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Policy statement

Your privacy is important to SKAGEN. To better protect your privacy we have issued this policy which explains our practice and the choices you can make about the way your information is collected and used.

Definitions

Personal data

Personal data is any piece of information that may be either directly or indirectly associated with an individual, such as name, address, telephone number, email address and national identification number etc.

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Personal data

Handling of personal data

SKAGEN AS is the Data controller, meaning responsible for the manner in which SKAGEN handles your personal data. SKAGEN's Operations Director is responsible for the day-to-day processing of personal data.

The purpose of personal data processing

The main purpose of SKAGEN's processing of personal data is to fulfil client agreements and to provide clients with the best possible service, follow-up and communication. Moreover, the processing is necessary in order to comply with requirements imposed by laws or agreements with authorities, securities registries and other enterprises (data processors) that process personal data on behalf of SKAGEN.

Personal data forms the basis for SKAGENs market and client analysis, business- and processes development as well as statistics purposes.

Which personal data is processed by SKAGEN?

SKAGEN records personal data for which the company has a legal and justifiable requirement, for example:

  • Client's name, birth registration number (date of birth), contact information and bank account information
  • Correspondence with the client including telephone conversations for documentation and quality control purposes. Recordings will be catalogued and stored on a secure storage medium subject to restricted access and deleted after three years.
  • Information regarding any legal guardians, beneficiaries and other persons with rights of disposal of accounts, or ID holders for other clients.
  • Other personal data that SKAGEN is requested by individuals to process, for example request to send information to prospective clients.

How is personal data processed?

SKAGEN process personal data by collecting, storing and systematising information.

SKAGEN has established a proprietary address registry, in which clients may opt out of receiving marketing communication. However, clients cannot not refuse to receive information that SKAGEN is legally bound to provide.

Disclosure of personal data – Use of partners

If legislation permits SKAGEN may disclose personal data to external partners to be used within the purposes stated for processing. External partners may be financial institutions, the securities register, addressing and distribution entities as well as other SKAGEN subcontractors. The external partners may not use the personal data for own purposes and may not transfer the personal data to other entities.

Marketing

Personal data may be used for the marketing of SKAGEN's products and services, provided that the client has not opted out of receiving this type of communication.

Access – Correction – Deletion

A client may request information about SKAGEN's processing of personal data related to the client by sending a written and signed communication to SKAGEN. The client may ask for a printout of recorded information, how the information is processed, and security measures implemented for processing, on condition that providing this type of information does not impede security or legal obligations.

A client may further demand that inadequate/incorrect personal data be corrected and unnecessary information deleted.

Personal data is deleted when storing is no longer necessary to fulfil the purpose of the processing or as a consequence of legislation.

The client's consent to the processing of personal data by SKAGEN is voluntary and may be withdrawn at any time. If a client withdraws consent and demands that information be deleted, SKAGEN may, however, no longer be able to fulfil its obligations to the client, and the client relationship may as a result be terminated.

Personal data ombudsman

SKAGEN has appointed a personal data ombudsman who shall ensure that information is processed in accordance with the applicable law. The personal data ombudsman can be contacted at:

personaldataombudsman@skagenfunds.com

Further information about personal data and data protection on the Data Inspectorate website.

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Historical returns are no guarantee for future returns. Future returns will depend, inter alia, on market developments, the fund manager's skill, the fund's risk profile and management fees. The return may become negative as a result of negative price developments.