Legal information

Auditors and control functions 

 

The Nordic Equities organization includes the following control functions. 

 

Risk management 

Compliance 

Internal audit 

 

External audit 

External auditor is KPMG with Mattias Lötborn, Authorized Public Accountant, as mainly responsible. 

 

Responsible for the above control functions are Revac Redovisningsbyrå AB, Rune Evertsson (risk management), Harvest Advokatbyrå AB, Björn Wendleby (compliance), and Mikaela Grundberg KPMG (internal audit). 

 

Custodian 

SEB serve as custodians for the funds, managed by Nordic Equities Kapitalförvaltning AB.

.

Nordic Equities Kapitalförvaltning cares about your privacy and always strives for a high level of data protection. This privacy policy explains how we collect and use your personal information in our activities under the rules set out in the EU’s new data protection regulation (EU 2016/679) [Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC] (“GDPR”) It also describes your rights and how you can exercise them.

Nordic Equities Kapitalförvaltning AB, corporate identity number 556571-9126, address Grev Turegatan 7, 114 46 Stockholm, is the controller for the Company’s processing of personal data.

Terminology and definitions

The following terms are used in these guidelines with the meanings stated below:

Personal data refers to all types of information that directly or indirectly can be attributed to a natural person who is alive. Images and sound recordings processed electronically, for example, may be personal data, even if no names are mentioned. Encrypted data and different types of electronic identifiers, such as IP addresses, are considered to be personal data if they can be linked to natural persons.

Processing of personal data refers to everything that happens to the personal data. Every action taken with personal data represents processing, irrespective of whether it is performed in an automated manner or not. Examples of common forms of processing are collection, recording, organisation, structuring, storage, adaptation, alteration, transmission and erasure.

What data do we collect, and for what purpose?

The Company collects and processes personal data in the areas and functions listed below. We process the following categories of personal data for the purposes stated below and on the legal basis indicated in relation to the processing concerned.

Customer relationship

What is the legal basis for the processing?

At the time when a natural person becomes a customer of ours, we process his or her personal data to meet statutory obligations.

What personal data is processed and who are recipients?

Personal data that is processed consists principally of name, address, personal identity number, copy of ID document, e-mail address, telephone number, account details, financial information such as accounts, ownership, transactions, income, the customer’s financial experience and investment goals, propensity to risk, information on family situation, etc. Those who may come into contact with the personal data are the marketing department, back office, the IT department, the financial department, the risk department, auditors, the depositary and authorities.

For what purposes is the personal data processed?

The personal data is processed for the following purposes: performing a transaction with a customer, managing the customer relationship, providing and administering access to products and services, administering customer registers, carrying out suitability assessment in investment services, and carrying out checks to prevent money laundering and terrorist financing. Personal data may also be processed for the purpose of e-mailing interesting offers and advertising, news and other information about the Company and our services and products.  As stated in 8.4.3, there is always a right to object to processing for direct marketing.

How long will the data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular weeding among personal data and removes data that is no longer needed. In order to fulfil its statutory commitments, the Company needs to retain certain data even after a customer relationship has ended.  For example, data must be retained to fulfil statutory obligations regarding taxation or book-keeping or for defence against legal claims. In these exceptional cases, data is stored for between 5 and 10 years (with regard to book-keeping, taxation and time-bars).

Recruitment

What is the legal basis for the processing?

The Company must process certain personal data to enable it to handle applications submitted by the data subjects, conduct interviews and make decisions in a recruitment procedure. The basis of this processing is a balance of interests. When we store personal data for future recruitments in our candidate database, consent is obtained.

What personal data is processed and who are recipients?

Personal data processed by the Company is name, date of birth, address, information about experience and skills, any photographs, etc.

Those who may come into contact with the data are principally the HR officer, senior managers and engaged recruitment firms. In cases where recruitment firms handle recruitment, a data processing agreement is always drawn up with the external actor.

For what purposes is the personal data processed?

To enable the Company to handle applications, interviews and decision-making in a recruitment procedure, we collect and process personal data. We may also retain the personal data in our candidate database for the purpose of contacting the applicant in future recruitments.

How long will the personal data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular weeding among stored personal data and removes data that is no longer needed. The Company may, however, need to store the personal data after the recruitment procedure has ended, if we deem it necessary to retain it in order to respond to legal claims that might be lodged against the Company. The period of storage in these cases is 2 years.

