This Privacy Policy is intended to inform the individual (hereinafter referred to as “Data Subject”) about the collection, processing, and protection of personal data (hereinafter “Personal Data”) provided to or collected by the distributor of the Asgard-Steno Global Macro fund, Steno Global Macro Invest ApS (hereinafter “Data Controller”). The Data Controller is based at Nyropsgade 14, st., 1602 Copenhagen, Denmark, and can be contacted via email at info@stenoglobalmacro.com. This policy applies to both the newsletter service and the user access service offered through the website www.stenoglobalmacro.com (hereinafter “Website”).
Any updates or modifications to this Privacy Policy will become effective immediately upon being posted on the Website. If the Data Subject does not accept these changes, they may unsubscribe from the newsletter, request the deletion of their Personal Data, or stop accessing the investor portal.
Categories of Personal Data processed
The Data Controller processes the following types of Personal Data:
- Newsletter Subscribers: For those subscribing to the newsletter, the only personal data collected is the email address, used solely for sending newsletters.
- Investor Users: For users who register and access the “For Investors” section of the Website, the following additional personal data may be collected and processed:
- Name
- Email Address
- Username
- Password
- Login Data (e.g., IP address, login times)
The Data Controller does not process sensitive data unless explicitly provided by the Data Subject during additional communication.
Cookies and similar technologies
The Website may use cookies and similar technologies, such as tracking pixels and web beacons, to collect information about how users interact with the Website. These technologies may track user behavior on the site, such as pages visited or links clicked, to enhance the website experience. For more information on the use of cookies, please refer to our Cookie Policy, available on the Website.
To manage the cookies and similar technologies used (including tracking pixels and web beacons) and related consents, we use the consent tool Real Cookie Banner. Details on how Real Cookie Banner works can be found at https://devowl.io/rcb/data-processing/.
The legal basis for the processing of personal data in this context are:
- Art. 6 (1) lit. c GDPR: To fulfill our legal obligations.
- Art. 6 (1) lit. f GDPR: For our legitimate interest in managing the cookies and similar technologies used and the related consents.
The provision of personal data for this purpose is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide this personal data. However, if you do not provide the personal data, we will not be able to manage your consents.
Legal basis and purpose of data processing
The Data Controller processes Personal Data on the following legal bases:
- Newsletter Subscription: The email address is processed solely for the purpose of delivering the newsletter and providing updates on the performance of our funds. No marketing or promotional content is included in these communications.
- User Accounts for Investors: Personal Data provided by users registering for the “For Investors” section of the Website is processed for the purpose of:
- Creating and managing user accounts.
- Granting access to exclusive content, performance reports, and data related to the fund.
- Ensuring secure login and preventing unauthorized access.
- Monitoring and optimizing the user experience on the investor portal.
Personal Data may also be processed for technical and security purposes, such as identifying and resolving technical issues, managing infrastructure, and ensuring the security of the Data Controller’s assets.
- Consent: By subscribing to the newsletter or creating an account on the “For Investors” section of the Website, the Data Subject consents to the collection and processing of their Personal Data for the specified purposes.
Personal Data will not be used for marketing purposes or shared with third parties for promotional activities without explicit consent.
Data processing methods and receivers of Personal Data
Personal Data is processed using appropriate technical and organizational security measures to ensure confidentiality, integrity, and protection from unauthorized access or disclosure.
Personal Data may be accessed and processed by:
- Authorized Personnel: Employees or contractors of the Data Controller who are specifically authorized to manage the newsletter or investor portal and have signed confidentiality agreements.
- Service Providers: Third-party service providers (e.g., email platform providers, hosting providers, IT support) who assist in delivering the newsletter or maintaining the investor portal. These providers process data on behalf of the Data Controller and are bound by confidentiality and data protection agreements.
Personal Data will not be shared with or sold to third parties for marketing purposes.
Place of Data Processing
All Personal Data is processed within the European Economic Area (EEA). Data will not be transferred outside the EEA unless necessary for the performance of the service, in which case appropriate safeguards will be in place as required by applicable data protection laws.
Personal Data storage period
Personal Data is retained for as long as necessary to fulfill the purpose for which it was collected. Specifically:
- Newsletter Subscribers: Personal Data will be stored as long as the Data Subject remains subscribed to the newsletter. Upon unsubscribing, the Data Subject’s Personal Data will be deleted immediately.
- Investor Users: Personal Data will be stored for the duration of the user’s account activity. If the user requests account deletion or ceases to use the account, Personal Data will be deleted unless legally required to retain it for compliance with legal obligations (e.g., tax or regulatory requirements).
If there is a legal dispute, Personal Data may be retained for the duration of the dispute and until the expiration of any legal appeal periods.
Rights of the Data Subject
The Data Subject has the following rights concerning their Personal Data:
Right to Access: The Data Subject has the right to request access to their Personal Data held by the Data Controller.
Right to Rectification: The Data Subject may request the correction of any inaccurate or incomplete Personal Data.
Right to Erasure: The Data Subject has the right to request the deletion of their Personal Data if it is no longer necessary for the purpose it was collected, or if the Data Subject withdraws consent.
Right to Restrict Processing: The Data Subject may request that processing of their Personal Data be restricted in certain circumstances, such as when contesting the accuracy of the data.
Right to Object: The Data Subject has the right to object to the processing of their Personal Data for specific reasons related to their particular situation.
Right to Withdraw Consent: The Data Subject may withdraw consent for the processing of their Personal Data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Data Portability: The Data Subject has the right to request the transfer of their Personal Data to another data controller in a structured, commonly used, and machine-readable format.
To exercise these rights, the Data Subject can send a request to info@stenoglobalmacro.com. The Data Controller will respond to such requests within 30 days.
Rights of the Data Subject
The Data Controller takes appropriate security measures to protect Personal Data from unauthorized access, disclosure, alteration, or destruction. These measures include both technical and organizational safeguards, such as encrypted data storage, secure access controls, and regular security audits.
However, no online transmission or storage system can guarantee complete security. While we strive to protect your Personal Data, we cannot ensure or warrant its absolute security.
Changes to the Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in data processing practices or legal requirements. Any changes to the policy will be posted on the Website, and significant changes may be communicated to the Data Subject via email. The Data Subject is encouraged to review the Privacy Policy regularly.
If the Data Subject does not agree with any updates to the Privacy Policy, they should unsubscribe from the newsletter, request account deletion, or stop accessing the investor portal and request the deletion of their Personal Data.
Contact Information
For any questions, concerns, or requests related to this Privacy Policy, please contact the fund distributor at:
Steno Global Macro Invest ApS
Nyropsgade 14, st.
1602 Copenhagen, Denmark
Email: info@stenoglobalmacro.com