Fondo Technologies GmbH

Grünauer Str. 8

D-12557 Berlin

Amtsgericht Charlottenburg (Berlin) HRB 235561 B

T: +49 30863296196

info@fondo.de

© Fondo Technologies 2023

Disclaimer:

This publication is for the sole benefit and use of the client or the person to whom it has been delivered by a representative of Fondo Technologies GmbH. It is based on specific facts and circumstances and prepared for specific purpose. It is not intended to be, and may not be, relied on by any other person.

Without the prior written consent of Fondo Technologies GmbH it shall not be copied, referred to or disclosed, in whole or in part.

The information and opinions expressed in this publication were produced by Fondo Technologies GmbH as of the date of the presentation and are subject to change. Fondo Technologies GmbH is not obliged to update the publication and it should be noted that significant events may have occurred since the date of the publication. Although the information has been obtained from and is based upon sources that Fondo Technologies GmbH believes to be reliable, no representation is made that the information is accurate or complete. Any reference to past performance is not necessarily indicative of future results.

This publication does not constitute an offer or solicitation to any person in any jurisdiction and is not intended a recommendation for an investment or as a sufficient basis for an investment decision and Fondo Technologies GmbH does not accept liability for any loss arising from such use. An investment in a target described in this publication should be made only after careful study of the most recent prospectus and a comprehensive due diligence on the targeted assets. Fondo Technologies GmbH recommends that investors independently assess, with professional advisors, financial, legal, regulatory, credit, tax and accounting consequences before making a final investment decision.

Privacy Policy:

1. Personal data protection

Data protection is a matter of great importance for Fondo Technologies GmbH (FT or the Company) since it guarantees the client confidentiality and security in managing personal data. FT is required to protect the privacy of the client and respect the obligation of confidentiality and for this reason applies a high standard of technical and organisational protection based on its operational structure.

This declaration has the purpose of providing clients with information regarding the data that the Company collects, the reason and the procedure for using them, the legal basis of data processing, their storage and the rights of the client as our obligations in relation to said processing.

2. Definition

The concept of personal data is extended to general and biometric data that uniquely identify a natural person.

3. Collected data

The data we gather and use depend substantially on the services requested or agreed. According to the service, FT processes the following personal data (non-comprehensive list):

• basic data such as name, address, date of birth, KYC documents (including copy of the identity card or passport), legitimation data, tax identification code, telephone number, e-mail address, data on family members, etc;
• fiscal data, such as tax domicile and other tax documents and information;
• financial information, such as records of payments and transactions related to properties of the client (including real estate), financial statements, liabilities, taxes, income, earnings and investments;
• authentication data (e.g.: specimen signature);
• information on the professional and personal context of the client worthy of special attention (e.g. professional activities and experience, information on opinions or religious, ideological or political activities, information relating to health or any criminal convictions or sanctions);
• details on proxies given;
• knowledge and experience in the field of investments;
• client or account number;
• details on the interactions with the client and the products and services they use.

Besides the data provided directly or according to client consent, FT also draws on other public sources, e.g. Internet, World-Check, land registers, company registers, media, printed material or information that is transmitted to us by authorised third parties.

To the extent that the client communicates to FT information regarding natural persons involved in the business relationship (e.g. family members, financial beneficiaries, legal successors, representatives, etc.), FT invites the client to make available a copy of this declaration to these third parties.

4. Purposes of data processing and legal basis

We always process personal data for a specific purpose and to the extent that it is necessary to achieve this purpose. Within the scope of the business relationship with the client, we need to gather and process personal data, which are essential for performing the proxy, as well as to fulfil legal and contractual obligations related to it, to provide the services requested by the client and to execute orders.

The processing of data is therefore necessary:

• to protect the legitimate interests of FT or third parties;
• to fulfil contractual obligations with the client for the services or products requested;
• to comply with a legal obligation;
• to implement the pre-contractual measures within the scope of initiating the contract;
• to carry out an activity of public interest;
• to process special cases of data where it is necessary to establish, exercise or defend a right in a court of law or when the processing
• relates to personal data which are made manifestly public
• in limited circumstances, processing will be carried out upon consent of the client obtained each time (for e.g. when requested by law)
• or with the client’s prior consent in case of special categories of personal data;

Consent to the processing of personal data does not apply for the purposes of the general data protection regulation of 2016/679 (GDPR) of the European Union. For GDPR purposes, in principle the Company refers to the legal basis of fulfilling the legal or contractual obligations, to the implementation of the pre-contractual measures or protection of legitimate interests (according to the Privacy Policy). Please note that this does not affect any consent provided for other reasons, for example in compliance with the federal law on data protection or banking secrecy.

