Last updated: 2020-06-17
It is of great importance for us to ensure that you are comfortable being a co-investor, and we treat the data/information that you provide to us, and the data/information which we collect about you, with strict confidentiality and with respect for your privacy in accordance with applicable law.
Data responsibility
Formue Nord is responsible for handling data in accordance with The Data Protection Act. Data is registered in connection with subscription of investments in affiliated investment funds and in connection with previous and ongoing dialogue about subscription of investments in affiliated investment funds.
Formue Nord A/S
Østre Alle 102, 4th floor
9000 Aalborg
CVR-nr.: 37 08 93 62
Privacy policy
It is of great importance for us to ensue that you are comfortable being a co-investor, and we treat the information that you provide to us, and the information which we collect about you, with strict confidentiality and with respect for your privacy in accordance with applicable law.
1. What data/information does Formue Nord collect and what is it used for?
We record the data you provide when completing the subscription list and the data you provide in dialogue with us, which is necessary for:
If you redeem your investment in one of our affiliate investment funds, data about you will be stored for the following five years. This is to comply with applicable law.
1.1. Data/information in connection with your subscription and/or redemption of investments in affiliated investment funds.
When subscribing investments in our affiliate investment funds, subscription amounts, investment fund, share class, identification number (CVR/CPR), name of company/person subscribing for the shares, address and e-mail, as well as time and place of signature is registered. Upon completion of the subscription, the date of subscription, net asset value, brokerage, number of shares and, if necessary residual amounts, are recorded. In connection with subscription, an identification copy (i.e. passport or drivers license) is uploaded by the investor to PENNEO CLA in order for Formue Nord to comply with the Anti Money Laundering Act etc.. Sensitive material such as these copies are kept confidential and with restricted access.
Following a redemption, equivalent data is recorded, as well as the investor’s registration and account number used for the transfer of redemption amount.
The information registered in connection with subscription and redemption is subsequently used for the preparation of periodic return statements, which are sent to you as an investor, and on an annual basis for reporting to SKAT and Finanstilsynet.
1.2. Other data/information provided through dialogue in connection with your subscription and / or redemption of investment in affiliated investment funds.
Prior to a subscription, Formue Nord will engage in a dialogue with you, to gain an understanding of your total wealth, the origins of your assets and your current as well as expected allocations. This process is allows for us, as a manager, to reflect on an imminent or future subscription. Moreover, it is necessary for us, through dialogue with you, to ensure that you understand and are qualified to invest in the products being considered.
Data/information relevant for these purposes is registered by Formue Nord, in order to ensure compliance with the Anti Money Laundering Act and the AIFM Act.
1.3. Data/information on the use of the website, www.formuenord.dk
Data/information, about which parts of the website are visited, is collected in log files along with the IP address, and the information is used for further development of the website to match the demands and needs of the customers or potential customers who use the website.
The website uses cookies. A cookie is a small text file that is stored in your terminal equipment through your browser. The cookies used by Formue Nord cannot contain viruses and no personal information is stored.
If you do not want to receive cookies, you can block all cookies, delete existing cookies from your hard drive or receive a warning before saving a cookie. Click here for instructions on how to set this up in your browser/smartphone: http://minecookies.org/cookiehandtering. The guide applies for most browsers and smartphones.
You can always use the help function in your browser for more information on cookie settings. You typically do this by pressing “F1” on your PC. Search for “cookies”.
Authorized employees of Formue Nord, have access to the data collected.
Formue Nord uses Albacross and Google Analytics to analyze traffic on www.formuenord.dk. We wish to continuously improve the website and make it more user friendly, and data collected b y google Analytics is a help in this process. In this context, cookies are used to keep statistics on the number of users, time spent on the website, and which sub-pages are visited. In order to collect data for these statistics, Google places cookies in your terminal equipment. The IP address used is passed to Google for Google Analytics measurements. See above for how to avoid these cookies. You can also opt out of Google Analytics metrics in general, see more here:
https://tools.google.com/dlpage/gaoptout.
On selected pages, Formue Nord A/S uses “LinkedIn Insight Tags”, which is a tracking technology on the LinkedIn-platform, delivered by LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2 (Ireland). This technology enables us to show you relevant advertising based on your interests. In addition, we receive anonymous (to the extent this is possible) reports from LinkedIn regarding advertising activity and information about how you interact with our web pages. LinkedIn uses cookies for this purpose. The information gathered through cookies is used to compile the before mentioned anonymous statistics and reports, and to show advertising based on your interests. Further information about data protection on LinkedIn is available at www.linkedin.com/legal/privacy-policy. You can object to the analysis of your page visits by LinkedIn and the subsequent retargeting by clicking on the following link (opt-out): www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
1.4. Data/information on the use of Mailchimp when sending out newsletters etc.
Formue Nord uses mail chimp to send out periodic newsletters and/or relevant return updates. You will receive these distributions if you are either an investor in the affiliated investment funds, or if you are a stakeholder who actively, or through dialogue with Formue Nord, have chosen to receive theses distributions. For each distribution sent, Mailchimp collects information about the recipient’s interaction with the distribution, and this information is used by Formue Nord to target relevant information/material to the recipient according to perceived needs. Mailchimp i.e. gathers statistics on the number of recipients who open the e-mail, number of clicks on the links in the e-mail etc. If you do not want this data to be collected about you as a recipient, you can unsubscribe from the distribution (done using the link at the bottom of the e-mail distribution), and you can always contact us to get your data updated or deleted.