We may also retain applications from candidates who are interested in future recruitments in our candidate database. The data is retained for a maximum of 2 years in such cases. The candidates are, however, always given the opportunity to oppose such future contacts.

Marketing

What is the legal basis for the processing?

Personal data may also be processed for the purpose of e-mailing interesting offers and advertising, invitations to seminars, news and other information about the Company and our services and products. The basis for this processing is a balance of interests. As stated in 8.4.3, there is always a right to object to processing for direct marketing.

What personal data is processed and who are recipients?

Personal data processed by the Company is the name and e-mail address and, in certain cases, allergies and diets (principally for seminars and training events).

Those who may come into contact with the data are principally the Company’s administrative department and the marketing department.

How long will the personal data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular thinning among stored personal data and removes data that is no longer needed. The Company for the time being stores personal data for marketing purposes.

What is the legal basis for the processing?

Personal data may be processed for other purposes such as responding to enquiries, establishing, exercising and defending legal claims, for example in order to deal with complaints and in connection with a legal dispute, handling, protecting
and developing our systems and services and fulfilling legal obligations.
for example rules of book-keeping.

The basis for this processing is statutory obligation.

What personal data is processed and who are recipients?

Personal data processed by the Company is name, contact details (e.g. address and telephone number), information on previous assignments, log information, information on paid fees, charges and other financial transactions with the data subject.

 

Those who may come into contact with the data are principally the Company’s administrative department, legal department, financial department and customer complaints officer.

How long will the data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular weeding among stored personal data and removes data that is no longer needed. The Company stores documentation in order to respond to enquiries for 24 months from the time when the enquiry was received. The Company applies appropriate time bars in the event of legal claims, etc. In the management, protection and development of its systems and services, the Company stores the data for 12 months from time of the log event. In fulfilling statutory obligations, for example under the Book-keeping Act, the Company stores data for 7 years from the end of the calendar year in which the relevant financial year concluded.

From what sources do we obtain your personal data?

In addition to the data you yourself supply to us, we may also collect personal data from another source (‘third party’). The data we collect from a third party is as follows:

Address information from public registers to ensure that we have the correct address details for you,

Data on creditworthiness from credit rating agencies, banks or reference agencies.

Who may we share your personal data with?

Processors

In cases where it is necessary to enable us to offer our services, we share your personal data with businesses that act as ‘processors’ for us. A processor is an enterprise that processes the information on our behalf and in accordance with our instructions. We have processors who assist us with:

IT services – enterprises that deal with necessary operation, technical support and maintenance of our IT solutions

Suppliers of systems for administration of registers of unit holders

Back-office services – enterprises that deal with administrative actions, for example mailing reports to customers

When your personal data is shared with processors, this takes place solely for purposes consistent with the purposes for which we have collected the information (for example in order to be able to fulfil our commitments under the agreement with you as our customer). We check all processors to ensure that they can provide sufficient guarantees regarding the security and secrecy of personal data. We have written agreements with all the processors (data processing agreements) under which they guarantee the security of the personal data processed and undertake to fulfil our security requirements and requirements regarding international transmission of personal data.

Other independent controllers

We also share your personal data with certain enterprises which are independent controllers. The fact that the enterprise is an independent controller means that it is not we who control how the information to be submitted to the enterprise is to be processed. Independent controllers we share your personal data with are:

Financial and legal advisers, auditors

Credit institutions and financial institutions, insurance providers and brokers for financial services, third parties taking part carrying out orders, settlement or reporting

Third parties that maintain databases and registers, for example credit registers, population registers, trade registers, securities registers or other registers containing or passing on personal data

Credit reference agencies

Participants and/or parties related to domestic, European and international payment systems

When your personal data is shared with an enterprise that is an independent controller, the privacy policy and personal data handling of that enterprise apply.

Where do we process your personal data?

Your personal data is in general processed only within the EU/EEA [but in certain cases may be transmitted and processed in countries outside the EU/EEA].

Transmission and processing of personal data outside the EU/EEA may take place if there is a legal basis, i.e. a legal obligation or consent from the data subject, and there are appropriate safeguards. Appropriate safeguards are that:

An agreement is in place that covers EU standard agreement clauses or other approved clauses, codes of conduct, certifications, etc. approved in accordance with GDPR.

The country outside the EU/EEA where the recipient is located has a reasonable level of data protection which is established by the European Commission

The recipient is certified according to Privacy Shield (applicable to recipients in the United States).

Further information on transmission of personal data to countries outside the EU/EEA can be obtained on request.

