Privacy Protection
Caspar Asset Management S.A. and Caspar TFI S.A. make every effort to ensure that your personal data is processed in accordance with the regulations contained in:
- Regulation (EU) 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/EC (General Data Protection Regulation, GDPR),
- The Act of 10 May 2018 on personal data protection.
Both companies take appropriate technical and organizational security measures against threats related to the processing of personal data.
What is personal data?
Personal data, according to the GDPR, is information about an identified or identifiable natural person. In the case of using the website, such data are, for example, e-mail address, IP address or your data in a user account or an account in another service offered by the Companies. Personal data can be stored in cookies, which are remembered by internet network servers on your end telecommunication device.
Below you will find basic information on the processing of personal data by Caspar Asset Management S.A. and Caspar TFI S.A.
| Caspar Asset Management S.A. | Caspar TFI S.A. |
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| The personal data administrator of clients or potential clients and other persons whose data are obtained in connection with the execution of brokerage activities including receiving and transmitting orders, portfolio management which may include one or more financial instruments, offering financial instruments and investment advice, is Caspar Asset Management S.A. with its registered office in Poznań, at Półwiejska Street 32, 61-888 Poznań. You can contact us at +48 61 855 16 14. In the case of people using the newsletter or people applying for employment at Caspar Asset Management S.A., the personal data administrator is Caspar Asset Management S.A. with its registered office in Poznań, at Półwiejska Street 32, 61-888 Poznań. You can contact us at +48 61 855 16 14. | The personal data administrator of the investment fund participants and other persons whose data are obtained in connection with participation in the investment fund, is the respective investment fund managed by Caspar TFI S.A. in Poznań, at Półwiejska Street 32, 61-888 Poznań. You can contact us at +48 61 855 44 44. In the case of potential participants of the investment fund and people using the newsletter, contact form or people applying for employment at Caspar TFI S.A., the personal data administrator is Caspar TFI S.A. in Poznań, at Półwiejska Street 32, 61-888 Poznań. You can contact us at +48 61 855 44 44. |
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Caspar Asset Management S.A. has appointed a Data Protection Officer for the purpose of:
The Data Protection Officer at the Company is Joanna Rotter. To contact the Inspector, please send a message to the following e-mail address: iodo@casparam.pl or by post to: Data Protection Officer Caspar Asset Management S.A. ul. Półwiejska 32 61-888 Poznań. |
Caspar Towarzystwo Funduszy Inwestycyjnych S.A. has appointed a Data Protection Officer to:
The Data Protection Officer at the Association is Joanna Rotter. To contact the Inspector, please send a message to the following e-mail address: iodo@caspartfi.pl or by post to: Data Protection Officer Caspar Towarzystwo Funduszy Inwestycyjnych S.A. ul. Półwiejska 31 61-888 Poznań |
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Caspar Asset Management S.A. processes personal data for the purpose of:
I. Providing services: providing portfolio management (asset management) service consisting of managing financial assets of individual and institutional Clients; providing services in accepting and transmitting orders to acquire or dispose of financial instruments; providing services in offering financial instruments; providing investment advisory services; providing services through the CasparLine platform; providing telephone service enabling, among others, current monitoring of portfolio value; sending and receiving information electronically. Legal basis: Processing of the above data is necessary to perform the contract based on art. 6 section 1 lit. b) of the GDPR. Providing data is voluntary, but it is a condition for concluding a contract. Failure to provide this data will prevent its conclusion. II. Fulfillment of legal obligations incumbent on the personal data administrator resulting in particular from: Act on Trading in Financial Instruments of July 29, 2005. Act on Investment Funds and Management of Alternative Investment Funds of May 27, 2004. Act of March 9, 2017, on the exchange of tax information with other countries (CRS), Act of March 1, 2018, on counteracting money laundering and financing of terrorism, Act of October 9, 2015, on the implementation of the Agreement between the Government of the Republic of Poland and the Government of the United States of America on improving the fulfillment of international tax obligations and implementing FATCA legislation. Legal basis: The processing of the above data takes place on the basis of art. 6 section 1 lit. c) of the GDPR – processing of data is necessary to fulfill a legal obligation incumbent on the administrator. III. Direct marketing service IV. Recruiting a new employee Legal basis: The processing of the above personal data takes place on the basis of art. 6 section 1 lit. a) of the GDPR- providing data is voluntary. Consent to the processing of data can be withdrawn at any time. The withdrawal of consent does not affect the legality of the previous data processing. V. Resulting from legitimate interests pursued by the data controller, including profiling, so that the content appearing in our services is tailored to the needs and interests of the service users, pursuit and defense against claims, conducting statistics and analysis. Legal basis: Processing of the above personal data takes place on the basis of art. 6 section 1 lit. f) of the GDPR. |
Caspar Investment Fund Company S.A. processes personal data for the purpose of:
I. Providing services: implementation of participation in investment funds chosen by the participant, provision of services through the Caspar Investment Fund Transaction Platform, provision of a telephone service enabling current monitoring of investments within the Caspar Umbrella FIO, sending and receiving information electronically. Legal basis: Processing of the above data is necessary to perform the contract based on art. 6 section 1 lit. b) of the GDPR. Providing data is voluntary, but it is a condition for concluding a contract. Failure to disclose data will prevent its conclusion. II. Fulfillment of legal obligations incumbent on the personal data administrator resulting in particular from: Act on Investment Funds and Management of Alternative Investment Funds of May 27, 2004. Act of March 9, 2017, on the exchange of tax information with other countries (CRS), Act of March 1, 2018, on counteracting money laundering and financing of terrorism, Act of October 9, 2015, on the implementation of the Agreement between the Government of the Republic of Poland and the Government of the United States of America on improving the fulfillment of international tax obligations and implementing FATCA legislation. Legal basis: The processing of the above data takes place on the basis of art. 6 section 1 lit. c) of the GDPR – processing of data is necessary to fulfill a legal obligation incumbent on the administrator. III. Direct marketing service IV. Recruiting a new employee Legal basis: The processing of the above personal data takes place on the basis of art. 6 section 1 lit. a) of the GDPR - providing data is voluntary. Consent to the processing of data can be withdrawn at any time. The withdrawal of consent does not affect the legality of the previous data processing. V. Resulting from legitimate interests pursued by the data controller, including profiling, so that the content appearing in our services is tailored to the needs and interests of the service users, pursuit and defense against claims, conducting statistics and analysis. Legal basis: Processing of the above personal data takes place on the basis of art. 6 section 1 lit. f) of the GDPR. |
