Privacy Notice for First Eagle’s Non-U.S. Clients and Shareholders

Last revised: December 20, 2021
 
1.    Privacy Notice for First Eagle’s Non-U.S. Clients and Shareholders

This Privacy Notice is provided by the following entities (collectively “First Eagle” or “we): First Eagle Global Fund, First Eagle Overseas Fund, First Eagle U.S. Value Fund, First Eagle Gold Fund, First Eagle Global Income Builder Fund, First Eagle High Income Fund (formerly named First Eagle High Yield Fund), First Eagle Small Cap Opportunity Fund, and First Eagle Fund of America and First Eagle Global Real Assets Fund, separate portfolios of First Eagle Funds, an open-end investment management company, as well as the First Eagle Credit Opportunities Fund, a closed-end interval fund (each a “Trust” and, combined, the “Trusts”), together with any additional portfolios that may be added to the Trusts from time to time, as well as First Eagle Investment Management, LLC (“FEIM”), First Eagle Separate Account Management, LLC (“FESAM”) First Eagle Alternative Credit, LLC (“FEAC”) and First Eagle Alternative Capital BDC, Inc. (“FCRD”).

First Eagle is committed to protecting your privacy. We are providing you with this Privacy Notice to inform you of how we handle your personal information that we collect and may disclose to our affiliates. If the First Eagle information practices change, we will provide you with notice of any material changes. This Privacy Notice supersedes any of our previous policies relating to the information you disclose to us. The fund in which you hold shares will be the data controller of your personal information for data protection law purposes. If you have an investment management account or separately managed account, FEIM, FESAM, FEAC or FEAC BDC is the data controller of your personal information for that account for the purposes of data protection law.

2.    Why this Privacy Notice Applies to You

You obtained a financial product or service from or through us for personal, family or household purposes when you opened an account with First Eagle and are therefore covered by this Privacy Notice.

3.    What We Do to Protect Your Personal Information

We protect personal information provided to us according to strict standards of security and confidentiality. These standards apply to both our physical facilities and any online services we may provide. We maintain physical, electronic and procedural safeguards that comply with United States federal standards to guard consumer information. We permit only authorized individuals, who are trained in the proper handling of individual personal information and need to access this information to do their job, to have access to this information.

4.    Personal Information that We Collect and May Disclose

As part of providing you with First Eagle’s products and services, we obtain non-public personal information about you from the following sources:

(a)    Information we receive from you on subscription applications or other forms, such as your name, address, telephone number, Social Security number, occupation, assets and income;
(b)    Information about your transactions with us, our affiliates, or unaffiliated third parties, such as your account balances, payment history and account activity;
(c)    Information from public records we may access in the ordinary course of business; and
(d)    Information collected from you online, such as your IP address and data gathered from your browsing activity and location.

5.    Why We Have and How We Use Your Personal Information

We use your personal information for a number of reasons including:

(a)    to provide you with First Eagle’s products and services and/or manage and administer your shares;
(b)    to comply with our legal and regulatory obligations including but not limited to applicable tax, anti-money laundering and counter terrorist financing legislation. Personal information (including financial information) may be shared with relevant tax authorities. They in turn may exchange information (including personal information and financial information) with foreign tax authorities (including foreign tax authorities located outside the European Economic Area);
(c)    to carry out statistical analysis and market research in First Eagle’s legitimate business interest; and
(d)    for any other specific purposes where you have given specific consent.

6.    How Long We Keep Your Personal Information

We will keep your data for as long as you are a client or shareholder and afterwards in accordance with our legal and regulatory obligations. 

7.    Disclosure and Transfer of Your Personal Information

We may share personal information about you with affiliates. Our affiliates do business under names that include but are not limited to: First Eagle Holdings, Inc.; First Eagle Investment Management, LLC; FEF Distributors, LLC; First Eagle Separate Account Management, LLC; First Eagle Alternative Credit, LLC; First Eagle Alternative Capital BDC, Inc.; First Eagle Investment Management, Ltd; First Eagle Investment Management GmbH; First Eagle Funds (Ireland) ICAV; First Eagle Amundi Sub-Funds (Luxembourg) SICAV; and any other First Eagle Funds and any sub-funds, as applicable.
If you are located in Europe please note due to the global nature of First Eagle’s operations, it may be necessary to disclose your personal information to persons in locations outside of the European Economic Area, the United Kingdom and/or Switzerland. Where First Eagle does disclose or transfer your data outside of these regions, we will ensure that appropriate data transfer mechanisms are in place. Generally, we put in place European Commission approved standard contractual clauses for such transfers. 

8.    You May Limit Marketing Solicitations by Choosing to Opt Out

We offer you the right to opt out from many types of marketing by our affiliates based on your personal information that we collect and share in accordance with this Privacy Notice. To limit those marketing solicitations, Trusts investors may call 800.334.2143 indicating your desire not to receive marketing from our affiliates. Investors in private funds or separate accounts managed by First Eagle may call 800.800.9006. Should you choose to opt out, your choice will remain in our records until you notify us otherwise, although we may choose to contact you in the future to modify your preference.

9.    Your Rights in Relation to Your Personal Information

If you are located in certain jurisdictions including the European Economic Area, the United Kingdom, Switzerland, Andorra, Argentina, Australia, Canada, Cayman Islands, the EU, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, and Uruguay, you have certain rights (subject to exceptions) with respect to our use of your personal information, which may include the right:

(a)    to access, amend, update, restrict, delete or object to the use of your personal information;
(b)    to request information about the basis on which your personal information is processed;
(c)    to withdraw your consent to the processing of your personal information (where the use of your personal information is based on your consent); 
(d)    to complain to your local data protection authority; and
(e)    to request we send a copy of your data to another entity.

10.    When We May Disclose Your Personal Information to Unaffiliated Third Parties

We will only share your personal information collected, as described above, with unaffiliated third parties:

(a)    At your request;
(b)    When you authorize us to process or service a transaction or product (unaffiliated third parties in this instance may include service providers such as brokers and custodians, Trust distributors, registrars and transfer agents for shareholder transactions, sponsors of wrap fee or other non-institutional separately managed account programs, including certain broker-dealers, banks, investment advisers, and other parties providing individual servicing, accounting and recordkeeping services);
(c)    With companies that perform sales and marketing services on our behalf with whom we have agreements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them; or
(d)    When required by law to disclose such information to appropriate authorities.
We do not otherwise provide information about you to outside firms, organizations or individuals except to our attorneys, accountants and auditors, and as permitted by law.

11.    What We Do with Personal Information about Our Former Customers

If you decide to discontinue doing business with us, First Eagle will continue to adhere to this Privacy Notice with respect to the information we have in our possession about you and your account following the termination of our relationship.

12.    How to Contact Us

If you have any questions about this notice or how we process your personal information, please call us toll free at: 1 (800) 482‑5667 or you can email us at FirstEagle.Privacy@feim.com.