Privacy Policy

Information Clause Regarding the Processing of Personal Data

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), we hereby inform you of the rules for processing personal data and the rights associated with it. These rules apply from 25 May 2018.

Data Controller

The controller of personal data is Mount Investment Funds Company S.A. (“Company”) and the investment funds managed by the Company (collectively the “Fund”), both located in Warsaw, ul. Żelazna 51/53, 00-841 Warsaw, Poland. Contact: biuro@mounttfi.pl (jointly referred to as the “Controller”).

Purposes and Legal Basis for Data Processing

Personal data will be processed when necessary for:

a) Performance of a contract — under Article 6(1)(b) GDPR, including maintaining participant registers and settling transactions;

b) Compliance with legal obligations — under Article 6(1)(c) GDPR, arising from laws such as:

The Act on Investment Funds and Management of Alternative Investment Funds

The Anti-Money Laundering and Terrorism Financing Act

The FATCA implementation act

The CRS (Common Reporting Standard) Act

The Acts on Individual Retirement Accounts and Occupational Pension Schemes

c) Legitimate interests pursued by the Controller — under Article 6(1)(f) GDPR, such as:

Direct marketing

Establishment and defense of legal claims

Fraud prevention

Data sharing within the corporate group

Analytics and statistics

IT system and data security

Internal controls

Data Recipients

Your personal data may be shared with:

Entities authorized under applicable law

Service providers such as: transfer agents, record-keeping support entities, fund distributors, marketing, IT, advisory, audit, archiving, and document destruction services

Auditors in connection with statutory audits

Data Retention

Personal data will be stored for the period necessary to:

Execute contracts

Fulfill legal obligations

Assert or defend against legal claims (according to general limitation periods)

Your Rights

Data subjects have the right to:

Access their data

Rectify, delete, or restrict processing

Data portability

Object to direct marketing (including profiling)

Object to processing based on legitimate interests

You also have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO).

Additional Information

Providing data is voluntary but necessary for fund participation. Refusal may prevent contract formation.

Personal data is not processed through automated decision-making or profiling.