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Your MainFirst Team

PRIVACY NOTICE

Thank you for visiting the website of MainFirst Affiliated Fund Managers S.A. and its subsidiaries (hereinafter “MainFirst”).

Further information about MainFirst can be found www.mainfirst-fundmanagers.com. In the use of our website, the issue of privacy and data security is very important for us. For this reason, we would like to inform you about which personal data we collect during your visit to our website, and the purposes for which they are processed in accordance with Regulation (EU) 2016/679 of 27 April 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 (the “GDPR” and together with any other applicable national laws and regulations, the “Data Protection Law”).
Because changes in the law or changes to our internal processes may require an amendment to this privacy notice (“Privacy Notice”), we kindly ask you to read this Privacy Notice regularly. This Privacy Notice can be accessed, stored and printed anytime under www.mainfirst-fundmanagers.com/impressum.

§ 1 Scope

This Privacy Notice applies to the MainFirst internet services, which are accessible under the domain www.mainfirst.com and the various sub-domains (hereinafter referred to as “our website”).

§ 2 What are personal data?

Personal data are information that could be used to identify personal or factual information about you (e.g. name, address, telephone number or email address). Data with which it is not possible to identify you (or only with a disproportionate level of effort) are not classified as personal data.

§ 3 What personal data do we collect, process and use?

It is possible to use the majority of our online presence without providing personal data.
Only data without personal references will be stored, e.g. the name of your Internet service provider, the website you were referred from, the names of requested files, and their request date. These data are solely for the purposes of improving our services and do not allow conclusions to be made about your person.
Nevertheless, it is necessary to provide additional data to the extent that you make use of the services offered by us on our website, such as ordering an Asset Management Factsheet or subscribing to a Newsletter. These concern data required for each procedure, such as the email address provided in order to subscribe to a newsletter.
We use data about you collected by us for the provision of our products and services, to respond to your inquiries, and in the operation and improvement of our websites and applications as further set out below.
Further use of your personal data will not take place. Your personal data is not disclosed to third parties, or a use of your data for promotional purposes without your consent, except the cases described below, will not take place unless we are legally obliged to disclose data (provision to prosecuting authorities and courts, provision to public bodies that receive these data by law, e.g. social insurance agencies, financial authorities, etc.), or in the case that we turn to third parties who are bound to professional secrecy.
The following services use personal data in the manner described below:

a) Newsletter
To subscribe to our email-based Asset Management Newsletter and Factsheet Service (hereinafter referred to as “Newsletter”), alongside your consent we require at least your email address to which the newsletter should be sent, and your name. Any additional information is optional and will be used to contact you personally and to personally tailor the contents of the Newsletter, as well as to clarify questions concerning your email address. You are free to decide whether to provide these data. However, without these data, it will not be possible to send you our Newsletter.
For the purpose of sending out the Newsletter, we generally use the so-called “double opt-in process”, whereby we only send you the Newsletter if you have previously confirmed your subscription via a link for this purpose contained in the confirmation email. Here, we hope to ensure that only you, as the owner of the email address, have consented to receiving the Newsletter. Your confirmation to this effect be carried out promptly after receipt of the confirmation email, otherwise your subscription to the Newsletter will be automatically deleted from our database.
Following subscription to our Newsletter, your email address will be used for promotional purposes until you unsubscribe. To unsubscribe, you can either send an informal email to unsubscribe@mainfirst-invest.com or use the link at the bottom of the newsletter.

b) Contact form
If you direct inquiries to us via our contact form, we will ask you for your first and last name, and your email address. You can then direct individual inquiries to us via the message field.
You are free to decide whether to provide these data. However, without this information, we will not be able to fulfill your contact request.

§ 4 Safeguards to protect the data stored with us

We commit ourselves to protecting your privacy and treating your personal data with confidence. To avoid any loss or misuse of data stored with us, we take extensive technical and internal security precautions, which are reviewed on a regular basis and updated in line with technical progress. We will inform you in case of personal data breach in relation to your personal data.

§ 5 Hyperlinks to external websites

Included in our website are so-called hyperlinks to other websites. When activating these links, you are forwarded directly from our website to the website of the other provider. You can recognise this, for instance, when there is a change of the URL. We cannot take responsibility for the strictly confidential handling of your data on these external websites, as we have no control over whether these companies comply with data protection regulations. Please obtain information on the handling of your personal data by these companies on their websites directly.

§ 6 Withdrawal / Objection

You may have given your explicit consent to the following text. We would like to point out that you have the right to withdraw your consent with effect for the future, and may object to the processing and use of your data for advertising purposes at any time: Please contact unsubscribe@mainfirst-invest.com.

Authorisation to send the Newsletter / Factsheet
( ) Yes, I would like to regularly receive the selected information from MainFirst, which will be sent to my email address. I can unsubscribe from the service at any time by clicking the “Unsubscribe” link at the bottom of the Newsletter, or via unsubscribe@mainfirst-invest.com.

§ 7 Your rights: Information about your personal data we store / Deletion

We only store your personal details with us inasmuch as this is permitted by law. You have a right to ask us to erase or ‘restrict’ your personal data in some circumstances. Where we have asked for your consent to process your personal data you may withdraw your consent at any time. If you withdraw consent, this will not affect the lawfulness of any processing which we have already carried out. Where we process personal data because the processing is in our, or a third party’s, legitimate interests, then you may object to this processing.
You also have a right to complain to a supervisory authority for data protection. This may either be the supervisory authority in the place of your habitual residence, your place of work, or the place where you consider that there has been a breach of data protection law. The relevant supervisory authorities may be found here: [http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm]. These rights may be limited – for example, where we are required by law to process your personal data. Where we must process personal data in order to comply with law or in order to perform or enter into a contract with you, we may not be able to execute the contract unless the personal data are provided.
At your request, we will be happy to inform you of which of your personal data is stored in our system. If incorrect data has been stored despite our efforts to ensure that it is correct and up to date, we will rectify the data immediately at your request. You may also ask us to transfer some of your personal data to other organisations, in structured and machine readable form.
Subject to the provisions above, you have the opportunity at any time to review, modify or delete the personal data available to us by sending an email to unsubscribe@mainfirst-invest.com.

§ 8 Transfers of personal data

We may transfer personal data to countries outside the European Economic Area (the “EEA”) which may not be deemed by the EU to have the same level of protection as EU data protection law. We ensure that such transfers are made in accordance with the conditions in the Data Protection Law (such as they are protected by standard contract clauses, or ensures that the recipient of the personal data participates in the EU-US Privacy Shield or uses Binding Corporate Rules).
You may obtain a copy of these safeguards by contacting

MainFirst Affiliated Fund Managers S.A.
16, Rue Gabriel Lippmann
L-5365 Munsbach

§ 9 Deletion

We keep your personal data for the purposes outlined above. Unless we are obliged to hold it for a shorter or longer period under applicable law, we may keep your personal data for up to 10 years in order to maintain records in accordance with laws and regulations which apply to us and to respond to any regulatory requests or questions.

To the extent we are not permitted to delete your data for legal, regulatory or technical reasons we may keep your data for longer than 10 years. In such circumstances, we will ensure your data and privacy is protected.

As per 18th May 2018