Additional information about how we process your personal data can be provided in pre-contractual information, contracts and other documents related to the provision of our services.
Privacy pocicy compliance
Where and what information do we get about you?
We receive your personal data directly from you when you submit inquiries to us, conclude or intend to conclude contracts with the Management Company, fill out application forms, other documents requested by the Management Company, communicate with us on social networks.
When you intend to conclude or enter into contracts with the Management Company, when submitting applications to it, we process the following personal data: data related to identification: name(s), surname(s), personal identification number, date of birth, tax payer code, country of residence, citizenship, personal identification document data, digital identification data if your identity is determined remotely, signature. Also contact data: address of place of residence, address for correspondence (if assigned), telephone number, e-mail e-mail address, data related to your family situation, website browsing data, your visits to social networks administered by the Management Company, other data: taking into account the measures of the money laundering and terrorist financing prevention policy implemented by the Management Company, your presence as a politically vulnerable (affected) person, you assigned risk class, data related to the application of sanctions to you, information on sources of income and invested amount, activities (occupation, positions held), employer, available accounts in credit institutions, direct or indirect participation in company management (controlling 25% or more), as well as taking into account the requirements of legislation governing taxes, the country of residence for tax purposes When you submit inquiries on the website, you provide us with your name, surname and email address.
When you want to order the newsletters of the Management Company, you provide us with an e-mail address. When legal entities contact us regarding the provision of services, we may receive the following data from you as a representative, manager, owner, shareholder, beneficiary, voter of such a legal entity: data related to identification: name (- us), surname(s), personal identification number, date of birth, citizenship, country of residence, country of residence, personal identity document data.
Contact details of the representative: address for correspondence, telephone number, e-mail e-mail address, other data: taking into account the measures of the money laundering and terrorist financing prevention policy implemented by the Management Company, your presence as a politically vulnerable (affected) person, data related to the application of sanctions, data on the beneficiaries of the client – a legal entity (their names, surnames, country of tax payment, amount of control).
Indirectly, we may also receive information about you with a legitimate interest related to risk reduction or in accordance with the requirements of legal acts regulating the prevention of money laundering/terrorist financing, when at your request we make a decision on the provision of a service to you or provide you with services available to us. sources: registers, we can also collect information using internet search engines.
Personal data processing for direct marketing purposes
We generally process your personal data for the following purposes:
- the decision to enter into a transaction with you,
- Confirmation of your identity,
- administering, responding to your inquiries or in order to solve the problems that have arisen,
- in order to protect and defend their rights and legitimate interests,
- in compliance with the requirements of legal acts, including those for the prevention of money laundering and terrorist
- financing and legal acts regulating the Management Company and its activities,
- improving our services and developing our activities,
- in direct marketing,
For the purposes specified in this section, we process your personal data when we are required to do so by legal acts, a transaction with you, our legitimate interest, when we seek to protect our or if we have received your consent for the processing of personal data.
What information do we collect?
When processing your personal data for the purpose of direct marketing, we ask you to provide consent for such processing. If you do not give your consent, we will not process your personal data for this purpose. If you give your consent, you can withdraw it at any time by contacting us by e-mail at firstname.lastname@example.org
For direct marketing purposes, we will process personal data for a maximum of 3 years after receiving your consent or until you withdraw your consent to data processing for this purpose, whichever comes first.
Term of personal data storage
We ensure that your personal data is processed no longer than is necessary to achieve the purposes of data processing, no longer than is provided for by legal acts.
We will process the personal data of the clients of the management company who invest in the collective investment entities managed by it, which are not related to the requirements for the prevention of money laundering and terrorist financing, for the entire period of activity of the collective investment entity and for at least 3 years after the termination of the collective investment entity. We will normally store other personal data during the execution of the contract and for 10 years from the last calendar day of the year in which the contract concluded with the Management Company was executed, unless longer periods are necessary in order to fulfill legal requirements, defend legal interests, or longer storage periods are mandatory in the performance of requirements related to the archiving of documents or other requirements established by legal acts.
