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
+45 39 17 58 02
2. When and why will your personal data be processed?
PFA Asset Management process only personal data in the “General information” category. That is name, contact information, National ID Number.
PFA Asset Management may collect information from third parties in relations to screening of political exposed persons.
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 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.
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. The legal basis are The General Data Protection Regulation (GDPR), article.
As a beneficial owner of a company in which PFA seeks to invest or client to PFA Asset Management
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. Further we will ask you of this information if you become a client to PFA Asset Management A/S. The legal basis is Danish Anti Money Laundering Act, Chapter 3.
3. 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.
4. 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.
5. 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.
6. 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.
7. Your rights
When PFA Asset Management process your personal data, you have the right to:
The right to gain insight
You have the right to gain insight into what personal data PFA have at their disposal.
The right to object
You have the right to oppose the processing of your personal data and to limit it. In specific, you have the right to oppose the processing of your personal data for direct marketing purposes and to object to profiling in relations to direct marketing.
The right to edit
You have the right to edit incorrect personal data. In addition, you are entitled to add personal data, taking into account the purposes of the treatment.
The right to delete
Go to Section 3 to see when your personal data will be deleted by PFA - Retaining your Personal Information. In special cases, you have the right to delete your personal data before the specified deadlines.
The right to limited treatment
You have the right to limit PFA's processing of your personal data in certain cases, including when in doubt of the accuracy of your data.
The right to data portability
You have the right to request and receive all personal data that PFA received from you in a structured format. You have the right to receive your submitted personal data, held by PFA. Also, you have the right to have your personal data transferred from PFA to another data controller.
Withdrawal of consent
At any time, you have the right to revoke your consent concerning your personal data processed by PFA. Withdrawal of your consent entails that PFA may not process your personal data for the purpose for which you gave your consent. If you revoke your consent it does not affect earlier processing of your personal data even though it may lead to a termination to the customer relationship. Finally, PFA may be entitled to process your personal data on a basis other than consent.
At any time, feel free to contact us at PFA.
Restrictions on the rights above may occur for example about data portability and the right to delete personal data. This depends on the specific circumstances of the data processing.
8. 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.
9. 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.
10. Contact information on PFA’s data protection officer (DPO)
We are responsible for collecting and processing your personal data. Please contact PFA Group’s data protection officer concerning any questions regarding processing of your personal data.
Phone: +45 70 20 75 15