If the personal data collected are necessary to fulfil a legal or regulatory obligation or to enter into a proxy agreement with the client directly, if it is not possible to get hold of such data, FT could find itself unable to sign the mandate.

The personal data are processed in accordance with legal provisions, such as – more specifically – the Federal data protection act, the Federal financial services act and the federal money laundering act.

The purposes of the processing also include the determination of creditworthiness, identity and age, prevention of fraud and money laundering, as well as risk analysis, examination, assessment and management.

5. Persons authorised to access the data

All FT staff members are authorised to handle the personal data to the extent in which this is necessary to fulfil the contractual, legal or supervisory obligations, as well as to protect legitimate interests.

FT can share the personal data with those who operate as representatives of the client or are involved in the management of the business relationship, in particular:

• custodian banks
• brokers or other market counterparties;
• payment recipients, beneficiaries, joint current account holders, intermediaries and corresponding banks;
• asset management services and ancillary activities as also other services related to the trading, execution and processing of financial instruments;
• credit card companies if the client is a credit card holder;
• service providers that operate in the IT sector;
• withholding agents;
• accounting service providers and corporate service providers;
• anyone who takes a risk or has an interest in relation to a transaction (e.g.an insurer)

FT is committed to ensuring that all third party providers of such services respect the data protection standard.

The personal data may be communicated to public regulatory or governmental authorities and institutions or when such authorities request it.

Clients can ask the Company to which recipients or categories of recipients their data have been transmitted.

6. Duration of data storage

In principle, FT stores the personal data as long as they are necessary for the purposes for which they were collected. In asset management or financial advisory proxies, for the whole duration of the contractual relationship plus another ten years after the termination, that which corresponds to the statute of limitations period for legal actions related to contractual or non-contractual claims to be enforced against the Company. Ongoing judicial or supervisory proceedings may lengthen the storage period.

FT also stores personal data in compliance with legal requirements. On expiry of the respective periods, such data are deleted or destroyed.

7. Rights of the client

With reference to their personal data, the client has the following rights in the area of data protection:

• right to receive information on which personal data are processed and to what extent;
• right to rectify, cancel and restrict processing. The client has the right to claim that personal data that are incorrect or incomplete related to them are immediately corrected. Furthermore, the data must be deleted if they are no longer necessary for the purposes for which they were collected and processed, if the client has revoked their consent or if they are processed illegitimately. The client also has the right to claim a restriction of data processing;
• right to withdraw: the client has the right to withdraw at any time their consent to the processing of data that require their consent. The withdrawal does not affect the validity of the processed data and has effect only for the future. Any processing activity carried out before the withdrawal will not be affected;
• right to data portability: in case of processing data that need their consent, the client has the right to request the personal data made available to FT or to obtain that these data are made available to another data supervisor;
• right of appeal: in case of dissatisfaction related to data processing by FT, the client has the right to appeal to the competent supervisory authority on the matter of data protection;
• right to object: the client has the right to object at any time to the processing of their personal data by communicating their query to the Company.
• In case of questions, doubts or comments on data protection, the client can contact the FT data controller at the following address: Fondo Technolgies GmbH, Grünauer Str. 8, D-12557 Berlin, Germany, privacy@fondo.de.

8. Data security

Technical and organisational measures have been adopted to ensure the security of the information collected and processed from illicit access, loss, improper use, modification, falsification and destruction. However, since it is not possible to guarantee total security of data for communications via e-mail, instant messaging and similar communication means, it is advisable to send particularly confidential information using secure alternative means (e.g. registered mail).

9. Modification of personal data

FT undertakes to maintain the data of its client correct and up to date. We invite clients to inform us as soon as possible in the event that data should change. In case of significant changes, FT will inform the client appropriately.

FT reserves the right to amend this privacy policy from time to time. The text of the current version is always available on fondo.de.