How long do we retain your personal data?

We never retain personal data for longer than is necessary for the particular purpose. For the specific storage periods, see under the purpose concerned.

The Data Subject’s rights

Right of access (‘register extracts’)

The data subject has the right to approach the Company in its capacity as controller to request access to the personal data which the Company processes and also be informed, among other things, about the purposes of the processing and who has received the personal data.

In its capacity as controller, the Company has to provide the data subject with a free copy of the personal data that is processed. If any extra copies are requested, the Company may levy an administration charge.

Right to rectification, erasure or restriction of processing

The data subject has the right, without undue delay, to have his or her personal data rectified or, subject to certain conditions, restricted in processing or erased. If the data subject is of the opinion that the Company processes personal data concerning him or her which is incorrect or incomplete, the data subject may require that this be rectified or supplemented.

If the data subject requests that the data be rectified, erased or restricted in processing, the Company in its capacity as controller has a routine procedure of making reasonable efforts to inform each recipient of the personal data about the data subject’s request.

You may request erasure of personal data we process concerning you if:

The data is no longer necessary for the purposes for which it has been collected or processed.

You object to a balance of interests we have done based on legitimate interest and your reason for objecting outweighs our legitimate interest.

You object to processing for direct marketing purposes.

The personal data is processed in an unlawful manner.

The personal data must be erased to fulfil a legal obligation we are covered by.

Personal data has been collected concerning a child (below the age of 13 years) for whom you have parental responsibility and the collection has taken place in connection with offering of information society services (e.g. social media).

Bear in mind that we may have the right to deny your request if there are legal obligations preventing us from immediately erasing certain personal data. These obligations come form book-keeping and tax legislation, bank and money-laundering legislation, but also from consumer legislation.

It may also happen that the processing is necessary to enable us to establish, exercise or defend legal claims. If we are prevented from acceding to a request, we will instead block the possibility of the personal data being used for purposes other than the purpose preventing the requested erasure.

Right to restriction of processing. You have the right to request that our processing of your personal data be restricted. If you contest the accuracy of the personal data, you may request restricted processing for the period we need to verify the accuracy of the personal data. If we no longer need the personal data for the established purposes, but you need it in order to be able to establish, exercise or defend legal claims you may request limited processing of the data by us. This means that you may request that we not erase your data.

If you have objected to a balance of legitimate interest we have done as a legal basis for a purpose, you may request restricted processing during the period we need to verify whether our legitimate interests outweigh your interests in having the data erased.

If the processing has been restricted according to one of the situations above, we may only, beyond the actual storage, process the data in order to establish, exercise or defend legal claims, to protect the rights of another, or if you have given your consent.

Right to object to a particular type of processing

As a data subject, you have the right at any time to object to processing of your personal data if the legal basis for the processing is public interest or balance of interests under Article 6(1)(e) and (f) GDPR.

In cases where we apply a balance of interests as a legal basis for a purpose, it is possible for you to object to the processing. To enable us to continue to process your personal data after such an objection, we need to be able to demonstrate a compelling legitimate reason for the processing concerned that outweighs your interests, rights or freedoms. We are otherwise allowed to process the data only in order to establish, exercise or defined legal claims.

It is also possible for you to object to your personal data being processed for direct marketing. The objection also includes the analyses of personal data (‘profiling’) carried out for direct marketing purposes. Direct marketing means all types of outreach marketing actions (for example by post, e-mail and text message). Marketing actions where you as customer have chosen to use one of our services or have otherwise reached out to us to find out more about our services are not counted as direct marketing (for example product recommendations or other offers). If you object to direct marketing, we will discontinue the processing of your personal data for the purpose and discontinue all types of direct marketing actions.

Right to data portability

If our right to process your personal data is based either on your consent or on fulfilment of an agreement with you, you have the right to request that the data concerning you and that you have provided to us be transmitted to another controller (‘data portability’). A condition to be met for data portability is that transmission is technically feasible and can be automated.

Right to withdraw consent

If the personal data processing is based on your consent, you have the right to withdraw this consent at any time. Such withdrawal of consent does not affect the lawfulness of the personal data processing before the consent was revoked.

How do we handle personal identity numbers?

We will only process your personal identity number when it is clearly warranted in consideration of the purpose, necessary for reliable identification or if there is some other notable reason. We always minimise the use of your personal identity number as far as possible by using your birth registration number instead, in cases where this is sufficient.

What are cookies, and how do we use them?

