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

Last revised: June 30, 2023
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 Investment Management, LLC (“FEIM”); First Eagle Separate Account Management, LLC (“FESAM”); First Eagle Alternative Credit, LLC (“FEAC”); 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, First Eagle Global Real Assets Fund, First Eagle Rising Dividend Fund (formerly named First Eagle Fund of America), and First Eagle U.S. Smid Cap Opportunity Fund, each a separate portfolio of First Eagle Funds, an open-end investment management company; First Eagle Overseas Variable Fund, a portfolio of First Eagle Variable Funds, an open-end investment management company; First Eagle Credit Opportunities Fund, a closed-end interval fund; and First Eagle Private Credit Fund, a business development company (each, a “Trust” and, collectively with any additional portfolios that may be added to the Trusts from time to time, the “Trusts”).

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 and nonaffiliates. 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 Trust or private fund in which you hold shares will be the data controller of your personal information for data protection law purposes. If you have a separately managed account, FEIM, FESAM, or FEAC is the data controller of your personal information for such separately managed account for the purposes of data protection law.

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 became a client or shareholder of First Eagle and are therefore covered by this Privacy Notice.

Sources and Types of Personal Information We Collect

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

  • Information we receive from your (or your employer’s, financial intermediary’s and/or designated representative’s) correspondence, interactions and transactions with us, our affiliates or others, including by letter, email, telephone, and our websites, and through information provided on subscription applications or other forms, such as your name, address, email address, telephone number, Social Security number, occupation, assets and income;
  • Information about your transactions with us, our affiliates, or unaffiliated third parties, such as your holdings and investment activity;
  • Information we receive from consumer reporting agencies, our service providers or other sources we may engage in connection with conducting due diligence, know-your-customer, anti-money laundering, and other checks required to be performed in relation to admitting new investors;
  • Information from public records we may access in the ordinary course of business; and
  • Information collected from you online, such as your IP address and data gathered from your browsing activity and location.
Why We Have and How We Use Your Personal Information

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

  • Where processing is necessary to perform a contract with your or take steps to enter into a contract at your request in order to provide you with First Eagle’s products and services, including to process your subscription application and other forms, provide information you have requested, create and administer your account, manage and administer your shares, maintain registers and communicate with you about your investments;
  • Where processing is in our legitimate interests, including to operate and facilitate our business and services to you, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain our core records, protect First Eagle’s rights and interests, ensure the security of our assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, and enforce our terms and conditions;
  • Where processing is necessary to comply with our legal and regulatory obligations including but not limited to applicable know-your-customer requirements, tax, anti-money laundering, fraud, sanctions and counter terrorist financing legislation. Personal information (including financial information) may be shared with applicable regulators, government bodies and 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);
  • Where processing is necessary for the establishment, exercise or defence of legal claims; and ;
  • For any other specific purposes where you have given consent.