PRIVACY POLICY

We, NCH Baltics AIFP, are aware that by visiting our website and providing your personal data, such as: name, surname, date of birth, e-mail address, telephone number, you entrust us with said data.

Ensuring your privacy as a visitor of NCH Baltics AIFP website and as a client is very important for us, hence why NCH Baltics AIFP takes all necessary measures to ensure that the data we have received is secure, protected and proccessed in accordance with applicable laws.

In view of the above, we would like to inform you that the controller of personal data of the website www.nchbaltics.eu is LLC “NCH BALTICS AIFP” (hereinafter – Controller).

LLC “NCH BALTICS AIFP” is an alternative investment fund (hereinafter – Fund) manager.

Please use the following contact details for any inquiries for the Controller or the Fund:

Telephone number: +371 67228086

e-mail: info@nchbaltics.lv

In the context of this Privacy policy the following term is used – client, who is a person who has provided a written or oral interest pertaining to products, services, real estate or investment in said real estate provided by NCH Baltics AIFP or the Fund. The statuss of a client remains until prescription period  has lapsed in accordance with contractual obligations between the parties or when the client has refused to receive newsletters and information about special offers.

Contact information of the controller of personal data:

SIA “NCH Baltics AIFP”

Reg. nr. 40203321175

Adress: Riga, Ķelnes street 1, LV-1014

telephone number: +371 67228086

e-mail: info@nchbaltics.lv    

E-mail of the contactperson: edgars.livmanis@nchriga.lv

Purposes of processing your personal data are as follows:

• for the performance of an agreement where you are a contracting party pertaining to purchase, sale, rent or lease of real estate or for taking measures at our request before the conclusion of an agreement. In such cases processing of personal data is in accordance with the agreement and is a prerequisite for the conclusion of said agreement;
• to build relationship with clients and to analyze such relationship within the context of marketing acitivities;
• ensuring the completion of the following activities in regard to the sale or purchase of real estate: execution of agreements, compliance with the requirements set out by applicable laws and regulations. NCH Baltics AIFP is entitled to transfer all or a part of the relevant personal data to subcontractors and other bussiness parters, if this transfer is neccessary for the performance of an agreement. When transfering personal data to subcontractors, NCH Baltics AIFP will sign a separate agreement to ensure compliance of Controller’s instructions, this Privacy policy and to ensure that processing of personal data is compliant with applicable laws and regulations;
• ensuring marketing activities: notification, communication, sending messages relating to products and services;
• identification of the client before entering into a legal arrangement and to conduct the client due diligence: identification and due diligence of the client is carried out under the requirements of Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing, as well as other external legal acts.

By accepting and agreeing to the Privacy policy and by subcribing to NCH Baltics AIFP company’s news and special offers, you have given permission to be a recipient of commercial notices in regard to news and special offers of NCH Baltics AIFP and the Fund.

If you no longer wish to receive such commercial notices then you can at any time send a request of withdrawal to the indicated e-mail of the Controller. your request will be processed as soon as possible.

The Controller shall process personal data in accordance with the following rules:

1. The Controller processes your personal data in accordance with the General Data Protection Regulation (hereafter – GDPR) of the European Union, Personal Data Processing Law of the Republic of Latvia and other external legal acts, and does not disclose this data to 3rd parties, except in the following cases:

• if by the court judgment, decision of public law-enforcement institutions or other official institution, there is a requirement to disclose this information;
• if the Controller or the person supporting the website needs personal data to perform actions, which are connected with website functioning and maintenance. In this case, NCH Baltics AIFP will ensure that sub-contractors will observe NCH Baltics AIFP instructions, this Privacy Policy and that personal data will be processed according to the normative acts;
• if the Controller is required to submit reports on suspicious transactions or to submit threshold declarations to government institutions. In these cases personal data can be disclosed to Latvian State Security Service, The Financial Intelligence Unit of Latvia, State Revenue Service and other government institutions;
• in other cases, which are provided for by normative acts and the Privacy Policy.

