Personal Data Protection
PFA Asset Management A/S (hereinafter “PFA Asset Management”) is licensed as an asset management company by the Danish Financial Supervisory Authority, pursuant to the Danish alternative investment funds manager act. PFA Asset Management manages the following alternative investment funds that are all a part of the PFA Group, and has the power to enter into legally binding transactions on behalf of each of the following entities:
- PFA DK Core Erhverv I K/S
- PFA Investment Fund (umbrella structure)
- PFA Capital Association (umbrella structure) in Danish PFA Kapitalforening
PFA Asset Management is also licensed as a manager of undertakings for collective investment in securities (UCITS), pursuant to the Danish Financial Business Act, and acts as a manager for:
- Investeringsforeningen PFA Invest (a UCITS fund listed on Nasdaq Copenhagen A/S).
In addition, PFA Asset Management is acting as a portfolio manager on behalf of discretionary mandates, and further as an investment advisor for professional clients.
The EU General Data Protection Regulation ("GDPR") came into force on 25 May 2018. GDPR strengthens the rights of individuals regarding their personal data and seeks to unify data protection laws across Europe, regardless of where the personal data is processed. PFA Asset Management is obliged to comply with the regulation on behalf of PFA Asset Management as an investment management company, and on behalf of each of the company’s managed entities by informing you about what personal data PFA Asset Management retains from you, how it is attained, how it is used, and for how long the personal data it retained.
PFA Asset Management is considered a data controller on behalf of members and investors in Investeringsforeningen PFA Invest and PFA Kapitalforening, while these entities are considered responsible for data protection.
In order to reach PFA Asset Management regarding your personal data, you shall contact :
PFA Asset Management A/S
2100 Copenhagen O
CVR-nr. 32 67 18 88
att: Governance & Business Support
When and why will your personal data be processed?
PFA Asset Management can process your personal data in the following circumstances:As a member of Investeringsforeningen PFA Invest
When you become a member of Investeringsforeningen PFA Invest you are not obliged to enter any of your personal information, unless you wish to tag your investment with your name. In this case your investment will be listed with your name in the Central Securities Depository, VP Securities (hereinafter “VP”) and in the book entry records of VP.
When your ownership of the instrument is attached, you are automatically entitled to a number of member rights. Amongst these rights, you will be entitled to participate in the general assembly of Investeringsforeningen PFA Invest and to vote, if a request is made. Further to this, you will also be given personal notices, if this has been considered necessary by PFA Asset Management. As a member you will be able to receive newsletters and other relevant marketing material, if you wish to receive this.
In order to be able to summon you to the general assembly, and provide you with marketing material and newsletters, PFA Asset Management needs to be able to administer your member rights and receive information about you from VP. This information contains: Name, postal address, mailing address, depo number and ownership share. The information is, however, only available to PFA Asset Management if you have provided this upon registry.
As a beneficial owner of a company in which PFA seeks to invest If you are beneficial owner of a company in which PFA seeks to invest, PFA Asset Management may collect personal legitimation from you in order to perform KYC in accordance with applicable Anti Money Laundering regulation.
Information retained from www.pfaassetmanagement.dk
The information is qualified as general statistic data that cannot be traced back to any specific individual. PFA Asset Management does not have access to your personal information, and the information is used for statistical purposes use only.
Information retained from telephone recordings
Under MIFID II (2014/65/EU) PFA Asset Management is required to record telephone conversations, and keep a copy of electronic communications that relates to the activities in financial instruments that are made with, sent from, or received on equipment that is provided by PFA Asset Management to an employee and/or a contractor.
Hence, PFA Asset Management keep records of communications relating to client transactions. The information is retained to ensure evidence to resolve disputes between firms and clients, to assist supervisory authorities and to help prevent market abuse through enhanced detection.
Legal basis for processing, using and sharing your personal data
The legal basis for processing, using and sharing your personal data adheres from:
- Executive Order on Management and Control of Banks, etc.
- Executive Order on Beneficial Owners
- Executive Order on Investor Protection in connection with Securities Trading
- Danish Anti Money Laundering Act
- Danish Data Protection Act
- The General Data Protection Regulation (GDPR)
- Markets in Financial Instruments Directive (MIFID II)
- Market Abuse Regulation (MAR)
Furthermore, PFA Asset Management will access your information to the extend you give PFA Asset Management your express consent, in accordance to art. 6, (1), a and b in GDPR, or if your consent applies under the conditions of art. 9 in GDPR.
PFA Asset Management can also use your personal data to the extend it is determined to be of legitimate interest to us. An example of such instance would be, if use of your personal data would be crucial to prevent misconduct, fraudulent behavior, and if such personal data can be used for maintaining your requested member rights.
Sharing personal data
PFA Asset Management may share your personal data with PFA Bank if you are a member of Investeringsforeningen PFA Invest. PFA Bank has entered into a confidentiality agreement as a distributor of Investeringsforeningen PFA Invest.
Furthermore, PFA Asset Management may share personal data with PFA Pension, if you are a beneficial owner of a company in relation to which PFA Asset Management has entered into a financial transaction. The relationship between PFA Asset Management and PFA Pension is subject to confidentiality.
PFA Asset Management may also share your personal data with regulatory authorities to the extent PFA Asset Management is required to share information, in accordance to applicable law and regulation.
When PFA Asset Management process your personal data, you have the right to:
- obtain access to the personal data held about you;
- ask for incorrect, inaccurate or incomplete personal data to be corrected;
- request that personal data be erased when it’s no longer needed or if processing it is unlawful;
- object to the processing of your personal data for marketing purposes or on grounds relating to your situation;
- request the restriction of the processing of your personal data in specific cases
- receive your personal data in a machine-readable format and send it to another controller
How is your personal data stored?
PFA Asset Management hold your personal data if the personal data serves a legitimate purpose. Hence, PFA Asset Management retain your personal data if PFA Asset Management provide a financial service or a product to you.
Personal data that is processed and used in accordance to the anti-money laundering regulation can be retained for 5 years after a customer relationship is finalized.
Personal data that is collected through recorded telephone conversations in accordance to the MIFID II regulation is deleted after 7 years. Personal data used for statistical purposes will be deleted immediately after use if such personal data is not anonymized.
Complaints to the Danish Data Protection Agency
You may always exercise your right to file a complaint to the Danish Data Protection Agency, if you find that PFA Asset Management has breached any personal data protection rules. However, you should always initiate by contacting PFA Asset Management, if you find that such breach has occurred. Complaint addressed to the Danish Data Protection Agency shall be sent to email@example.com. More information can be found on www.datatilsynet.dk.
Who is responsible for personal data in PFA Asset Management?
If you have any questions regarding the collection, processing, usage, storing etc. of your personal data, you can contact our Data Protection Officer on firstname.lastname@example.org.