Data policy

Data policy

IMPORTANT INFORMATION ON HOW WE COLLECT, USE AND STORE INFORMATION ABOUT YOU

24.5.2018

At Northern Horizon Capital A/S (and all companies belonging to the same group, hereafter referred to as “Northern Horizon” or we) we care about protection of your information. We follow the requirements of the European Union General Data Protection Regulation (GDPR), and other laws protecting information about you at the Northern Horizon, therefore, we would like to provide you with certain information about data we process in relation to you.

This notice will answer the most important questions about how we collect, use and store information about you. In case you have any other questions or find any part of this notice unclear, our Data Protection Officer is ready to help you as described in Section 11 of this notice. This notice may be supplemented by solution specific privacy statements and additional local documentation.

 1. Which personal data does Northern Horizon collect and process?

Northern Horizon collects personal data of its investors, potential investors, their representatives and ultimate beneficial owners, representatives of business partners, current and previous employees and job applicants, board members, other managers and shareholders, tenants and representatives of the real estate investments in the investment vehicles (“Data Subject”).

Northern Horizon collects, among others, the following personal data:

  • name, contact information and title or function at work;
  • information and notes related to meetings and correspondence;
  • information of investments in investment vehicles managed by Northern Horizon and investment potential;
  • information related to recruiting;
  • information required due the anti-money Laundering, tax reporting or other regulation; and
  • possible other information relevant for the business relationship.

    2. Why we collect information about you

Due to Northern Horizon’s different range of products and activities, different situations require that different data is collected. Therefore, Northern Horizon maintains several Privacy notices which you have been provided. Depending on your relationship with, either one or several Privacy Notices may be applicable.

Investment vehicle operations

Personal data is collected and processed in connection of your investment to Northern Horizon’s investment vehicles, e.g. anti-money laundering checks and sanctions screening, legal due diligence, fund administration, management of the investment vehicle’s unit holder register, reporting and decision making. Processing for this purpose is based primarily on fulfilling of our contractual obligations, also due to legal requirements or legitimate interest.

Communication, press releases and marketing

Personal data is collected and processed in order to contact, maintain, develop and update Northern Horizon’s business relationship and communication with you, marketing new products and services and distributing press releases regarding interesting news related to Northern Horizon. Processing for this purpose is based on a consent given by you or a contract made between you and us. You can always retain your right to withdraw your consent to process your personal data for marketing purposes or distributing press releases.

Development of business operations

Personal data may be collected and processed for development of business operations. Personal data may be processed in order to analyse the business relationship or to enhance the quality of products and services. General visitor information of our website is tracked, and this information may be generalized and used to analyse the use of the website and to further develop the website. Processing for this purpose is based Northern Horizon’s legitimate interest to develop its operations and enhance the quality of the products and services provided to its customers.

 Other contractual obligations

Personal data may be collected and processed in order to execute obligations originating from agreements or to make preparations for such agreements. Processing for this purpose is based on our contractual obligations.

Legal obligations

Personal data may be collected and processed for fulfilling our obligations under mandatory legislation.

Recruitment

Personal data is collected and processed in connection of recruitment process in order to assess job applicants, to make recruitments decisions and to manage employment related matters. Processing for this purpose is based either on fulfilling our contractual obligations or legal requirements.

No other purposes

Northern Horizon does not process the collected personal data for any other purposes without informing you and without receiving your prior consent for that purpose, unless it is necessary in order to comply with contractual or regulatory obligations.

 3. How we collect personal data?

Personal data is mainly collected directly from you or from your employer entity. Personal data may also be collected from publicly available or other sources as official registers and business information systems. The information sources may vary depending on the home country and your citizenship.

In addition, Northern Horizon may collect, process and analyse personal data about visitors on the web page using cookies. The collected personal data is not used to identify individuals.

  4. Automatic decision making or profiling

Please note that no automatic decision making or profiling is used with us.

  5. How do we share information about you

Please note that only people who need to process your personal data for the purposes mentioned in this notification have the access to your personal data.

We may need to share your personal data with the persons performing services for us and our investment vehicles and Northern Horizon group companies it is necessary and as the case might be.

Personal data may also be shared with courts, law enforcement authorities, regulatory and supervisory authorities, attorneys, alternative dispute resolution bodies or other organisations or entities, when it is reasonable and necessary for the purpose of pursuing or exercising a legal claim or for the defence of such or any other claim.

  6.Transfers of data outside the European Economic Area [1]

 We do not transfer your data outside the EU/EEA.

  7. Storage

Your personal data will be stored for as long as necessary under the above-specified purposes. The necessity of retaining personal data for the above-specific purposes, as well as the data’s correctness is reviewed annually. Unnecessary and outdated data will be deleted.

  8. Providing personal data on someone else

We generally conduct business with legal entities. Therefore the person providing personal data to us might be someone else than the Data Subject him or herself, for example his or her employer or other similar legal or natural person. In case you provide personal data on someone else, ensure that you are entitled to provide the personal data to us and we can, without further actions, collect and process the provided personal data as described in this notice. In addition, when providing personal data on someone else, ensure that the Data Subject is informed on how we process personal data and his or her applicable legal rights.

  9. How do we protect your personal data?

Northern Horizon applies both technical and organizational measures to protect your personal data against unlawful access and loss.

  10. Your rights

In order to assist you in implementing your rights please contact our Data Protection Officer as described below. You have the right to know what information we have about you. You are also entitled to request us to correct incorrect information about you and in some cases you may also request us to delete your information or restrict use or deletion of your information. You can also object to collection, use and storage of your certain information at our company. You also have the right to request us to export your data to you or transfer it to other companies.

If you are dissatisfied with how we process your personal data, you are also entitled to submit a complaint to the national Data Protection Authority or another Data Protection Authority within the EU/EEA area:

In Denmark:

The Danish Data Protection Agency (https://www.datatilsynet.dk)

In Finland:

Office of the data protection ombudsman (https://tietosuoja.fi)

In Sweden:

The Swedish Data Protection Authority (https://www.datainspektionen.se)

In Lithuania:

The State Data Protection Inspectorate (https://www.ada.lt)

In Estonia:

The Estonian Data Protection Inspectorate (https://www.aki.ee)

In Germany:

Berliner Beauftragte fur Datenschutz und Informationshfreiheit (https://www.datenschutz-berlin.de)

In Luxembourg:

The National Commission for Data Protection (https://cnpd.public.lu/en/commission-nationale.html)

  11. Assistance of Data Protection Officer

If you have any inquiries or comments regarding how we collect, use and store information about you, Northern Horizon Capital Group has the Data Protection Officer to help you. Please feel free to contact us at dataprotection@nh-cap.com.

 

[1] This is all members of the European Union plus Iceland, Lichtenstein and Norway.