Privacy policy

I. GENERAL

1. This privacy policy (hereinafter referred to as the Policy) contains main information about the processing of personal data of clients of UAB „Lords LB Asset Management“ (hereinafter referred to as Management Company), visitors to the website of the Management Company lordslb.lt and other natural persons (data subjects).

2. UAB „Lords LB Asset Management“ is a management company licensed by the Bank of Lithuania operating in accordance with the Law on Collective Investment Undertakings of the Republic of Lithuania, the Law on Collective Investment Undertakings Intended for Informed Investors of the Republic of Lithuania, the Law on Management Companies of Collective Investment Undertakings Intended for Professional Investors of the Republic of Lithuania and other applicable legal acts (further information about the licences held by the Management Company is available here: https://www.lb.lt/lt/finansu-rinku-dalyviai/uab-lords-lb-asset-management ).

3. While processing personal data and respecting the privacy of natural persons (data subjects) in its business operations, the Management Company also acts in accordance with the legal acts regulating the protection of personal data, including the General Data Protection Regulation (EU) 2016/679.

4. Please be advised that this Policy may be updated. In all cases the Management Company publishes a new version of the Policy on its website.

II. DATA CONTROLLER AND ITS CONTACT DETAILS

5. The Management Company processes personal data of its clients, website visitors, candidates to vacancies, persons who filed enquiries with the Management Company and other natural persons (data subjects).

6. The controller of these personal data is the Management Company, i.e.:
UAB LORDS LB ASSET MANAGEMENT
Legal entity code: 301849625
Office address: Jogailos Str. 4, Vilnius, Lithuania
Tel: +370 5 261 94 70
E-mail: info@lordslb.lt.

7. Should you have any questions in connection with this Policy or the processing of your personal data, please feel free to contact the Management Company using the contact details given above. Please submit your enquiries in writing (for example, by e-mail: info@lordslb.lt) so that we could properly consider your enquiry and reply to you.

III. PROCESSING OF CLIENTS’ PERSONAL DATA

Personal data processing for the purpose of providing the services of a management company

8. The Management Company processes personal data of its clients (their representatives) for the purpose of providing the services of a management company, performing the agreements concluded with its clients and implementing the requirements established in the legal acts regulating the operations of a management company.

9. When providing the services of a management company, the Management Company can process the following data of its clients, inter alia: the first name, surname, personal identification code, other data from personal identification documents, contact details, residential address, data on citizenship, place of work and current position, educational background, profession, knowledge and experience in the field of investment and/or other data which are necessary for the provision of the respective services of a management company. The Management Company can obtain these data about its client (its representative) directly from its client (its representative) or other financial institutions or other business enterprises (if you have applied to them in connection with the services provided by the Management Company).

10. Clients of the Management Company also have the possibility of logging into their individual accounts on the website of the Management Company, where any information that is relevant to the respective client in connection with the particular service is provided. Clients log into their accounts using the unique login data provided to them. With a view to properly administer this system, the Management Company also processes additional personal data of its clients, inter alia: client user IDs, login passwords, time of the client’s login to his/her individual account, data provided in the client’s applications or agreements, data on transactions carried out by the client as well as other data. The Management Company processes these personal data under the agreements concluded with clients.

11. By providing services the Management Company protects the personal data of its clients at least for ten years after the adoption of the respective investment decision, the completion of the transaction, the submission of the respective application or execution of the operation, except for cases where the legislation provides for longer time limits for the storage of such data. Information about client requests to acquire or repurchase investment units of a fund managed by the management company is stored at least for five years after the life-cycle of the respective fund.

Personal data processing for the purpose of preventing money laundering and terrorist financing

12. In accordance with the requirements of the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania (hereinafter referred to as the Law), before commencing the official relationship, the Management Company must establish the identity of its clients, their representatives and beneficiaries. In the event that the requirements established in the Law are not fulfilled properly, the person may not become a client of the Management Company. Therefore, the Management Company also processes personal data of its clients, their representatives and/or beneficiaries for the purpose of preventing money laundering and terrorist financing.

13. The data subject themselves can provide the personal data required by law to the data controller the Management Company. Furthermore, in the cases, under the procedure and on the grounds provided for by the Law, the Management Company can establish the identity of its client, representative or beneficiary without their direct participation (for example, by receiving necessary information from other financial institutions and authorised subjects). By properly implementing the requirements for the prevention of money laundering and terrorist financing, the Management Company can obtain additional personal data on clients, their representatives and beneficiaries from other third parties (for example, client data can be verified in the databases on wanted persons and in international databases which accumulate and store information about the persons involved in politics, etc.).

