fund information via contact form and subscriptions to online newsletters,
• or when a participant uses our web tool for administrative purposes.

On the one hand, Swiss Fund Data processes that specific data (e.g. name, gender, address, email, telephone, fax, investor profile and function), that the User explicitly and actively provides to Swiss Fund Data. Same occurs if the User takes parts on events of Swiss Fund Data (online and personal presence). On the other hand the webserver of Swiss Fund Data records automatically specific details about the visit of the User (e.g. IP-address, type of browser and version, used operating system, origin website, requested pages, date, time of usage).

Furthermore, Swiss Fund Data does not collect any particularly sensitive data and restricts its range of services to persons domiciled in Switzerland.

Cookies

The websites of Swiss Fund Data use essential cookies, which are saved on the User's computer. These enable Swiss Fund Data to retrace the User's visit and to save their preferences if they switch pages or revisit the website at a later date.

Cookies particularly serve the following purposes:

• save the User's preferred language, country settings or investor profile
• perform a statistical analysis of the number of users and of their usage habits
• improve the loading speed of the individual pages

The User can control cookie specifications via their browser settings. The relevant browser options and instructions on use can generally be found in the browser manual or help file. If the User rejects, blocks or deactivates cookies, this may restrict the availability of the services offered via the website. In addition, parts of the website may not work correctly under certain circumstances.

Web analysis

Swiss Fund Data analyses how its websites are used with the help of third-party analysis tools, such as Google Analytics (hereinafter «Analysis Service Providers»). Swiss Fund Data assumes no responsibility or liability for any data processed by Analysis Service Providers.

Google Analytics

Google Analytics, a web-based analysis service by Google Inc. (hereinafter «Google»), uses cookies, which are saved on the User's computer. The information generated by the cookie concerning their visit is usually sent to and stored on a Google server in Ireland. If Swiss Fund Data activates IP anonymization for this website, Google shortens the User's IP address within Member States of the European Union or in other partner states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and anonymized there. Google evaluates the information that has been saved on behalf of Google for the purpose of compiling reports on the website's usage and in order to provide other associated services for Swiss Fund Data. Google may combine the IP address transmitted from the User's browser by Google Analytics with other data that has been collected.

For more information on how to disable Google Analytics in the user's browser, see
https://tools.google.com/dlpage/gaoptout?hl=en.

Usage and protection of Personal Data

By processing Personal Data according to this Privacy Statement, Swiss Fund Data is able to improve the quality of its products and services.

Personal Data is processed for the following purposes in particular:

• technical management as well as research and further development of websites
• user administration and marketing
• user information on the services and products rendered by Swiss Fund Data, provided the User has given their consent for this

The User authorizes Swiss Fund Data to transmit Personal Data to employees, agents or other third parties within or outside the country where the User lives in order to provide services and for the purposes indicated above. Employees, agents and other third parties which have access to Personal Data are required by Swiss Fund Data to ensure compliance with all applicable data protection provisions. Any person who authorizes Swiss Fund Data to access their Personal Data as defined in this Privacy Statement will be made aware of the data security and data protection implications.

Swiss Fund Data protects Personal Data with appropriate physical, electronic and process-related security measures, such as firewalls, personal passwords, encoding and authentication technologies.

Swiss Fund Data reserves the right to disclose Personal Data to regulatory and supervisory authorities, as well as, pursuant to this Privacy Statement, to Analysis Service Providers. In so doing, Swiss Fund Data will comply at all times with applicable regulations, laws, court orders or official requests.

Information on processed Personal Data

Persons whose Personal Data is processed within the scope of this Privacy Statement have the following rights:

• to receive information on whether Swiss Fund Data may save Personal Data and what form this Personal Data may take (which categories of data, recipients or categories of recipients, retention periods for Personal Data or criteria governing retention periods)
• to receive a copy of the Personal Data
• to request the rectification of Personal Data if it is incorrect
• to request the deletion of Personal Data
• to request restrictions on processing Personal Data
• to receive Personal Data in a structured, accessible and machine-readable format
• to submit an objection to processing, especially for the purpose of direct advertising

The rights specified above may be denied or restricted if the interests, rights and freedoms of third parties take precedence or if processing is necessary to establish, exercise or defend legal claims of Swiss Fund Data.

Queries in relation to processing Personal Data are to be directed to the Data Protection Officers of Swiss Fund Data:

Swiss Fund Data AG
Geschäftsleitung
Räffelstrasse 24

CH-8045 Zürich

E-Mail: info@swissfunddata.ch

Links

The websites of Swiss Fund Data may contain hyperlinks to other websites which are not operated or monitored by Swiss Fund Data. Third-party websites are not subject to this Privacy Statement. Swiss Fund Data is not responsible for their content or how they handle Personal Data.

Social Media Buttons

Functions (plugins) of third-party providers or social media platforms (Facebook, Twitter, Google+, etc.) are embedded into the websites of Swiss Fund Data. These plugins enable the User to share content on the social networks mentioned. The interfaces are deactivated by default when the website is accessed. This means that no Personal Data is transmitted to the respective third-party providers without intervention on the part of the User. Once the User has activated the interfaces, data (incl. also Personal Data) is automatically transmitted to the relevant third-party providers by the plug-ins. If the User is simultaneously logged in to the network of the respective third-party provider when they visit the website, the third-party provider can assign the visit to the User's network account. Swiss Fund Data has no influence on this. The purpose and scope of such a form of data collection and the further processing and usage of Personal Data are outlined in the data protection guidelines of the individual social networks. Users can also obtain information there on rights and settings options in relation to protecting their privacy.

Responsible Data Protection Officer

Swiss Fund Data AG
Geschäftsleitung
Räffelstrasse 24

CH-8045 Zürich

E-Mail: info@swissfunddata.ch

Right to withdraw consent in respect of data protection

Anyone affected by the processing of Personal Data can withdraw their consent to this effect at any time. This must be done in writing or by e-mail to the Data Protection Officer of Swiss Fund Data.

In addition, every data subject has the right to enforce his or her claims through legal channels or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).

Copyright © 01.09.2023 Swiss Fund Data AG. All rights reserved.