Privacy policy & GDPR

Introduction

CNI Advisory AB 559154-1189 and its affiliates “the data controller”, may collect and process your personal data when you interact with us. For example, in business-related purposes and for administrating and maintaining agreements and business relations with CNI’s customers, suppliers and business partners; visits on the CNI website; invitations to events; or if you apply for a position at CNI.

CNI recognizes the importance of data protection and its ambition is to always maintain appropriate protection of personal data and to comply with applicable data protection laws and regulations. This privacy policy informs you of how your personal data is processed by CNI.

Personal data collected by CNI

CNI collects data which we receive via email, telephone or other communication channels, such information might contain personal data (e.g. name, title, address, telephone number and email address, etc.), identification details (e.g. date of birth, personal identification number, passport details, etc.) and other information (e.g. tax information, information about the organization you work for, information from your application, etc.). CNI may also collect data about individuals which are connected to you (e.g. directors, trustees, representatives, beneficiaries, shareholders, investors, etc).

Processing of your personal data by CNI

CNI processes data to provide performance information; maintain and keep contact with investors and business relationships and send invitations to meetings and events; allow administration and maintenance of records; to onboard new clients; to scan business opportunities; to perform contractual obligations and comply with legal obligations; to assess suitability of a job applicant.

CNI does not disclose personal data outside CNI.

How CNI stores your personal data

All personal data collected by CNI is held within our secure online database, it may also be held and stored in documents, emails, and other records within our secure network. We also use a third-party system, to send our email communications and your name and email address is recorded within that database. Additionally, the CNI website consists of a secure environment, for members, for this purpose personal identity numbers are stored.

Disclosures of your personal data

We will not disclose personal information we hold about you to any third party except to other members of our group, to the board of directors of the funds, to third parties who are providing services to us and/or the funds, including IT or other third party service providers, financial institutions, processors of the Funds (including printers, brokers, analysts, registrars, administrators), telephone service providers, document storage providers, backup and disaster recovery service providers, payroll agents and providers of insurance products.

We may also disclose personal data we hold to third parties:

• in the event that we sell any business or assets, in which case we may disclose personal data we hold about you to the prospective and actual buyer of such business or assets; and/or
• if we are permitted by law to disclose your personal data to that third party or are under a legal obligation to disclose your personal data to that third party.
• We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We do not transfer your personal data outside the European Economic Area (EEA). If a business partner or a service provider is located in a country outside the EU/EEA, your personal data may be transferred to a country that does not have data protection laws equivalent to ours. In those cases, CNI will put in place appropriate safeguards to protect your personal data in connection with the transfer.

Your rights and questions regarding personal data

With limited exceptions, you have the right to request information about what personal data that CNI holds about you and request inaccurate information to be corrected. In some circumstances and in accordance with applicable law, you may have the right to request that all your personal data is erased or that the processing of your personal data is restricted. Furthermore, you may have the right to object to the processing of your personal data and to request that your personal data is transmitted in a machine-readable format to another controller.

If you have any questions regarding the processing of personal data by CNI, you can contact us at cni@cninordic.com. If you have any complaints regarding the processing of your personal data, you can also contact the Swedish Data Protection Authority.

On May 25, 2018, a new legislation called General Data Protection Regulation (“GDPR”, Swe: Dataskyddsförordningen) came into force regarding the protection of personal data. More information can be found on www.datainspektionen.se/dataskyddsreformen.