Cookies are small text files consisting of alphanumeric characters sent from our web server and saved on your web browser or unit. We use the following cookies on [www.nordeq.se].

Session cookies (a temporary cookie that stops when you close your web browser or unit).

The cookies we use normally improve the services we offer. Some of our services need cookies to work correctly, while others improve the services for you. We use cookies for overall analytical information concerning your use of our services and to save functional settings such as language and other details. We also use cookies to enable us to target relevant marketing to you.

You can control the use of cookies yourself by changing the settings in your web browser or unit.

How is your personal data protected?

We use IT systems to protect secrecy, privacy and access to personal data. We have taken special precautions to protect your personal data against unlawful or unauthorised processing (such as unlawful access, loss, destruction or damage). Only those persons who actually need to process your personal data to be able to satisfy our stated purposes have access to it.

Supervisory authority

The Swedish Data Inspection Board is responsible for monitoring application of the legislation. Anyone who considers an enterprise to be processing personal data incorrectly can submit a complaint to the Swedish Data Inspection Board.

Contact details

Telephone number: +46 (0)8-657 61 00 E-mail address: datainspektionen@datainspektionen.se

Amendments to the Policy

The Company reserves the right to amend and update the policy. In the event of amendments to the policy or if existing information is to be processed in a different way than is stated in the policy, the Company will provide information on this in an appropriate manner.

Contact

If you have any questions concerning the Company’s handling of personal data, contract Mikaela Fredriksson.

Nordic Equities Kapitalförvaltning cares about your privacy and always strives for a high level of data protection. This privacy policy explains how we collect and use your personal information in our activities under the rules set out in the EU’s new data protection regulation (EU 2016/679) [Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC] (“GDPR”) It also describes your rights and how you can exercise them.

Nordic Equities Kapitalförvaltning AB, corporate identity number 556571-9126, address Grev Turegatan 7, 114 46 Stockholm, is the controller for the Company’s processing of personal data.

Terminology and definitions

The following terms are used in these guidelines with the meanings stated below:

Personal data refers to all types of information that directly or indirectly can be attributed to a natural person who is alive. Images and sound recordings processed electronically, for example, may be personal data, even if no names are mentioned. Encrypted data and different types of electronic identifiers, such as IP addresses, are considered to be personal data if they can be linked to natural persons.

Processing of personal data refers to everything that happens to the personal data. Every action taken with personal data represents processing, irrespective of whether it is performed in an automated manner or not. Examples of common forms of processing are collection, recording, organisation, structuring, storage, adaptation, alteration, transmission and erasure.

What data do we collect, and for what purpose?

The Company collects and processes personal data in the areas and functions listed below. We process the following categories of personal data for the purposes stated below and on the legal basis indicated in relation to the processing concerned.

Customer relationship

What is the legal basis for the processing?

At the time when a natural person becomes a customer of ours, we process his or her personal data to meet statutory obligations.

What personal data is processed and who are recipients?

Personal data that is processed consists principally of name, address, personal identity number, copy of ID document, e-mail address, telephone number, account details, financial information such as accounts, ownership, transactions, income, the customer’s financial experience and investment goals, propensity to risk, information on family situation, etc. Those who may come into contact with the personal data are the marketing department, back office, the IT department, the financial department, the risk department, auditors, the depositary and authorities.

For what purposes is the personal data processed?

The personal data is processed for the following purposes: performing a transaction with a customer, managing the customer relationship, providing and administering access to products and services, administering customer registers, carrying out suitability assessment in investment services, and carrying out checks to prevent money laundering and terrorist financing. Personal data may also be processed for the purpose of e-mailing interesting offers and advertising, news and other information about the Company and our services and products.  As stated in 8.4.3, there is always a right to object to processing for direct marketing.

How long will the data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular weeding among personal data and removes data that is no longer needed. In order to fulfil its statutory commitments, the Company needs to retain certain data even after a customer relationship has ended.  For example, data must be retained to fulfil statutory obligations regarding taxation or book-keeping or for defence against legal claims. In these exceptional cases, data is stored for between 5 and 10 years (with regard to book-keeping, taxation and time-bars).

Recruitment

What is the legal basis for the processing?

The Company must process certain personal data to enable it to handle applications submitted by the data subjects, conduct interviews and make decisions in a recruitment procedure. The basis of this processing is a balance of interests. When we store personal data for future recruitments in our candidate database, consent is obtained.

What personal data is processed and who are recipients?

