Effective 25 May, the new regulations concerning personal data protection come into effect in Poland. Because we, at ESALIENS, care about your privacy, we encourage you to review the information we have prepared for you. Keep reading to find out how we process personal data of our clients. This notice is addressed in particular to our existing clients because its scope is broader than the one required under personal data collection laws before 25 May 2018.
WHAT IS GDPR?
GDPR – Article 14 of Regulation (EU) 679/2016 of the European Parliament and of the Council 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/ECWHAT ARE PERSONAL DATA?
Personal data include but are not limited to your identification data (such as your first name and last name or your National Identification Number PESEL), your contact details (such as your residence address and your e-mail address, or your phone number) or data required to transfer funds following the redemption of units.
WHY DO WE COLLECT YOUR PERSONAL DATA?
• To run our business involving the management of mutual funds.
• To be able to enter into or perform agreements on funds participation.
• To respond to your inquiries.
• To be able to send you your subscription of our newsletter or valuations of the ESALIENS funds.
Therefore, we process only data that are necessary; if you decide to give us your personal data, we will notify you of the specific purpose for which we collect them.
WHAT ARE THE LEGAL GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA?
• We process your personal data to perform the agreement on your participation in the ESALIENS fund that we have with you or to take actions, at your request, prior to entering into that agreement.
• If you are an ESALIENS fund participant, we may, for example, send you information regarding the services provided by ESALIENS and the funds it manages.
• A number of legal duties is related, for example, to money laundering prevention, FATCA or CRS.
• If you are not an ESALIENS fund participant, you may give your consent to the processing of your personal data for a specific purpose, e.g. for marketing the services provided by ESALIENS and the funds it manages.
WHO IS THE PERSONAL DATA CONTROLLER?
The data controller is an entity that decides on the purpose and the manner of data processing. Because our business operations focus on the management of mutual funds, the data controller at ESALIENS is the ESALIENS fund the units of which you acquire. Each fund is represented by ESALIENS TFI SA with its registered office in Warsaw (00-034) at ul. Warecka 11A (this is also the registered address of each fund). If you give us your data, we always let you know who your data controller is so that you know who to turn to in order to assert your rights.
WHO IS THE DPO?
DPO is the Data Protection Officer. You may write the DPO at iod@esaliens.pl in any matter relating to the processing of your personal data.
WHO GETS TO SEE YOUR DATA?
In order to run our business operations, we employ certain entities that perform various services for us at our order, notably:
• they maintain the register of the ESALIENS fund unit holders,
• they distribute the units,
• they perform duties involving the safekeeping of assets and maintaining a register of the fund assets,
• they provide IT services, mail services, and archiving services. Your personal data will not be used by third parties to send you, for example, marketing content not related to ESALIENS funds or other services provided by ESALIENS.