Stock Picking ∙ Concentrated ∙ Long-Term
Stock Picking ∙ Concentrated ∙ Long-Term
This privacy policy ("Policy") describes how the personally identifiable information ("Personal Information") you may provide on the Nordflint.com website ("Website" or "Service") is collected, protected, and used, including specifically in relation to the investment services we provide to you, via our partners and service providers. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. By accessing and using the Website and Services, you acknowledge that you have read, understood Nordflint’s collection and processing of your personal data in accordance with this Privacy Policy. This Policy does not apply to the practices of companies that we do not control, or to individuals that we do not employ or manage.
Our top priority is customer data security and, as such, we exercise the no logs policy. We may process only minimal user data, only as much as it is absolutely necessary.
We process personal data when:
Using our website www.nordflint.com
We collect the following personal data when using our website: Identification data, login data, and digital footprints (e.g., IP address, information about the usage).
We collect and process personal information for one or more of the following: running and operating the website and services, identifying potential cases of abuse, and establishing statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.
Interacting with customers and providing our investment services
We may collect and process the following personal data: personal details, including your name, address, email, and telephone/fax numbers, date of birth, nationality; employment details, including your employer's name, your position or title, and your corporate contact details; information on your financial circumstances, including your profession, income, assets, and liabilities, as well as sensitive and/or criminal data. As well as collecting personal data from our clients, we may also process personal data about relevant persons connected with the investment services, for example investors in our funds, co-investors, directors of investee company portfolios, etc.
We collect and process personal information for one or more of the following: delivering our services, providing support, delivering communication, and compliance with legal requirements.
Interacting with individuals connected with our partners and service providers
We may collect and process your contact information, including your name, address, position, email, and telephone/fax numbers; financial details, including relevant details for invoicing and billing; and KYC documentation, if and where required under relevant Anti-Money-Laundering or Counter Terrorism Financing ("AML/CTF") legislation.
We collect and process personal information for one or more of the following purposes: planning, performing, and managing the business relationship, including any contracts; administration (e.g., auditing, billing, processing payments); providing support, and compliance with legal requirements.
Nordflint will process your personal data based on one or more of the following legal bases:
Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below.
In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Depending on the requested Services or as necessary to complete any transaction or provide any service you have requested, we may share your information with your consent with our trusted third parties that work with us, any other affiliates we rely upon to assist in the operation of the Website and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. We may share your Personal Information for these purposes only with third parties whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. These third parties are given Personal Information they need only in order to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes.
We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
We may disclose your personal information with the following category of recipients, and based upon the legal bases and purposes set-out above:
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
Once the retention period expires, Personal Information shall be deleted unless precluded by applicable legal obligations. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information.
Nordflint will only transfer your personal data to data processors or data controllers established in countries outside EU/EEA if it is assessed that there is an adequate level of protection. Transferring of personal data to countries outside EU/EEA will in general be based on the European Commission’s assessment of adequate level of protection.
You have certain rights under GDPR. Your rights under GDPR are subject to conditions and exceptions provided by applicable law.
You have the following rights:
We have taken multiple measures to protect your personal data. Furthermore, we have taken multiple measures to safeguard your rights as data subject. Your rights, however, only apply when certain conditions are met due to the extensive regulation which Nordflint is subject to.
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Policy.
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
In the event we become aware that the security of the Website and Services has been compromised or users' Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website.
We reserve the right to modify this Policy or its terms relating to the Website and Services from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
If you would like to contact us to understand more about this Policy or wish to contact us concerning any matter relating to individual rights and your Personal Information, please contact us using the following e-mail: backoffice@nordflint.com.
Nordflint Capital Partners Fondsmæglerselskab A/S
Central Business Register (CVR): 40887628
Scherfigsvej 10, DK-2100 København Ø
In case you want to complain about our processing of your personal data, you may file a complaint with the Danish Data Protection Agency.
You can find the Danish Data Protection Agency’s contact details by using this link: https://www.datatilsynet.dk/kontakt.
This document was last updated on March 15, 2024