14. The Management Company stores personal data of its clients, their representatives and beneficiaries for the time limits provided for by the Law, i.e. for eight years after the termination of the transactions or official relationship with the client (unless other legal acts provide for a longer time limit for the storage of data). In certain cases established by the Law, some personal data are stored for a shorter time limit (for example, the correspondence of the official relationship with the client is stored for five years after the termination of the transactions or official relationship with the client).

Personal data processing for the purpose of sending newsletters

15. The Management Company can process the personal data of the client and/or its representative for the purpose of sending newsletters (direct marketing). The Management Company provides information about its business operations, newly established funds and other news related to the services provided by the management company in newsletters sent by e-mail to its clients.

16. For the aforementioned purpose, the Management Company processes the following personal data of its client (its representative): the first name, surname and e-mail address. Personal data are processed on the basis of the lawful interest of the Management Company.

17. Future and current clients of the Management Company have the right to disagree with or reject such processing of their personal data for the purpose of sending newsletters at any time (i.e. both in advance and at any time later). Such objection can be expressed in writing by contacting the Management Company in writing (for example, by e-mail: info@lordslb.lt), or by clicking the respective link in the sent newsletter.

18. The time limit for the storage of personal data of the Management Company’s clients (or their representative) processed for the purpose of sending newsletters is two years after the termination of the official client relationship unless the client has expressed an objection to receiving newsletters before the expiration of this time limit. Upon the expiration of the aforesaid time limit, or upon the receipt of the client’s objection, the Management Company will cease the processing of these personal data for the purpose of direct marketing.

IV. PERSONAL DATA PROCESSING UPON RECEIPT OF ENQUIRIES

19. The Management Company processes your personal data when you contact the Management Company by e-mail, make enquiries on the website or social media accounts of the Management Company, or contact the company by any other method.

20. When you send an enquiry to the Management Company, you are required to comply at least with the minimum personal data protection requirements. If it is not necessary to disclose certain personal data for the respective purpose (for an enquiry, complaint or letter), you should not provide these excess data.

21. The Management Company processes personal data received together with your enquiry in order to properly administer enquiries, ensure the quality of provided services and, where necessary, fulfil various legal requirements and defend the lawful interests of the Management Company. The Management Company processes personal data received together with your enquiry on the basis of your consent, i.e. when you apply to the Management Company by your active actions.

22. The time limit for the storage of personal data specified in your enquiry is up to three years, depending on the nature of received personal data and other circumstances. Your personal data can be stored for a longer time limit, if this is necessary for the defence of the rights and lawful interests of the Management Company, appropriate enquiry management, complaint examination or dispute resolution as well as in other cases stipulated by law.

V. PERSONAL DATA PROCESSING FOR THE PURPOSE OF PERSONNEL SELECTION

23. If you provide data about yourself (for example, send your CV or motivation letter) when being a candidate to the vacancy offered by the Management Company, the Management Company processes your personal data for the purpose of personnel selection. The Management Company processes these personal data on the basis of your consent, i.e. when you apply to the Management Company by your active actions.

24. You are kindly requested to comply at least with the minimum personal data protection requirements and not to provide any excess information that is not related to your candidacy.

25. If you are a candidate to a particular vacancy offered by The Management Company processes the personal data provided by you until the end of the respective personnel selection process. Upon the completion of the selection, your personal data will not be further processed unless you express a separate consent to the processing of your personal data for the purpose of personnel selection.

26. In the event that you send your CV or motivation letter or provide other personal data related to your candidacy to the e-mail addresses given on our website when there is no ongoing personnel selection, we have the right to store and use your data for subsequent personnel selections for a period of up to one year. Please be reminded that you can always waive your consent for the processing of your personal data by contacting the Management Company (for example, by e-mail: info@lordslb.lt), in such case we will not process these personal data provided by you for the purpose of subsequent personnel selections.

VI. VISITING OUR WEBSITE

27. If you have visited the website of the Management Company can process the visitor’s IP address and other network data (if you provide them). Such data are collected with the help of cookies and/or similar technological solutions on the basis of consumer consent.

28. The following cookies are used on the website of the Management Company:

29. Cookies are small text files placed on the web browser used and saved on the visitor’s device. Cookies are placed on the visitor’s computer the first time that they visit the website of the Management Company. Cookies are used to ensure a convenient and safe functioning of the website as well as to analyse the habits of website visitors. This enables to constantly improve the functionality of the website and to better adapt it to the needs of visitors.

30. Some types of cookies, namely, essential and analytics cookies, are necessary to ensure the proper functioning of the website. Therefore, if one has disabled these cookies, the website might not function correctly.

