Moravian technologies, s.r.o. ("Company")  is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by the Company is controlled by the Company, and the Company is the data controller of your personal information. When your details are provided to the Company, then the Company, acting as a data controller, may process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (as distinguished from the entity itself) (the foregoing collectively, "Your Personal Information"). 

The Company's representative is located in the Czech Republic at 113, Veslarska, 637 00 Brno and can be contacted at gdprrepresentative@moraviantech.com.

This policy (the "EU Privacy Policy") explains the manner in which the Company collects, utilizes, and maintains nonpublic personal information about clients and potential clients ("Clients") based in the European Union ("EU") or the European Economic Area ("EEA"), as required under the General Data Protection Regulation (EU) 2016/679 ("GDPR"). This EU Privacy Policy applies to your investment or potential investment in the Fund.

Collection of Your Personal Information

The Company collects Your Personal Information from the following sources, as applicable:

• subscription documents and other information provided by the Client in writing, in person, by telephone, electronically, or by any other means (this information includes name, address, income, financial and investment qualifications, tax-related information, birth date, nationality, passport or other identification number, and employment information);

• transactions within the Fund, including account balances, investments, redemptions, and management fees and performance allocations; and

• other interactions with the Company (for example, discussions with our staff).

Why We Use Your Personal Information

Your Personal Information may be processed by the Company (or any of their affiliates, agents, employees, delegates, or subcontractors) for the following purposes, as applicable:

• to facilitate your investment and the management and administration of your investment on an ongoing basis (the "Services") as necessary to fulfill all contractual and regulatory obligations related to your investment, including without limitation the acceptance and processing of subscription documents and redemption and transfer requests;

• in order to carry out anti-money laundering checks and related actions that the Company  considers appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with the Company's anti-money laundering policies and procedures;

• to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;

• to disclose information to other third parties such as service providers of the Company  (including, for example, attorneys, accountants, auditors, or other professionals), regulatory authorities, and technology providers in order to comply with any legal obligation imposed on the Company or in order to pursue the legitimate interests of the Company;

• to monitor and record electronic communications and if applicable, calls, for any of the purposes specified herein; and/or

• to otherwise pursue the legitimate interests of the Company relating to your investment or your potential investment and/or where the processing of Your Personal Information would be in the public interest.

Countries Having Access to Your Personal Information

The Company's servers, which store and keep Your Personal Information, are located in the EU.

The Company also has service providers whose personnel will have access to Your Personal Information and that are located in other jurisdictions. Transfers to these service providers are necessary for the performance of the contract between the Company and the Client. These jurisdictions either (i) afford an adequate level of protection for Your Personal Information (as declared by the European Commission) or, (ii) if they do not, then the Company has entered into agreements with these service providers incorporating clauses that are the same as or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and impose obligations no less onerous than those contained in this EU Privacy Policy.

Collecting Client Information Legally

The Company are able to legally collect and use Your Personal Information because

• you have consented to their doing so;

• it is necessary for the performance of a contract to which the Client is a party or in order to take steps at the request of the Client prior to entering into a contract or to otherwise perform the Services;

• collecting and using Your Personal Information is necessary for the Company to fulfill their legitimate business interests, which may include to investigate, defend against, or prosecute any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum or otherwise protect their legal rights; and/or

• it is necessary to comply with any applicable regulatory, judicial, or other legal obligations applicable to Company.

Retention of Client Information

The Company will retain Your Personal Information for the purposes described in 1, 2, and 3 in the immediately preceding paragraph for as long as required for the purposes described above.

In particular, and without limitation to the foregoing, the Company have obligations imposed on them under applicable legal systems that require them to retain Your Personal Information for certain minimum time periods.

Your Rights

You have the right to

• be informed, as this EU Policy seeks to do, about Your Personal Information that the Company collects from you, uses, and retains;

• obtain confirmation from the Company that Your Personal Information is being collected, used, and retained as described above and access Your Personal Information held by the Company;

• have Your Personal Information corrected if it is inaccurate or incomplete at any time;

• erasure (or the right to be forgotten) which means you can request deletion or removal of any of Your Personal Information the Company holds at any time, subject to the Company's rights to retain Your Personal Information as provided under the GDPR;

• block or suppress the Company's collecting and using Your Personal Information, which means the Company can continue to store Your Personal Information but cannot further collect or use it in any way;

• obtain and reuse any of Your Personal Information that the Company holds for your own purposes across different services, which allows you to move, copy, or transfer Your Personal Information easily from the Company to another place identified by you to the Company in a safe and secure way without hindrance to the usability of Your Personal Information;

• object to the Company's collecting, using, or retaining Your Personal Information when this is based on

• your legitimate interest or the performance of a task in the public interest or

• your desire not to receive direct marketing even if otherwise legally permitted; and

• withdraw your consent to the use of Your Personal Information at any time, as described below.

To make any requests as listed above, please contact the Company at legalcompliance@moraviantech.com.

The Company will respond to requests relating to your rights above within one month of receipt of your request or within two months of receipt of your request when the request is more complex.

Withdrawal of Your Consent

You can tell the Company to stop collecting, using, and retaining Your Personal Information at any time by emailing the Company at legalcompliance@moraviantech.com. You should note that notwithstanding your withdrawal of consent, the Company may be legally required to retain some or all of Your Personal Information.

When the Company requires Your Personal Information to comply with AML or other legal requirements, failure to provide this information will mean that you will be unable to be accepted as an Client and/or may be mandatorily redeemed if you are already an Client.

Protection of Client Information

The Company maintains appropriate technical and organizational measures to ensure a level of security appropriate to address potential risks, including physical, electronic, and procedural safeguards that comply with the GDPR to protect customer information, including

• the pseudonymization and encryption of Your Personal Information when appropriate;

• ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;

• ensuring that the Company can restore access to Your Personal Information in a timely manner if a physical or technical incident occurs; and

• regular testing, assessment, and evaluation of the effectiveness of its technical and organizational measures to attempt to ensure Your Personal Information is secure.

The Company restricts access to the personal and account information of Client to those employees who need to know that information in the course of their job responsibilities. The Company will destroy, erase, or make unreadable data, computer files, and documents containing Your Personal Information that is nonpublic prior to disposal.

Making a Complaint

If you would like to make a complaint about the way the Company has collected, used, or retained Your Personal Information, please contact us at legalcompliance@moraviantech.com.

You have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work, or place of the alleged infringement if you consider that the processing of Your Personal Information carried out by the Company or its service providers infringes the GDPR.

Former Customers and Clients 

This EU Privacy Policy also applies to former Clients in the EU and the EEA.

Further Information

This EU Privacy Policy is in addition to the Company's existing Privacy Policy, a copy of which is available from the Company. The Company reserves the right to change this EU Privacy Policy at any time and without prior notification. The examples contained within this EU Privacy Policy are illustrations and are not intended to be exclusive. This EU Privacy Policy is intended to comply with the GDPR regarding privacy. You may have additional rights under other foreign or domestic privacy laws. If you have any questions about this EU Privacy Policy, please call or email us at legalcompliance@moraviantech.com. No further action is required on your part.