2. you as a data subject are entitled to the following rights:

• receive a confirmation from the Controller on whether your data is or is not processed;
• obtain from the Controller without undue delay the rectification of inaccurate personal data, as well as ask the Controller to supplement incomplete personal data;
• obtain from the Controller the erasure of personal data without undue delay. The erasure of your data will be carried out if at least one of the conditions referred to in Article 17 (1) of the GDPR is met;
• obtain from the Controller restriction on the processing of your personal data if at least one of the conditions referred to in Article 18 (1) of the GDPR is met;
• receive from the Controller your own personal data in a structured, commonly used and machine-readable format if conditions referred to in Article 18 are met.

3. To exercise the rights mentioned in the 2^nd clause of this Privacy policy, you need to contact the Controller by using the provided contact information and we will do everything that is in our power to process your request as soon as possible.
4. NCH Baltics AIFP undertakes to follow the requirements of normative acts, which regulate the use of personal data that was made available to us, additionally we continue to review and improve our policy in relation to personal data processing and its safety.
5. In rare cases, your personal data, such as name, surname, personal ID number, date of birth, may be transferred to NCH Capital Inc., a company that is incorporated in the United States, to enable the Controller to fulfil obligations set out by the Law on the Prevention of Money Laundering and Terrorism and Proliferation Financing and other normative acts that regulate the prevention of money laundering. Data transfer to NCH Capital Inc. is conducted within the framework of standard contractual clauses signed by the Controller and NCH Capital Inc.

6. Additionally, we want to inform you that in the case where your personal data is transferred outside of the European Union or European Economic Area and the recipient is not NCH Capital Inc., your data will be transferred only if at least one condition referred to in Article 49 (1) of the GDPR is met or if the European Commission has adopted an adequacy decision pertaining to the data recipient country.
7. We wish to inform you if, in the event that the Controller intends to further process the personal data provided by you for a purpose other than the initial purpose for which the personal data was collected, the Controller will inform you of this other purpose and provide you with all necessary information as required by GDPR.
8. We draw your attention that your personal data will be stored as long as relations exist between NCH Baltics AIFP and you as a client, additionally when this relationship has ceased, personal data will be stored until statute of limitations, which arises from the contractual relations of the parties, has ended. In addition to the mentioned conditions, requirements of personal data storage arise from the requirement of the normative acts to store them for specific time. Respectively, the Controller will store these data while these conditions exist.
9. We wish to inform you that if NCH Baltics AIFP will receive your personal data from persons other than you, then you will be provided with information about the source from which your data has been received, and in the respective case – information about whether data has been acquired from publicly available sources, as well as other information as prescribed by the GDPR.
10. The Controller does not utilize automated individual decision-making systems or methods, including profiling, when processing personal data.
11. If you have concluded that your personal data transferred to NCH Baltics AIFP is used for an unintended purpose or the grounds of such personal data processing have been violated, then you are entitled to file a claim to the Data State Inspectorate, address: Elijas street 17, Riga, LV-1050, additional information – www.dvi.gov.lv

NCH Baltics AIFP POLICY OF COOKIES USE

Host of this website and its owner is LLC “NCH Baltics AIFP” (hereinafter – NCH Baltics AIFP). Using this website, you accept and agree with application of NCH Baltics AIFP “Policy of Cookies Use” (hereinafter – Policy of Cookies Use).

Policy of Cookies Use defines the purpose of cookies use, as well as the rights of cookies users to choose, change or refuse cookies according to the user’s requirements and needs.

What is a cookie and where is it stored?

A cookie (HTTP cookie) is a small text file, which the website browser saves on your computer or other device, for example: a mobile phone.

How do the NCH Baltics AIFP cookies function?

When a user of NCH Baltics AIFP website visits the website for the first time, then an identification code named cookie is sent to the user’s browser. When this user visits the website of NCH Baltics AIFP next time, then the cookie technology allows us to define that this user has previously visited the website of NCH Baltics AIFP. During each next visit of the website, cookies are sent back to the original homepage or other webpage recognizing this cookie. This way, also your habits and needs of website use are recognized.

What cookies are used by NCH Baltics AIFP?

Technical cookies

These cookies are necessary so that you could quickly visit and review the website. These cookies identify the user’s device, but they do not collect and do not summarize the users’ information. Without these cookies, the website could not fully function. Technical cookies are stored on the user’s device, until the website browser is closed.

