LYNX Asset Managers, SGOIC, S.A., legal person no. 507929934, with registered office at Av. Duque D’Ávila, 185, 4º D 1050-082, in Lisbon, guarantees the protection and confidentiality of your personal data, in the scope of company’s activities, therefore ensuring that your data are processed according to the General Data Protection Regulation (EU) 1016/679) and applicable national legislation, under its Privacy Policy.

This Policy aims to set forth and guarantee that LYNX complies with the rules that apply to the processing of your Personal Data and provide you with information about your rights as a Data Subject.

This Privacy Policy applies solely to Personal Data collected and processed by LYNX.

Contact Details of the Data Controller

LYNX Asset Managers, SGOIC, S.A.

Rua Laura Alves, nº12, 4th floor, 1050-138 Lisbon

Telephone: (+351) 211 534 090

E-mail address: info@lynxassetmanagers.com

Contact Details of the Data Protection Officer

LYNX Asset Managers, SGOIC, S.A.

Rua Laura Alves, nº12, 4th floor, 1050-138 Lisbon

Telephone: (+351) 211 534 090

E-mail address: protecaodedados@lynxassetmanagers.com

Which Data are collected by LYNX?

In general, Personal Data which are collected and processed by LYNX are:  full name, picture, place of birth, nationality, date of birth, identification document number and validity, marital status, taxpayer identification number, address, e-mail and telephone/mobile.  Additional data can be requested, such as: academic qualifications, professional status, name of employer, financial information, investor profile, money laundering and terrorist financing risk.

Which channels are used to collect Personal Data?

Personal Data are collected directly with the data subjects themselves via e-mail, telephone/mobile and/or contract between both parties and indirectly via partners or third parties.

Use and Purpose of Personal Data collected

The Personal Data collected are processed strictly in compliance with the rules and principles or the General Data Protection Regulation (and legislation that applies to the sector). Personal Data will never be processed unlawfully and illegitimately.

In this scope, personal data processed by LYNX can be collected based on the need to execute a contract to which the data subject is a party or with the goal of complying with pre-contractual diligences requested by the data subject. Complying with a legal obligation to which the data controller is subject and processing Personal Data for purposes of pursuing the legitimate interests of LYNX or any third parties are valid processing grounds, as well as any other purpose for which the Data Subject has given their consent.

How long will Personal Data be retained for?

LYNX keeps Personal Data for as long as they are needed in the scope of the purpose for which they were collected.

For the purposes described herein, Personal Data will be kept by the maximum period permitted by law with effect from the date of collection.

Once this maximum retention period has elapsed, Personal Data will be destroyed in a safe manner, provided there is no higher interest that prevents this from happening.

LYNX keeps your personal data for the period required to comply with contractual and legal obligations. Personal data held by LYNX must be kept for time needed to guarantee:

– compliance with any obligation required by the law or any other regulations, namely in the scope of the commercial and tax law, banking law, Money Laundering Act and Securities Code.

– the right to keep evidence according to the applicable legal expiration periods.

How does LYNX ensure the adequate protection of Personal Data?

LYNX undertakes to guarantee and ensure the protection of the Personal Data given to the company by having in place the adequate Technical and Organisational Measures to avoid potential intrusions, diffusions, changes, unauthorised processing and access, and unlawful processing.

LYNX further undertakes to ensure that, by default, only data required for each specific processing purpose are processed and that those data are not made available or provided to any third parties in an unlawful manner.

Data Subjects’ Rights:

1. Right to Transparency: LYNX must provide the Data Subject with all information concerning processing, free of charge, in a concise, clear, intelligible and easily accessible way, using a clear, simple language.
   
   LYNX must also provide information about measures taken without any undue delay within one month after the request was received.
   
   If the data subject requests this information via electronic means, it will be provided via electronic means whenever possible, unless the data subject has requested otherwise.
2. Right of Access: Data Subjects have the right to access their Personal Data and get information about the purposes, categories, recipients or categories of recipients to which their personal data were or will be disclosed, the retention period and their origin.
3. Right to Rectification: Data Subjects have the right to get LYNX to rectify their personal data which are inaccurate. Considering the purpose of processing, data subjects have the right to see their incomplete data be completed, including via an additional declaration.
4. Right to Erasure or Right to be Forgotten: Data subjects have the right to ask LYNX to erase of their personal data and the company must comply with this request, without any undue delay, whenever one of the following reasons apply:
   
   – The personal data are no longer needed for the purpose for which they were collected or processed in the first place.
   
   – The data subject has withdrawn the consent that justifies data processing and there is no other legal ground for such processing.
   
   – The data subject opposes to processing of their Personal Data and there is no other prevailing legitimate interests that justify such processing.
   
   – The personal data were processed unlawfully.
   
   – The personal data must be deleted for complying with a legal obligation concerning the EU laws or the laws of a Member State that applies to LYNX.
5. Right to Limitation of Processing: Data Subjects have the right to get LYNX to limit the processing of their data, if they challenge the inaccuracy of their personal data.
6. Right to Notification: LYNX notifies the recipients to which personal data have been transmitted of any rectification or erasure of personal data or limitation of processing.
7. Right to Portability: Data Subjects have the right to receive their personal data, which they have provided to LYNX, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
8. Right to Object: Data Subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them. LYNX will stop processing Personal Data, unless there are urgent and legitimate reasons for such processing that take precedence over the interests, rights and freedoms of the data subject, or for purposes of establishing, exercising or defending a right in a judicial proceeding.
9. Individual Automated Decisions, including Profiling: The Data Subject has the right to not be subject to solely automated decisions, including profiling, which have a legal or similarly significant effect on them.

Changes to the Privacy Policy of LYNX

LYNX reserves the right to change this Privacy Policy at any time. In case of changes to the Privacy Policy, the updated Policy will be made available at the Company’s website and the User/Data Subject will have direct access to this information.

Your privacy is important to us. We are focused on protecting and securing your Personal Data and have implemented the technical and organisational measures required to comply with the Regulation, therefore ensuring that your data are processed in a lawful, fair, transparent way and solely for the authorised purposes. We have adopted all measures we deem fit to ensure the accuracy, integrity and confidentiality of your Personal Data and your rights.

You can exercise the rights described in our Privacy Policy by sending a notification or request to the e-mail: protecaodedados@lynxassetmanagers.com

For any clarification on LYNX’s Privacy Policy and/or any information request, please contact us at: protecaodedados@lynxassetmanagers.com

Reporting violations and copyright issues

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