You can read more about Mailchimp here https://mailchimp.com/legal/privacy/
1.5. Data/information on the use of HubSpot in connection to handling client data.
As a co-investor in any of our investment companies under management, or any other interested parties, who through a dialogue with Formue Nord A/S has shown interest in Formue Nord A/S or any of its managed investment companies, any email correspondence and information regarding physical or online meetings will be registered in HubSpot. Other disclosed information/data which is relevant for maintaining the dialogue and co-investor relationship will also be registered. Upon termination of the co-investor relation or upon end of interest in Formue Nord A/S or one of its managed investment companies, any registered information will be deleted once this is deemed no longer relevant. If you do not wish for any previously mentioned information to be registered, you are welcome to contact us for the purpose of updating or deleting your registered information.
You can read more about HubSpot here: https://legal.hubspot.com/privacy-policy
1.6. Data/information on the use of Penneo KYC (CLA) in connection to identification of co-investors.
Penneo KYC (CLA) is used for collecting documentation of a co-investor’s identity, for understanding the purpose of the co-investor relation, and for collecting other information needed to assess the risk (in the context of the Danish Anti-Money-Laundering law) of the co-investor. If you do not wish for your information to be registered, you are welcome to contact us for the purpose of updating or deleting your registered information. Formue Nord A/S is legally obliged to collect and document all co-investor relations.
You can read more about Penneo KYC (CLA) here: https://penneo.com/da/privacy-policy/
2. Who has access to personal data?
Employees in Formue Nord and its affiliate investment funds, who are tasked with serving you as a customer and processing your data/information, have access to the collected personal data. These employees are only allowed to view and use your information to the extent necessary to serve and manage you as a customer or to comply with applicable law.
Formue Nord only discloses data/information collected to third parties, if they are tasked with performing various necessary functions in connection with the investment funds’ activities.
These include:
Legal firm:
HjulmandKaptain is the outside legal firm used by Formue Nord and its affiliated investment funds. HjulmandKaptain assists in the subscription process by receiving payments of subscription amounts, collecting and validating subscription documentation, and implementing and registering subscription of shares with the relevant authorities.
Accountant and auditor:
Beierholm is the auditor for Formue Nord and its affiliated investment funds. Beierholm performs a an ongoing and end of year audit, and provides the annual reports for Formue Nord and its affiliate investment funds. As part of the audit proces, subscriptions and redemptions, containing personal data, are reviewed.
Banking:
Danske Bank is the bank used by Formue Nord and its affiliate investment funds. Data is shared upon request with Danske Bank, if required it to comply with applicable legislation (i.e. the Anti Money Laundering Act).
Mailchimp:
Mailchimp is used as a service for sending out newsletters and periodic return reports as described in 1.4. You can read more about Mailchimp here https://mailchimp.com/legal/privacy/
Hubspot:
Hubspot is utilized as CRM-system for the purpose of administrating and servicing existing and potential co-investors as also described in item 1.5.
Penneo KYC (CLA):
Penneo KYC is used for documenting the identities of co-investors and ensuring compliance with current law, as also described in item 1.6
3. How and how long do we keep information about you?
Personal information must be kept safe and confidential. We store your personal information in IT systems with controlled and limited access.
Information about you as a customer, your subscriptions/redemptions, related registrations are saved as long as necessary to manage as a customer, or to comply with applicable law. This means information about you is saved for 5 years following redemption.
4. Changes and updates
This policy can be changed. In case of significant changes, these will be disclosed by a visible notice on www.formuenord.dk.
5. Your rights
As a customer of Formue Nord, you have the right to see what information is registered about you in accordance with The Data Protection Act. If the information or data processed about you is incorrect or misleading, you may require this data to be corrected, deleted or blocked. At any time, you can object to information about you being registered and handled. You can also recall your consent to the processing of personal data at any time. But please be aware that our registration and handling of data for the most part is required by law, or is a prerequisite for serving you as a customer at Formue Nord.
If you have any questions about what data/information Formue Nord has registered about you and how it is being handled, please contact:
Formue Nord A/S
Østre Alle 102
9000 Aalborg
Via e-mail: info@formuenord.dk
6. Complaints about collection and use of data
Formue Nord is subject to The Data Protection Act’s provisions about processing of personal information. The Data Protection Act is administered by Datatilsynet. If you experience a violation of your privacy as a result of interaction with Formue Nord or its affiliate investment funds, you can notify Datatilsynet to file a complaint.
Datatilsynets can be contacted at:
Datatilsynet
Borgergade 28, 5.
1300 København K
Telefon: 33 19 32 00
Fax: 33 19 32 18
Mail: dt@datatilsynet.dk
www.datatilsynet.dk
