(Information on the Processing of Personal Data of Investors, Prospective Investors, Business Partners, Delegates and Website Users)

 

1. Introduction

TRIGAL FUNDS, Alternative Investment Fund Management Company, d.o.o. (“TRIGAL FUNDS” or the “Company”), respects the privacy of individuals and is committed to processing personal data lawfully, fairly and transparently.

This Privacy Policy explains which personal data the Company processes, for what purposes, on which legal bases, to whom personal data may be disclosed, and what rights individuals have in relation to the processing of their personal data.

 

2. Data Controller

The controller of personal data is:

TRIGAL FUNDS, upravljanje alternativnih investicijskih skladov, d.o.o.
Tomšičeva ulica 1
1000 Ljubljana
Slovenia

E-mail: [●]
Telephone: [●]

TRIGAL FUNDS processes personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), the Personal Data Protection Act (ZVOP-2), the Alternative Investment Fund Managers Act (ZUAIS), the Prevention of Money Laundering and Terrorist Financing Act (ZPPDFT-2), and other applicable legislation.

 

3. Scope of this Privacy Policy

This Privacy Policy applies to:

 

• • investors and prospective investors in alternative investment funds managed by TRIGAL FUNDS;

• • legal representatives, authorised representatives and beneficial owners of investors;

• • business partners and their representatives;

• • delegates and external service providers engaged by the Company;

• • users of the Company’s website;

• • individuals who communicate with the Company.

 

4. Purposes and Legal Bases for Processing

Management of Alternative Investment Funds

Personal data is processed for the establishment, administration and termination of investment relationships, the exercise of rights and obligations arising from fund documentation, and communication with investors.

Legal basis: performance of a contract (Article 6(1)(b) GDPR).

Compliance with Legal and Regulatory Obligations

Personal data is processed in order to comply with legal and regulatory requirements applicable to alternative investment fund managers and investment funds.

This includes, among other things:

 

• • investor categorisation;

• • regulatory reporting;

• • record-keeping obligations;

• • compliance with requirements imposed by supervisory authorities.

Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR).

Anti-Money Laundering and Counter-Terrorist Financing

Personal data is processed for the purposes of customer due diligence, identification and verification procedures, beneficial ownership verification, transaction monitoring and compliance with anti-money laundering regulations.

Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR).

FATCA, CRS and Tax Reporting

Personal data may be processed for the fulfilment of obligations arising from tax legislation and international tax reporting standards, including FATCA and CRS.

Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR).

Business Relationships

Personal data of business partners and their representatives is processed for the negotiation, conclusion and performance of contractual relationships.

Legal basis: performance of a contract (Article 6(1)(b) GDPR).

Communication and Handling of Requests

Personal data may be processed for responding to inquiries, requests, complaints and other communications.

Legal basis: performance of a contract and/or legitimate interests (Articles 6(1)(b) and 6(1)(f) GDPR).

Website Operation

When visiting the website, certain technical data may be processed to ensure the secure and efficient operation of the website.

Further information is available in the Cookie Policy.

 

5. Categories of Personal Data

Depending on the purpose of processing, the Company may process the following categories of personal data:

 

• • identification data;

• • contact details;

• • citizenship and tax residency information;

• • information relating to legal representatives, authorised representatives and beneficial owners;

• • information relating to investments and business relationships;

• • transaction and payment information;

• • anti-money laundering and customer due diligence information;

• • FATCA and CRS-related information;

• • communication records;

• • technical and website usage data.

 

6. Sources of Personal Data

Personal data is generally obtained directly from individuals.

Where permitted or required by law, personal data may also be obtained from:

 

• • public registers and publicly available sources;

• • business partners;

• • authorised representatives;

• • competent authorities;

• • other lawful sources.

 

7. Recipients of Personal Data

Personal data may be disclosed to:

 

• • the Securities Market Agency of the Republic of Slovenia (ATVP);

• • the Financial Administration of the Republic of Slovenia (FURS);

• • the Office for Money Laundering Prevention;

• • courts and other competent public authorities;

• • depositaries of alternative investment funds;

• • statutory auditors;

• • legal, tax and other professional advisers;

• • IT service providers and other contractual processors;

• • other recipients where disclosure is required by law.

All processors are required to implement appropriate technical and organisational measures to ensure the protection of personal data.

 

8. Transfers of Personal Data to Third Countries

As a general rule, TRIGAL FUNDS does not transfer personal data to countries outside the European Economic Area.

Where such transfers are necessary, they will be carried out in accordance with the GDPR and subject to appropriate safeguards.

 

9. Retention Periods

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable laws and regulations.

Purpose	Retention Period
Investment relationship management	10 years following termination of the relationship or completion of the transaction
AML/CFT compliance	10 years following termination of the business relationship
FATCA and CRS reporting	5 years or as required by applicable legislation
Business partner management	5 years following termination of the business relationship
Accounting and tax documentation	10 years
Complaints and legal claims	Until completion of the relevant proceedings and expiry of applicable limitation periods
Website communications	Until the purpose has been fulfilled or communication has been concluded

 

10. Rights of Individuals

Individuals have the right to:

 

• • access their personal data;

• • rectify inaccurate or incomplete personal data;

• • request erasure of personal data;

• • request restriction of processing;

• • object to processing;

• • receive personal data in a structured, commonly used and machine-readable format where applicable;

• • withdraw consent at any time where processing is based on consent.

Requests may be submitted using the Company’s contact details provided above.

 

11. Right to Lodge a Complaint

If an individual believes that their personal data is being processed in breach of applicable data protection laws, they have the right to lodge a complaint with the competent supervisory authority.

In Slovenia, the competent authority is:

Information Commissioner of the Republic of Slovenia
Dunajska cesta 22
1000 Ljubljana
Slovenia

Official website: https://www.ip-rs.si

 

12. Automated Decision-Making

TRIGAL FUNDS does not carry out automated decision-making, including profiling, which would produce legal effects concerning individuals or similarly significantly affect them.

 

13. Amendments to this Privacy Policy

TRIGAL FUNDS reserves the right to amend or update this Privacy Policy at any time.

The current version of this Privacy Policy is published on the Company’s website.

Trigal Funds d.o.o.

Junij 2026