IVAR APP PRIVACY STATEMENT

Wahlstedt Sageryd Financial Services AB (”Wahlstedt Sageryd”) offers back office services and supplementary services to fund companies and institutional  asset managers  supported by the transaction based portifolio- and  accounting system IVAR™ Asset Management.

Wahlstedt Sageryd collect, use and store personal data in the IVAR™ Asset Management system as processor on account of our customers (collectors) in accordance with our customer’s instructions and the provisions of the General Data Protection Regulation (GDPR) and other applicable rules according to Swedish law. Personal data collected for use and store in the IVAR™ App is processed in a way compatible with the purpose for which it was collected. Wahlstedt Sageryd places great importance on security of your personal data and use a high level of data protection. This Privacy Statement explains how we process the personal data we receive from user of the IVARÔApp and your rights with respect to our processing of personal data.

Type of Personal Data, Purpose and Legal Reason

The personal data we collect and process for access to the IVARÔApp are the following

• Personal identity number
• Login details

The personal identity number of the user is processed in order for the user to login through BankID in accordance with our customer agreement.

The purpose of the processing is to provide access to the IVAR™ Asset Management financial system and the legal reason for processing is to fulfil the agreement with our customer.

We do also collect data regarding your use, however with no personal identifiers. We use this aggregate data to help us understand how the site is being used and to improve its usability. We also use it to enhance the quality and availability of products and services we offer.

Collecting of Data

Personal data is collected from our customer as part of fulfilment of our agreement with customer.

Would it be possible to share your personal data?

Sub processors

We do not use sub processors for processing of personal data unless approved in writing by the collector.

Principles for Processing Personal Data

Our processing of personal data is based on the principle of minimizing the scope of data we process, meaning that all data collected shall be relevant, adequate and not too extensive in relation to the purpose causing the processing of personal data. Such data is not collected for the purposes of future possible needs but for the purpose of special, explicitly stated and justifiable reasons according to the assignment we have received from the collector. We, as well as the collector, have an obligation to register the processing we perform.

We also adhere to the principle of minimizing storage, meaning that personal data will not be stored longer than adequate for the purposes of the processing or for fulfilling of legal requirements, for example bookkeeping- or anti money laundering rules. When there is no longer any need for the data it will be erased or be made anonymous.

Protection of Data

We strive to make processing of personal data safe and have therefore implemented technical, administrative and organizational security measures to protect it from unauthorized use or extradition, misuse, loss, change or destruction. We process data on our own IT-systems within EU/EES. We will not transfer your data to third countries.

Your Rights

You have the right of access to the personal data we are processing concerning you regardless of how data was collected. To receive such information, you shall contact the fund company or institutional asset manager you represent when you access the IVARÔ

App.

If incorrect personal data is identified you may demand rectification.

In certain circumstances you may demand erasure of your personal data or limitation of processing. The processing may however continue if our customer has a legal reason for processing your personal data, for example if it is necessary for the fulfilment of an agreement between you.

Changes of this Policy

Since we strive continuously to improve us and our working methods we may change this policy in the future. The version from time to time prevailing will be the one published on our web site.

Questions

Should you have questions in respect of this policy you are welcome to contact us via e-mail (info@ws.se) by letter to Holländargatan 17, P O Box 7029, SE-103 86 Stockholm, Sweden.