Functional cookies

With functional cookies, the website remembers the user’s selected settings and the performed choices to use the website in a more convenient way. These cookies are stored on the user’s device permanently or for time, depending on the settings. 

Analytical cookies

Analytical cookies summarize information, how the user uses the website, state the most often visited sections, including content chosen by the user, reviewing the website. Information is processed for the purpose of analysis to find out what is interesting to website users, and how to improve the website functionality, make it more convenient to use. Analytical cookies do not use information for other purposes.

Third persons’ cookies

NCH Baltics AIFP website may have the third persons’ cookies, especially, Facebook, Instagram, etc. social networks or search engines, especially Google Analytics. Google Analytics,the tool is provided by Google Inc.(USA company), which has access to statistical data collected by this tool.

NCH Baltics AIFP bears no responsibility for processing of information performed by the third persons cookies.

How does NCH Baltics AIFP use cookie information?

1. NCH Baltics AIFP summarizes NCH Baltics AIFP website use statistical data, performs their analysis;
2. Cookies are used by NCH Baltics AIFP to know whether the user has visited NCH Baltics AIFP website before;
3. Based on the fact, which pages of NCH Baltics AIFP website the user has looked at, how long he has spent on the website, from which place he has entered the website, where he has clicked when he was on the website, the repeated marketing ad is applied;
4. Allows NCH Baltics AIFP to evaluate the ad efficiency.

Refusal from cookies use

NCH Baltics AIFP website user may refuse from cookies use, respectively selecting settings in his browser and deleting NCH Baltics AIFP cookies. Please, pay attention to the fact that changes in the browser safety settings shall be performed in each browser individually.

Data protection and personal data

We draw your attention that to guarantee your data protection, NCH Baltics AIFP has introduced electronic, administrative and physical safety measures, which it continues to perfect.

NCH Baltics AIFP wishes to inform you that if you do not enter your personal data when visiting NCH Baltics AIFP website, then NCH Baltics AIFP is unable to identify you and your status is “anonymous user”.

How to contact us?

The Controller for cookie use  on www.nchbaltics.eu site and the processing of personal data is LLC “NCH Baltics AIFP” (registration number 40203321175), address: Riga, Ķelnes street 1, LV-1014, telephone nr. +371 67228086, email: info@nchbaltics.lv

SIA NCH BALTICS AIFP

Application and complaint review procedure

for the provided services and ancillary services to fund investors

1. This SIA NCH BALTICS AIFP application and complaint review procedure for the provided services and ancillary services (hereinafter – Procedure) precribes the order under which applications and complaints are received and examined from investors in the alternative investments funds (hereinafter – Investors) managed by SIA NCH Baltics AIFP.
2. Investors can submit written applications and complaints (hereinafter – Application) about the services and ancillary services provided by SIA NCH Baltics AIFP without any costs. Application must be written in Latvian or in English language and it must contain clear and substantiated statements on the issue, as well as the claim. Application has to be signed by the Investor and it must containt its name, surname or title of the legal, as well as the name and surname of the Investor’s represantative, if the Application is submitted by its represantative. The Application must contain an adress to which a response can be sent. If an Application is sent to an e-mail, it must be signed digitally with a secure digital signature.
3. Applications must be sent to this adress: SIA NCH Baltics AIFP, Ķelnes iela 1, Riga, LV-1014 or to the following e-mail adress info@nchbaltics.lv.
4. SIA NCH Baltics AIFP will review the received Application within 30 days from receiving it. Application is deemed to be received: (i) on the seventh day from the date of submission if it is a registered postal item, (ii) on the date of Application’s submission if it has been submitted in person and the submission has been signed, (iii) on the next working day if the Application has been sent to the aforementioned e-mail adress. If due to objective circumstances it is not possible to abide by the 30 day review term, SIA NCH Baltics AIFP is entitled to prolong the due date by informing the Investor in writing and by providing the extented term.
5. In case of a dispute due to the content of the Application between SIA NCH Baltics AIFP and the Investor, both SIA NCH Baltics AIFP and the Investor will make reasonable efforts to resolve this dispute as expeditiously as possible and to a mutual benefit. If the dispute cannot be resolved, it will be reviewed in accordance with procedures specified in the limited partnership agreement between SIA NCH Baltics AIFP and the Investor.