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Cookie policy

1. Who is the controller of your personal data?


The Your personal data controller is UAB Modus Asset Management (hereinafter - the Company or We), legal entity code 302790959, Ozo str. 10A, LT-08200 Vilnius, Lithuania, e-mail: p., tel. +370 5 235 6080.


2. What is the purpose of this privacy policy and what is it for?


We respect your privacy and ensure the security and confidentiality of your personal data and other information. We aim to provide you with the necessary information about the processing of your personal data and your rights and their implementation. This Privacy Policy is intended for all entities that visit the website (hereinafter referred to as the Website) and use the investor functions contained therein ("Investor Self-Service").


3. What is personal data and how is it processed?


3.1. Personal data is any information about you that could be used to identify you, directly or indirectly, by name, personal identification number, whereabouts and IP address and any other physical, physiological, genetic, mental, economic, cultural or social identity of your person. identity features.


3.2. The Company processes the personal data provided by you in accordance with the 2016 April 27 Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) ("the Regulation") and other legislation on personal data protection.

4. For what purpose and what personal data do we process?

For the purpose of creating and administering the Investor's account ("Investor's self-service") for the purpose of providing investment services when investing in the funds managed by Us (i.e. by concluding investment agreements) you may additionally choose whether you want Us to create an Investor account for you (i.e. to provide a connection to the “Investor Self-Service”). By logging in to this account on the website, you will be able to see the most up-to-date fund information (eg fund financial data, financial statements, key documents, performance indicators, parameters, etc.). If you choose to use the Investor Self-Service (ie by giving us consent to create an investor account for the purpose of creating and administering an investor account), We will process the following personal data in your account: name, surname, e-mail. email address, login password (encrypted), information about concluded contracts, deadlines and / or other data (eg phone number, address, country from which the account is connected, etc.). Personal data will be processed on the basis of your consent (Article 6 (1) (a) of the Regulation), which you express at the time of concluding the investment agreement. Personal data (including personal data) contained in this account will be processed (stored) until the date of revocation of your consent, but no longer than the validity of the investment agreement concluded with Us.

5. Who is your personal data provided to?


In order to ensure the uninterrupted operation of the Company and the proper provision of services, we may disclose your personal data to our employees and / or service providers if this is reasonably necessary to achieve the purpose. We may transfer your personal data to third parties (data processors) who process and / or have access to your personal data on our behalf and under our instructions, such as service providers developing and maintaining information systems and other persons who assist Us in providing you with services properly. In this case, your personal data is provided only to those third parties who contractually ensure appropriate conditions for the processing and protection of personal data. Your personal data is not transferred to third countries (i.e. outside the European Union or the European Economic Area) or to international organizations. Your Data may also be transferred to the competent authorities and / or law enforcement authorities (such as the courts, the police or other public authorities carrying out investment or other supervision); legal service providers and / or others. However, your data will only be provided if required by applicable law and only in accordance with the law, in order to ensure Our rights, respond to inquiries from competent authorities, ensure the security of Our customers, employees and resources, declare, provide and / or defend legal requirements.

6. What rights do you have and how are they exercised?

As a data subject, you have the following rights:


  • request access to your personal data and a copy;

  • request the correction of inaccurate or incomplete personal data or the suspension of their use;

  • request the deletion or restriction of redundant or unlawfully processed personal data;

  • request the transfer of your personal data submitted in a structured, computer-readable format (right to data portability);

  • right to withdraw his consent at any time (when personal data are processed on the basis of consent);

  • do not consent to the processing of your personal data;

  • submit a complaint to the State Data Protection Inspectorate (

You can exercise your rights listed above by contacting the Data Controller at the registered office address: Ozo str. 10A, LT-08200 Vilnius or by e-mail, having previously confirmed his identity, i. y. properly identified (eg by using a qualified e-signature, etc.). We will provide the information you request free of charge within one month of receiving your request, but if your requests are manifestly unfounded or disproportionate, in particular due to their repetitive content, We will charge a reasonable fee depending on the information or notifications or actions you request. administrative costs, or refuse to act on your request.


Please note that the Website may contain links to websites and (or) social networks outside the Company. In this case, we recommend that you read the privacy policies of these websites and / or contact the operators of these websites directly if you have any questions about how they use your personal data.

7. Where to go if you have questions?

If you have any questions, you can contact us by e-mail. email address, tel. No., +370 5 235 6080 or to our data protection officer - "Data protection and security solutions", MB, company code 304539959, address Jonažolių str. 8-35, LT-04134 Vilnius, Republic of Lithuania, website (contact person of the Data Protection Officer: Darius Štitilis, tel. +37061880495, e-mail:

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