Personal data processed by the Company is name, date of birth, address, information about experience and skills, any photographs, etc.

Those who may come into contact with the data are principally the HR officer, senior managers and engaged recruitment firms. In cases where recruitment firms handle recruitment, a data processing agreement is always drawn up with the external actor.

For what purposes is the personal data processed?

To enable the Company to handle applications, interviews and decision-making in a recruitment procedure, we collect and process personal data. We may also retain the personal data in our candidate database for the purpose of contacting the applicant in future recruitments.

How long will the personal data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular weeding among stored personal data and removes data that is no longer needed. The Company may, however, need to store the personal data after the recruitment procedure has ended, if we deem it necessary to retain it in order to respond to legal claims that might be lodged against the Company. The period of storage in these cases is 2 years.

We may also retain applications from candidates who are interested in future recruitments in our candidate database. The data is retained for a maximum of 2 years in such cases. The candidates are, however, always given the opportunity to oppose such future contacts.

Marketing

What is the legal basis for the processing?

Personal data may also be processed for the purpose of e-mailing interesting offers and advertising, invitations to seminars, news and other information about the Company and our services and products. The basis for this processing is a balance of interests. As stated in 8.4.3, there is always a right to object to processing for direct marketing.

What personal data is processed and who are recipients?

Personal data processed by the Company is the name and e-mail address and, in certain cases, allergies and diets (principally for seminars and training events).

Those who may come into contact with the data are principally the Company’s administrative department and the marketing department.

How long will the personal data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular thinning among stored personal data and removes data that is no longer needed. The Company for the time being stores personal data for marketing purposes.

What is the legal basis for the processing?

Personal data may be processed for other purposes such as responding to enquiries, establishing, exercising and defending legal claims, for example in order to deal with complaints and in connection with a legal dispute, handling, protecting
and developing our systems and services and fulfilling legal obligations.
for example rules of book-keeping.

The basis for this processing is statutory obligation.

What personal data is processed and who are recipients?

Personal data processed by the Company is name, contact details (e.g. address and telephone number), information on previous assignments, log information, information on paid fees, charges and other financial transactions with the data subject.

 

Those who may come into contact with the data are principally the Company’s administrative department, legal department, financial department and customer complaints officer.

How long will the data be stored?

The Company never stores data longer than necessary in consideration of the purposes of the processing. The Company therefore carries out regular weeding among stored personal data and removes data that is no longer needed. The Company stores documentation in order to respond to enquiries for 24 months from the time when the enquiry was received. The Company applies appropriate time bars in the event of legal claims, etc. In the management, protection and development of its systems and services, the Company stores the data for 12 months from time of the log event. In fulfilling statutory obligations, for example under the Book-keeping Act, the Company stores data for 7 years from the end of the calendar year in which the relevant financial year concluded.

From what sources do we obtain your personal data?

In addition to the data you yourself supply to us, we may also collect personal data from another source (‘third party’). The data we collect from a third party is as follows:

Address information from public registers to ensure that we have the correct address details for you,

Data on creditworthiness from credit rating agencies, banks or reference agencies.

Who may we share your personal data with?

Processors

In cases where it is necessary to enable us to offer our services, we share your personal data with businesses that act as ‘processors’ for us. A processor is an enterprise that processes the information on our behalf and in accordance with our instructions. We have processors who assist us with:

IT services – enterprises that deal with necessary operation, technical support and maintenance of our IT solutions

Suppliers of systems for administration of registers of unit holders

Back-office services – enterprises that deal with administrative actions, for example mailing reports to customers

When your personal data is shared with processors, this takes place solely for purposes consistent with the purposes for which we have collected the information (for example in order to be able to fulfil our commitments under the agreement with you as our customer). We check all processors to ensure that they can provide sufficient guarantees regarding the security and secrecy of personal data. We have written agreements with all the processors (data processing agreements) under which they guarantee the security of the personal data processed and undertake to fulfil our security requirements and requirements regarding international transmission of personal data.

Other independent controllers

We also share your personal data with certain enterprises which are independent controllers. The fact that the enterprise is an independent controller means that it is not we who control how the information to be submitted to the enterprise is to be processed. Independent controllers we share your personal data with are:

Financial and legal advisers, auditors

Credit institutions and financial institutions, insurance providers and brokers for financial services, third parties taking part carrying out orders, settlement or reporting

Third parties that maintain databases and registers, for example credit registers, population registers, trade registers, securities registers or other registers containing or passing on personal data

Credit reference agencies

Participants and/or parties related to domestic, European and international payment systems

When your personal data is shared with an enterprise that is an independent controller, the privacy policy and personal data handling of that enterprise apply.