31. By changing the settings of your web browser, you can control the use of cookies. Further information about cookies, their functioning, and how to control or remove them is available on the website: http://www.allaboutcookies.org.

VII. RECIPIENTS OF PERSONAL DATA AND OTHER INFORMATION

32. For the purpose of processing your personal data, the Management Company can employ data processors. Such data processors provide various services to the Management Company. They might include companies providing data storage services, companies providing communication services, software design and maintenance companies, companies tracking and analysing online activities, and other service providers. Your personal data can be provided to these data processors employed by the Management Company only if and to the extent that is necessary for the provision of their respective services.

33. By providing the services of a management company, the Management Company can transfer some personal data of its clients (their representatives) to other data recipients, for example, the Bank of Lithuania, companies providing accounting services, persons providing audit services, the depository, etc.

34. By providing the services, the Management Company can transfer some personal data of its clients (their representatives and (or) beneficial owners) to the companies controlled by collective investment undertakings managed by the Management Company (to special purposes vehicles)) if this is reasonably necessary for the purposes specified in this Privacy policy (i.e. opening of bank accounts, etc.).

35. We ensure that the aforementioned processors (special purposes vehicles) of your personal data follow the instructions for the processing of personal data (where applicable in accordance with legislation) and implement appropriate organizational and technical measures to protect such personal data from accidental or unlawful destruction, alteration, disclosure or any other unlawful handling.

36. For the purpose of preventing money laundering and terrorist financing, personal data of the Management Company clients, their representatives and/or beneficiaries may be transferred under the procedure, in the cases and on the grounds provided for by the Law to the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania, other law enforcement organisations and financial institutions operating within the EEA and beyond. In all cases, the Management Company makes reasonable efforts to ensure that, in compliance with the requirements of the Law, the personal data of its clients, representatives and/or beneficiaries are not lost or used illegally.

37. Moreover, we would like to note that the Management Company stores the consents given by you for the processing of personal data for the minimum time limit for the storage of personal data established by the Chief Archivist of Lithuania (for one year after the expiration of the time limit for the storage of personal data for the processing of which consent was given).

VIII. YOUR RIGHTS

38. In respect of your personal data, you have the following rights provided for in the legislation, namely:

38.1. The right to get familiar with one’s personal data and the way it is processed.

You have the right to obtain the confirmation of the Management Company that the Management Company processes your personal data as well as to get familiar with your personal data being processed and other related information.

38.2. The right to rectify incorrect, inaccurate or incomplete data.

If you believe that your information which is processed by the Management Company is inaccurate or incorrect, you have the right to request to change, revise or rectify this information.

38.3. The right to request to delete your personal data.

Under certain circumstances listed in the applicable legislation (where personal data are processed illegally, the grounds for the processing of data have ceased to exist, etc.), you have the right to request that the Management Company would delete your personal data.

38.4. The right to request to restrict the processing of your personal data.

Under certain circumstances listed in the applicable legislation (where personal data are processed illegally, you have contested the accuracy of data, etc.), you have the right to request that the Management Company would restrict the processing of your personal data.

38.5. The right to request to transfer your personal data to another data controller or to provide them directly in any form convenient for you.

You have the right to obtain the data which are processed by the Management Company on the basis of your consent and the processing of which is carried out by using automated tools in a customary and computer-readable format and you have the right to request to transfer them to another data controller.

38.6. The right to disagree with the processing of your personal data if such personal data are processed on the basis of a lawful interest.

If personal data are processed on the basis of a lawful interest, you may disagree with such processing of your personal data, except for the cases stipulated by law (for example, where there are legal reasons for such data processing, etc.).

38.7. The right to cancel the consent given for the processing of personal data at any time (where your personal data are processed on the basis of separate consent).

Upon the cancellation of your consent to process your personal data, the data processing based on your consent will be terminated.

39. Please be advised that these rights of data subjects are implemented provided that all the requirements established in the legislation are fulfilled. You can find more information about your rights as a data subject and the conditions and peculiarities of implementation thereof in the column Your rights on the website of the State Data Protection Inspectorate at ada.lt.

40. With a view to exercise your rights, or if you have any questions related to the protection of your personal data, please contact the Management Company using the contact details provided above in this Policy. In order to properly examine your enquiry and provide a detailed reply, please submit your enquiries in writing (by e-mail: info@lordslb.lt).

41. If you believe that your rights related to the protection of personal data are violated, you have the right to contact the State Data Protection Inspectorate and lodge a complaint. However, in all cases we would recommend that you should contact the Management Company first in order to find an appropriate and effective solution to the problem.