Privacy policy

November 12, 2021

In accordance with the requirements of the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), we hereby inform you about the principles of personal data processing and the associated rights. The following principles apply from May 25, 2018.

The controller of personal data is MOUNT Investment Funds Company A. (“Company”) and the investment funds managed by the Company (collectively “Fund”), both entities based in Warsaw, ul. Żelazna 51/53, 0-841 Warsaw, biuro@mounttfi.pl (together “Controller”). Personal data will be processed when necessary for:

1. The performance of the Fund’s contract, based on Article 6(1)(b) of the Regulation (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“General Data Protection Regulation”), and

2. Fulfillment of legal obligations incumbent on the Controller, based on Article 6(1)(c) of the General Data Protection Regulation, arising from the Act of May 27, 2004, on investment funds and alternative investment fund management (in the case of the Company’s obligation to archive documentation, handle complaints, and, in the case of the Fund, fulfill the obligation to maintain a register/record of participants and settle transactions with participants), the Act on Counteracting Money Laundering and Terrorism Financing, the Act of October 9, 2015, on the execution of the Agreement between the Government of the Republic of Poland and the Government of the United States of America on improving the fulfillment of international tax obligations and implementing FATCA legislation, and the Act of March 9, 2017, on the exchange of tax information with other countries (CRS), the Act of April 20, 2004, on individual retirement accounts and individual retirement security accounts, and the Act of April 20, 2004, on employee retirement programs.

3. The purposes arising from the legally justified interests pursued by the Controller or a third party, based on Article 6(1)(f) of the General Data Protection Regulation, for which the Controller recognizes: direct marketing, investigation and defense against claims, fraud prevention, data transmission within the group of companies, statistics and analysis, ensuring the security of the teleinformatics environment, and the application of internal control systems.

Recipients of my personal data may be entities authorized to do so under the law and entities cooperating with the Controller, including: a transfer agent maintaining a register of participants or an entity supporting the Company in maintaining a register of participants in investment funds managed by the Company, distributors of units of participation, or entities offering investment certificates, entities providing advisory and audit services, IT services, archiving and document destruction services, and marketing services on behalf of the Controller, expert auditors in connection with the audit. Personal data will be stored for a period necessary for: the performance of the contract, fulfilling legal obligations incumbent on the Controller, and investigation and defense against claims for a period resulting from the general limitation periods for claims calculated from the termination of participation in the Fund. The person whose data is processed has the right to access the content of their data and the right to rectify, delete, restrict processing, the right to data portability, and the right to object to the processing of their personal data for direct marketing purposes, including profiling, to the extent that processing is related to direct marketing. The person whose data is processed has the right to object to the processing of their personal data when processing is necessary for other purposes arising from the legally justified interests pursued by the Controller, without affecting the lawfulness of the processing. The person whose data is processed has the right to lodge a complaint with the President of the Office for Personal Data Protection. Providing personal data is voluntary, but it is necessary to participate in the Fund, and failure to provide them will prevent the conclusion of a contract. Personal data are not processed in an automated manner and are not subject to profiling.