Where do we process your personal data?

Your personal data is in general processed only within the EU/EEA [but in certain cases may be transmitted and processed in countries outside the EU/EEA].

Transmission and processing of personal data outside the EU/EEA may take place if there is a legal basis, i.e. a legal obligation or consent from the data subject, and there are appropriate safeguards. Appropriate safeguards are that:

An agreement is in place that covers EU standard agreement clauses or other approved clauses, codes of conduct, certifications, etc. approved in accordance with GDPR.

The country outside the EU/EEA where the recipient is located has a reasonable level of data protection which is established by the European Commission

The recipient is certified according to Privacy Shield (applicable to recipients in the United States).

Further information on transmission of personal data to countries outside the EU/EEA can be obtained on request.

How long do we retain your personal data?

We never retain personal data for longer than is necessary for the particular purpose. For the specific storage periods, see under the purpose concerned.

The Data Subject’s rights

Right of access (‘register extracts’)

The data subject has the right to approach the Company in its capacity as controller to request access to the personal data which the Company processes and also be informed, among other things, about the purposes of the processing and who has received the personal data.

In its capacity as controller, the Company has to provide the data subject with a free copy of the personal data that is processed. If any extra copies are requested, the Company may levy an administration charge.

Right to rectification, erasure or restriction of processing

The data subject has the right, without undue delay, to have his or her personal data rectified or, subject to certain conditions, restricted in processing or erased. If the data subject is of the opinion that the Company processes personal data concerning him or her which is incorrect or incomplete, the data subject may require that this be rectified or supplemented.

If the data subject requests that the data be rectified, erased or restricted in processing, the Company in its capacity as controller has a routine procedure of making reasonable efforts to inform each recipient of the personal data about the data subject’s request.

You may request erasure of personal data we process concerning you if:

The data is no longer necessary for the purposes for which it has been collected or processed.

You object to a balance of interests we have done based on legitimate interest and your reason for objecting outweighs our legitimate interest.

You object to processing for direct marketing purposes.

The personal data is processed in an unlawful manner.

The personal data must be erased to fulfil a legal obligation we are covered by.

Personal data has been collected concerning a child (below the age of 13 years) for whom you have parental responsibility and the collection has taken place in connection with offering of information society services (e.g. social media).

Bear in mind that we may have the right to deny your request if there are legal obligations preventing us from immediately erasing certain personal data. These obligations come form book-keeping and tax legislation, bank and money-laundering legislation, but also from consumer legislation.

It may also happen that the processing is necessary to enable us to establish, exercise or defend legal claims. If we are prevented from acceding to a request, we will instead block the possibility of the personal data being used for purposes other than the purpose preventing the requested erasure.

Right to restriction of processing. You have the right to request that our processing of your personal data be restricted. If you contest the accuracy of the personal data, you may request restricted processing for the period we need to verify the accuracy of the personal data. If we no longer need the personal data for the established purposes, but you need it in order to be able to establish, exercise or defend legal claims you may request limited processing of the data by us. This means that you may request that we not erase your data.

If you have objected to a balance of legitimate interest we have done as a legal basis for a purpose, you may request restricted processing during the period we need to verify whether our legitimate interests outweigh your interests in having the data erased.

If the processing has been restricted according to one of the situations above, we may only, beyond the actual storage, process the data in order to establish, exercise or defend legal claims, to protect the rights of another, or if you have given your consent.

Right to object to a particular type of processing

As a data subject, you have the right at any time to object to processing of your personal data if the legal basis for the processing is public interest or balance of interests under Article 6(1)(e) and (f) GDPR.

In cases where we apply a balance of interests as a legal basis for a purpose, it is possible for you to object to the processing. To enable us to continue to process your personal data after such an objection, we need to be able to demonstrate a compelling legitimate reason for the processing concerned that outweighs your interests, rights or freedoms. We are otherwise allowed to process the data only in order to establish, exercise or defined legal claims.

It is also possible for you to object to your personal data being processed for direct marketing. The objection also includes the analyses of personal data (‘profiling’) carried out for direct marketing purposes. Direct marketing means all types of outreach marketing actions (for example by post, e-mail and text message). Marketing actions where you as customer have chosen to use one of our services or have otherwise reached out to us to find out more about our services are not counted as direct marketing (for example product recommendations or other offers). If you object to direct marketing, we will discontinue the processing of your personal data for the purpose and discontinue all types of direct marketing actions.