If the transaction is not concluded, we will store personal data for 2 years from the date of receipt of your application for the provision of services, unless in compliance with the requirements of the legislation on the prevention of money laundering and terrorist financing, we will be required to store personal data for a longer period or if a longer period of personal data storage is necessary in order to protect our interests .
At the end of the retention period, we will either delete, destroy or anonymize the collected personal data. Some personal data stored in computer files may still be available for a certain period of time after their retention period has expired in data backup systems, but access to such personal data is strictly limited.
Personal data security
Since we value the security of your personal data, we apply appropriate technical and administrative measures to protect the personal data collected by us from loss, unauthorized use and changes.
The security of your personal data is extremely important to us, so we handle all personal data strictly in accordance with the principle of confidentiality.
Who do we transfer your personal data to?
We can transfer your personal data to the following recipients: persons providing accounting services, auditors, other consultants, payment service providers, engaged data processors, state institutions, law enforcement agencies and other persons in accordance with the procedure established by the legal acts of the Republic of Lithuania, to other recipients specified in the Management Company in the concluded transaction or in other documents presented to you.
After receiving your consent, we will be able to provide personal data to other persons.
When transferring your personal data to other persons, we ensure the security of the transferred personal data.
Personal data processors
In order to fulfill our obligations to you, as well as to ensure the operation of the Management Company and its managed collective investment entities, we may use data processors who, according to our instructions and to the extent determined by us, will process personal data to the extent necessary to achieve the purposes of personal data processing.
When choosing data processors, we require that the data processors have implemented appropriate organizational and technical security measures to ensure the security and confidentiality of personal data.
Data subject rights
We will normally provide such information to you free of charge, unless your requests are manifestly unreasonable or disproportionate, in particular due to their repetitive content. In addition, if your requests are clearly unreasonable or disproportionate, we have the right to refuse to fulfill your request.
If you do not specify the form of information submission in your request, we will provide you with the information in the same form as the received request.
The right to request the correction of personal data and to stop the processing of personal data if it is determined that the data is incorrect, incomplete or inaccurate.
The right to demand the destruction of personal data or restriction of data processing actions, if it is determined that personal data is being processed illegally or dishonestly.
The right to object to the processing of personal data, except in cases where these personal data are processed for our or a third party’s legitimate interest, if your interests are not more important.
You can request the deletion of all data we have collected about you and thus exercise the right to “be forgotten”. We have the right to refuse to fulfill your request “to be forgotten” in the cases established by law.
You have the right to demand that the personal data provided by you, if they are processed on the basis of consent or contract, and if they are processed by automated means, be “transferred”, i.e. forward to another data controller or transfer to you in a structured, commonly used and computer-readable format, if this is technically possible.
You have the right to object to only automated data processing, including profiling.
As a general rule, we do not make decisions about you based on automated processing of personal data. If we do make such decisions, at your request, we will review the decision and evaluate all relevant data.
If you have doubts about the legality of our processing of your personal data or if you are not satisfied with the solution to the situation, you have the right to file a complaint about such processing of personal data with the State Data Protection Inspectorate (address L. Sapiegos st. 17, Vilnius, e-mail address ada@ ada.lt, website https://vdai.lrv.lt/) or to a competent court. You have the right to complain about our actions or inaction by yourself or through a duly authorized representative or a non-profit institution, organization or association that meets the requirements established by law.
If you have suffered material or non-material damage as a result of us violating your rights as a data subject, you have the right to compensation.
Protection of minors
We do not provide services to persons under the age of 18. If we learn that personal data has been obtained directly from persons under the age of 18, we will immediately destroy such personal data. If you are under 18 years of age, you must obtain the consent of your parent or other legal guardian before submitting information about yourself.
If you are the parent or legal guardian of a child and you believe that your child has provided us with personal data, please inform us immediately so that we can delete such data immediately.
Social media fetures
We may have profiles on social media such as Facebook, Linkedin, etc. If you intend to communicate with us on social media, please read the privacy notices of the operators of the social network and contact them directly regarding the use of your personal data.
Novus Asset Management UAB
Address: M. Valančius 1A, LT-03155, Vilnius
We value all your questions, advice and opinion, so we will try to answer you as soon as possible.