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Privacy Policy<\/strong><\/p>\n\n\n\n Above Capital \u2013 SCR, S.A. (\u201cAbove Capital\u201d or \u201cCompany\u201d), as a Management Company of collective investment entities, will be responsible for processing the personal data of natural persons with whom it has relationships, namely investors and counterparties, within the scope of its activity, the protection of this personal data, ensuring that its processing is carried out in accordance with applicable European and national legislation, as well as confidentiality obligations, through this Privacy Policy.<\/p>\n\n\n\n This Policy aims to set forth and guarantee that Above Capital complies with the rules that apply to the processing of your Personal Data and provide you with information about your rights as a Data Subject.<\/p>\n\n\n\n The Privacy Policy applies exclusively to the collection and processing of personal data carried out by Above Capital.<\/p>\n\n\n\n Policy objective:<\/strong><\/p>\n\n\n\n This Privacy Policy aims to comply with Regulation (EU) no. 679\/2016, of April 27 (\u201cGeneral Data Protection Regulation\u201d or \u201cGDPR\u201d), regarding the protection of natural persons regarding respect for the processing of personal data and the free movement of such data, and national legislation, namely Law No. 58\/2019, of August 8, which ensures the implementation of the GDPR in the national legal order.<\/p>\n\n\n\n This policy defines and makes known to holders of personal data, who in any way interact with Above Capital, the most relevant information within the scope of the protection of their personal data, including their rights and the way in which these rights can be exercised, as well as, generally, what personal data is collected, the way in which they are processed, the respective processing purposes, associated legal bases and retention periods.<\/p>\n\n\n\n Contact Details of the Data Protection Officer<\/strong><\/p>\n\n\n\n Above Capital – SCR, S.A. Which Data are collected by Above Capital?<\/strong><\/p>\n\n\n\n In general, Personal Data which are collected and processed by Above Capital are: full name, picture, place of birth, nationality, date of birth, identification document number and validity, marital status, taxpayer identification number, address, e-mail and telephone\/mobile. Additional data can be requested, such as: academic qualifications, professional status, name of employer, financial information, investor profile, money laundering and terrorist financing risk.<\/p>\n\n\n\n Which channels are used to collect Personal Data?<\/strong><\/p>\n\n\n\n Personal Data are collected directly with the Data Subjects themselves via e-mail, telephone\/mobile and\/or contract between both parties and indirectly via partners or third parties.<\/p>\n\n\n\n Use and Purpose of Personal Data collected<\/strong><\/p>\n\n\n\n The Personal Data collected are processed strictly in compliance with the rules and principles or the General Data Protection Regulation (and legislation that applies to the sector). Personal Data will never be processed unlawfully and illegitimately.<\/p>\n\n\n\n In this scope, personal data processed by Above Capital can be collected based on the need to execute a contract to which the Data Subject is a party or with the goal of complying with pre-contractual diligences requested by the data subject. Complying with a legal obligation to which the data controller is subject and processing Personal Data for purposes of pursuing the legitimate interests of Above Capital or any third parties are valid processing grounds, as well as any other purpose for which the Data Subject has given their consent.<\/p>\n\n\n\n How long will Personal Data be retained for?<\/strong><\/p>\n\n\n\n Above Capital keeps Personal Data for as long as they are needed in the scope of the purpose for which they were collected.<\/p>\n\n\n\n For the purposes described herein, Personal Data will be kept by the maximum period permitted by law with effect from the date of collection.<\/p>\n\n\n\n Once this maximum retention period has elapsed, Personal Data will be destroyed in a safe manner, provided there is no higher interest that prevents this from happening.<\/p>\n\n\n\n Above Capital keeps personal data for the period required to comply with contractual and legal obligations. Personal data held by Above Capital must be kept for time needed to guarantee:<\/p>\n\n\n\n How does Above Capital ensure the adequate protection of Personal Data?<\/strong><\/p>\n\n\n\n Above Capital undertakes to guarantee and ensure the protection of the Personal Data given to the company by having in place the adequate Technical and Organizational Measures to avoid potential intrusions, diffusions, changes, unauthorized processing and access, and unlawful processing.<\/p>\n\n\n\n Above Capital further undertakes to ensure that, by default, only data required for each specific processing purpose are processed and that those data are not made available or provided to any third parties in an unlawful manner.<\/p>\n\n\n\n What are the Data Subject rights?<\/strong><\/p>\n\n\n\n At any time, the Data Subject may ask us for:<\/p>\n\n\n\n The withdrawal of the Data Subject consent does not affect the lawfulness of the processing of the personal data based on the Data Subject consent before the withdrawal. In order for the Data Subject withdraw the consent, please contact us at geral@abovecapital.pt<\/a>, stating that you wish to withdraw your consent.<\/p>\n\n\n\n The Data Subject also have the right to submit a complaint to the National Data Protection Commission (\u201cComiss\u00e3o Nacional de Prote\u00e7\u00e3o de Dados<\/em>\u201d), in https:\/\/www.cnpd.pt\/<\/a>. \u200d<\/p>\n\n\n\n Changes to the Privacy Policy of Above Capital<\/strong><\/p>\n\n\n\n Above Capital reserves the right to change this Privacy Policy at any time. In case of changes to the Privacy Policy.<\/p>\n\n\n\n You can exercise the rights described in our Privacy Policy by sending a notification or request to the e-mail: geral@abovecapital.pt<\/a> <\/p>\n\n\n\n
Av. Eng. Duarte Pacheco, Amoreiras Torre 1, Piso 4, Sala 11, 1070-101 Lisboa, Portugal
Telephone: +351 213 851 255
E-mail address: geral@abovecapital.pt<\/a><\/p>\n\n\n\n\n
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