Right to data portability

If our right to process your personal data is based either on your consent or on fulfilment of an agreement with you, you have the right to request that the data concerning you and that you have provided to us be transmitted to another controller (‘data portability’). A condition to be met for data portability is that transmission is technically feasible and can be automated.

Right to withdraw consent

If the personal data processing is based on your consent, you have the right to withdraw this consent at any time. Such withdrawal of consent does not affect the lawfulness of the personal data processing before the consent was revoked.

How do we handle personal identity numbers?

We will only process your personal identity number when it is clearly warranted in consideration of the purpose, necessary for reliable identification or if there is some other notable reason. We always minimise the use of your personal identity number as far as possible by using your birth registration number instead, in cases where this is sufficient.

What are cookies, and how do we use them?

Cookies are small text files consisting of alphanumeric characters sent from our web server and saved on your web browser or unit. We use the following cookies on [www.nordeq.se].

Session cookies (a temporary cookie that stops when you close your web browser or unit).

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How is your personal data protected?

We use IT systems to protect secrecy, privacy and access to personal data. We have taken special precautions to protect your personal data against unlawful or unauthorised processing (such as unlawful access, loss, destruction or damage). Only those persons who actually need to process your personal data to be able to satisfy our stated purposes have access to it.

Supervisory authority

The Swedish Data Inspection Board is responsible for monitoring application of the legislation. Anyone who considers an enterprise to be processing personal data incorrectly can submit a complaint to the Swedish Data Inspection Board.

Contact details

Telephone number: +46 (0)8-657 61 00 E-mail address: datainspektionen@datainspektionen.se

Amendments to the Policy

The Company reserves the right to amend and update the policy. In the event of amendments to the policy or if existing information is to be processed in a different way than is stated in the policy, the Company will provide information on this in an appropriate manner.

Contact

If you have any questions concerning the Company’s handling of personal data, contract Mikaela Fredriksson.

Remuneration policy

 

In order not to encourage excessive risk taking, the fund company has adopted a compensation policy. Remuneration to employees is based on fixed monthly salary, retirement provision and health insurance. There are no agreements on variable remuneration or similar.

 

Chapter 3, section 22 and chapter 9 section 3, of the Financial Supervisory Authority’s regulations on investment fund managers (FFFS 2013: 10) and Chapter 3, section 8a, of the Financial Supervisory Authority’s Securities Funds (FFFS 2013: 9) stipulates that the Company must have a compensation policy.

According to the regulations, the Company must have a remuneration policy that is partly compatible with and promotes a salutary and efficient risk management and counteracts excessive risk taking.

The compensation policy shall be designed and applied in a manner appropriate to the size and internal organization of the enterprise and the nature, scale and complexity of the business. The remuneration policy must also agree with the business strategy, objectives, values, long-term interests of the trustee and the managed alternative investment funds or the investors of the alternative investment funds, as well as a list of measures to be taken to avoid conflicts of interest.

 

The company has identified that an incorrect design of compensation systems and variable payment payments could adversely affect the Company’s liquidity and result in the Company failing to comply with the regulatory framework for capital adequacy and conflicts with shareholders’ interests. Risk takers could potentially take an excessive risk or violate the fund rules and the Company’s internal rules with a view to shortening their own remuneration level in the short term. Furthermore, the assets of the Fund could potentially be valued at an amount higher than the market price in order to increase the Company’s charging.

 

 

Against this background, it is essential for the Company to ensure that its compensation policy and remuneration systems are consistent with and promote a salutary and efficient risk management. A part of this work is to identify and report what measures are to be taken. Compensation models that may occur in the Company must have an appropriate balance between fixed and movable parts. Guaranteed variable compensation may not occur.

 

The fixed part shall represent a sufficiently high proportion of the employee’s total remuneration for it to be possible to put the moving parts to zero. The company shall state in its remuneration policy the extent to which the movable shares can be highest in relation to the fixed parts for all categories of employees who receive variable remuneration.

 

All employees may be entitled to variable remuneration. Variable compensation to employees may in no case be set at a higher amount than the corresponding 24 month salary.

 

Variable remuneration shall be decided by the Board on a proposal from the Chairman of the Board. The variable remuneration is not calculated on the basis of any predetermined formula but is by its nature discretionary. The company is based on the possibility of variable remuneration on, among other things, the following criteria for the respective personnel category.

