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GQG PARTNERS FUNDS PRIVACY POLICY

Last Updated: September 22, 2022

This Privacy Policy describes how the GQG Partners Funds (collectively, the "GQG Funds," "we," or "us"), each a series of The Advisors' Inner Circle Fund III, collect, use, and disclose information about you. This Privacy Policy applies to information we collect when you access or use our online shareholder portal (collectively, our "Portal"), contact us by phone, or when you otherwise interact with us, such as through our customer support channels.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and publicly posting it on the Portal. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

In addition to this Privacy Policy, customers should also review the GQG Funds Privacy Notice included within the GQG Funds' prospectus available at https://gqgpartners.com under "Funds".

Lastly, as is common with funds like ours, the GQG Funds rely on the services of third parties to carry out various operational tasks. For example, we use DST Systems, Inc. ("DST Systems") to operate the Portal, including managing collection, storage, and retention of information about you at sign-up and thereafter. For more information about how DST Systems handles information about you, please refer to the privacy policy of DST Systems' parent company, SS&C Technologies Holdings Inc.

CONTENTS

Collection of Information Use of Information Disclosure of Information Analytics Transfer of Information to the United States and Other Countries Your Choices Protection of Information Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you fill out a form, create an account through the Portal or by phone, or otherwise submit information about you through our Portal, request customer support, or otherwise communicate with us. The types of information about you that we collect include your name, email address, postal address, phone number, Social Security number, date of birth, bank account information (if applicable), username and password, and any other information we may need to open your account, verify your identity and residency or that you otherwise choose to provide.

Information We Collect Automatically

We automatically collect certain information about your interactions with us or our Portal, including:

  • Transactional Information: When you make trades through the Portal, we collect information about the transaction, such as the name of the fund, the purchase price and the date of the transaction.
  • Call Recordings: We may record your call when you call to open an account or request customer support.
  • Device and Usage Information: We collect information about how you access our Portal, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version, if applicable. We also collect information about your activity on our Portal, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Portal.
  • Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us, such as DST Systems) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Portal. Cookies are small data files stored on your hard drive or in device memory that help us improve the Portal and your experience, see which areas and features of our Portal are popular, and count visits. Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that we use on our Portal and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We obtain information from other sources. For example, if you are a beneficiary, partner, trustee of a trust or an authorized trader relating to one of our customers, our customers may have provided us with your name, address, date of birth and Social Security number. We may also receive information about you from identity verification providers, consumer reporting agencies (including credit bureaus), other advisors, and brokers/financial intermediaries.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve our investment management services and functionality of the Portal. We also use the information we collect to:

  • Verify your identity;
  • Provide, maintain, improve, and develop new products and services, including to debug and repair errors in our Portal;
  • Personalize your experience with us;
  • Send you technical notices, security alerts, support messages and other transactional or relationship messages;
  • Communicate with you about products, services, and events offered by GQG Funds and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our products and services;
  • Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
  • Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of GQG Funds and others;
  • Comply with our legal and financial obligations;
  • Create de-identified, anonymized, or aggregated information; and
  • Carry out any other purpose described to you at the time the information was collected.

DISCLOSURE OF INFORMATION

We disclose personal information in the following circumstances or as otherwise described in this policy:

  • We disclose personal information to vendors that access personal information to perform work for us, such as DST Systems, which assists us with satisfying our obligations under relevant customer identification and anti-money laundering laws as well as web hosting, and other companies that may assist us with services such as fraud prevention, customer service, and marketing and advertising.
  • We may disclose your name, address and size of your investment in any GQG Funds in regulatory documents if your investment exceeds a specific threshold.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of GQG Funds, our customers, the public, or others.
  • We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any reorganization or acquisition involving one of the GQG Funds and another company.
  • Personal information is disclosed between and among the GQG Funds and our current and future affiliated companies.
  • We disclose personal information with your consent or at your direction.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

ANALYTICS

We engage others to provide analytics services on the Portal. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Portal, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by the GQG Funds and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

The GQG Funds are located in the United States and have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law.

YOUR CHOICES

Account Information

You may update and correct certain account information at any time by logging into your account with us through the Portal or calling (866) 362-8333. If you wish to deactivate your account, please call (866) 362-8333 but note that we may retain certain information as required by law or for our legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Portal.

Communications Preferences

You may opt out of receiving promotional emails from the GQG Funds by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

PROTECTION OF INFORMATION

The GQG Funds implement security practices and policies designed to protect the confidentiality and security of information about you, which includes the information you provide to open an account or verify your identity (such as Social Security number and other identifying information) and other information we collect about you. The GQG Funds implement measures designed to limit access to this information to personnel that have a business reason to know it and prohibits its personnel from unlawfully disclosing this information.

CONTACT US

If you have any questions about this Privacy Policy, please contact us by calling (866) 362-8333.