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The recipients of the data may be:
entity providing accounting services, entity providing legal services, entity acting as a Caspar AM agent, trust bank, brokerage houses intermediating in the conclusion of transactions on behalf of the client, investment fund companies whose participation titles or certificates have been acquired by the client, entity providing IT services, auditing firm; postal operator. Caspar Asset Management S.A. will not transfer your personal data to a country outside the European Economic Area. |
The recipients of the data may be:
entity maintaining the fund participant register (including the emission agent), depositary, entity acting as a Caspar TFI distributor, entity providing accounting services, entity providing legal services, entity providing IT services, entity providing the Caspar TFI application verification service, auditing firm, postal operator. Caspar Investment Fund Company S.A. will not transfer your personal data to a country outside the European Economic Area. |
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The Company will store personal data for the time necessary to realize the purpose of the contract and obligations arising from the provision of a given service or use of the offered product, as well as asserting claims and defense against claims and/or for a period of time resulting from specific provisions.
In the case of candidates applying for a position in the Company, the personal data of people who have sent their application will be processed for a period of 3 months after the recruitment period ends. |
The TFI will store personal data for the time necessary to realize the purpose of the contract and obligations arising from participation in a given fund or use of the offered product, as well as asserting claims and defense against claims or for a period of time resulting from specific provisions.
In the case of candidates applying for a position in the TFI, the personal data of people who have sent their application will be processed for a period of 3 months after the recruitment period ends. |
What is profiling?
We speak of data profiling when we use algorithms or mathematical models to assess a client's personal profile. We make every effort to ensure that the assessment is objective and that our processes do not discriminate against clients.
What rights does the person to whom the data relates have?
According to GDPR, you have the following rights in relation to your data and its processing:
| Right of access to data | The person to whom the data relates has the right to obtain information about which data are processed and has the right to receive copies of these data. |
| Right to rectification of data | The person to whom the data relates can request that we immediately rectify incorrect or supplement incomplete data. |
| Right to erasure of data (right to be forgotten) | The person to whom the data relates can request that we erase their data when the data are no longer necessary to achieve the purpose for which we collected them, the data were not processed in accordance with GDPR or other laws. To stop processing personal data, we need to receive a statement from the person to whom the data relates specifying their requests. We will consider it when there will be no legally justified reasons to continue processing despite the objection. If we erase the data of the requesting person, we have the right to keep information about who and what request we did this for. We will consider the request as soon as possible, considering the circumstances and our technical possibilities. Please note that using this right will prevent participation in the investment fund/further provision of services and will require redemption/purchase of participation units/investment certificates by the given fund/ termination of the service provision contract. |
| Right to restriction of processing of personal data | The person to whom the data relates can also request that we restrict the processing of data. This applies to the following situations: when the person whose data are concerned questions the accuracy of personal data. When processing is illegal, and the person to whom the data relates objects to the erasure of personal data, requesting instead to limit their use – this can relate to data that are necessary to fulfill duties arising from legal provisions, recommendations or recommendations of supervisory authorities. When a person has objected to the processing, in such a situation, the administrator will check whether legally justified grounds on the part of the administrator are superior to the grounds of the person objecting. We draw attention to the fact that using this right may prevent participation in the investment fund/further provision of services and will require redemption/purchase of participation units/investment certificates by the given fund/ termination of the service provision contract. |
| Right to data portability | Each person to whom the data relates has the right to receive their personal data in a structured, commonly used format, along with the right to transmit those personal data to another controller. When exercising the right to data portability, the person to whom the data relates has the right to request that the data be transferred by the controller directly to another controller, if it is technically possible. This right cannot adversely affect the rights and freedoms of other people. |
| Right to object to processing | The person to whom the data relates may object to us processing their data if we do so based on our legitimate interest. If there is suspicion that data are processed in violation of the GDPR, the person may lodge a complaint with the supervisory authority for data protection in the manner indicated on the website of the supervisory authority. We note that using this right will prevent participation in the investment fund/further provision of services and will require redemption/purchase of participation units/investment certificates by the given fund/ termination of the service provision contract. |
You also have the right to lodge a complaint with the President of the Office for Personal Data Protection (UODO), if you find irregularities in data processing that violate the provisions of the GDPR. You can contact UODO by mail, sending a letter to: ul. Stawki 2, 00-193 Warsaw, or via the electronic submission box available on the website: https://www.uodo.gov.pl/pl/p/kontakt.