 

Investment Staff:

  • The company’s result
  • The employee’s contribution to the company’s earnings ability
  • Seniority
  • Customer Care/Investor Satisfaction
  • Management tasks
  • Training programs
  • Compliance with internal / external rules / risk management policy

 

Distribution

  • Customer Care / Investor Satisfaction
  • Strategic goals
  • structural issues
  • New unit owners
  • Compliance with internal / external rules

 

Non-investment staff:

  • Audit Results
  • Strategic goals
  • structural issues
  • Adaptation to new regulations
  • Compliance with internal / external rules, risk management policy
  • Teamwork / motivation
  • Leadership

 

When the Company decides how much of the total remuneration to be variable, the Company shall always ensure that its total remuneration does not limit the Company’s ability to maintain a sufficient capital base or, if necessary, strengthen the capital base. This means that the company, among other things, shall take into account:

– size and cost of the additional capital required to cover the risks affecting the profit for the period,

– the size of and the cost of the liquidity risk, and

– the possibility that expectations of future earnings can not be realized

 

For specially regulated staff, at least 60 percent of the variable compensation shall be postponed for three years before it is paid out or ownership of shares will pass on to the employee. For others, at least 40 percent of the variable compensation is postponed for five years before it is paid out.

 

Variable remuneration that is postponed is paid only or transferred to the employee to the extent that it is justified in view of the Company’s financial situation and justified according to the Company and the employee’s result. The deferred part of the remuneration may also fall completely for the same reasons.

An information about the fund company’s remuneration is published in the Fund’s annual report and on the fund company’s website. Information on the remuneration policy can also be sent in writing free of charge on request. Follow-up of compliance with the remuneration policy is performed annually by the compliance function.

Statement of the remuneration 2018:

 The total amount of remuneration for the fund company 2018 was SEK 5 878 240. The amount was divided into fixed remuneration of SEK 3 993 240 as well as variable remuneration of SEK 1 885 000. 16 employees have been paid fixed or variable remuneration during the year.  Variable remuneration to employees in leading strategic positions was SEK 1 372 000. No variable remuneration was paid to risk takers. No other employee has been paid remuneration that exceeds the total remuneration to anyone in a leading strategic position. Remuneration to employees has been calculated according to the company’s results, the company’s positions as well as the employee’s contribution to the earnings capacity, seniority, customer care, compliance with internal rules etc.

The units of the Nordic Equities’ funds have not been and will not be registered in accordance with any securities legislation in the United States, Canada, Japan, and Australia. The Nordic Equities’ funds are not directed to persons whose participation requires additional information, registration measures or other measures than those required by Swedish law.

 

Foreign laws and regulations may prohibit investors domiciled outside Sweden from investing in the Nordic Equities` funds. It is incumbent on each individual who wishes to invest in the Nordic Equities’ funds to ensure that such an investment complies with relevant laws and other regulations, both in Sweden and abroad. The Fund Manager, Nordic Equities Kapitalförvaltning AB, has no responsibility whatsoever to verify that an investment from abroad has been made in accordance with the laws and regulations of the country in question.

 

There is no guarantee that an investment in the Nordic Equities’ funds will not result in a loss, even at times when financial markets are otherwise performing favorably. Past performance is no guarantee of future return. The value of the capital invested in the Nordic Equities’ funds may increase or decrease and investors in the Nordic Equities’ funds cannot be certain of recovering all their invested capital. The Nordic Equities’ funds value may vary greatly due to the fund’s composition and the portfolio management methods used.

 

The information contained on this website shall not be regarded as a recommendation to buy units in the Nordic Equities’ funds, and it is the responsibility of individuals wishing to acquire units to make their own assessment of an investment in the Nordic Equities’ funds and of the risks associated with such an investment.

 

Any dispute, controversy or claim in relation to the Nordic Equities’ funds shall be settled in accordance with Swedish law by Swedish courts exclusively.

 

This website was prepared solely for presentation purposes and is a brief summary of selective information regarding Nordic Equities Kapitalförvaltning AB and the Nordic Equities’ funds. Thus, this website does not account for all terms, conditions and other information set forth in the fund regulations, the fund information brochure and the reports issued by the Fund Manager. This website has been prepared in Swedish and translated into English only for the convenience of non-Swedish readers. In the event of any discrepancy between this website and the fund regulations, the Swedish Fund Regulations shall prevail.