Personal Data Protection Policy

Data controller

Trend Asset Management AD, UIC 175436564, registered seat and management address: 28 Aksakov Street, second floor above ground level, apt. 5, Sofia, Bulgaria. Telephone: +359 2 494 90 84; email: trend@trend-am.com.

Data protection officer

Viktoria Kukleva — address: 28 Aksakov Street, second floor above ground level, apt. 5, Sofia; email: v.kukleva@trend-am.com.

Purposes and legal grounds of the processing

The Company collects and processes personal data in connection with: the conclusion of agreements for the purchase and sale of units in the contractual funds it manages; discretionary portfolio management agreements; the provision of investment advice on financial instruments; as well as the personal data of employees in connection with their employment duties.

The processing is carried out on one of the following grounds:

• the client's explicit consent;
• performance of the Company's obligations under a contract with the client;
• compliance with a legal obligation applicable to the Company (the Act on the Activity of Collective Investment Schemes and Other Undertakings for Collective Investment, Ordinance No. 44, the Measures Against Money Laundering Act and its implementing rules, the Markets in Financial Instruments Act, and others);
• the purposes of the Company's legitimate interest.

What data is collected

First name and surname, personal identification number, identity document number, email, country, telephone; data on marital status; education; occupation. The Company does not collect or process special categories of data (racial or ethnic origin; political, religious or philosophical beliefs; trade union membership; genetic and biometric data; data concerning sex life; health data, with the exception of employees' sick-leave certificates).

Retention period

Clients' personal data is retained throughout the entire period of the relationship with the respective client, but for no less than 5 years. Once this period expires, the data is destroyed (by shredding paper records and deleting the relevant files from electronic media).

Disclosure to third parties

The Company discloses information about the personal data it holds only: to the natural person to whom the data relates (or to a person expressly authorised by them under a notarised power of attorney); and to the competent public authorities in the cases and manner prescribed by law (the FSC, courts, the prosecution service, investigating authorities, and others).

Your rights

As a data subject, you have the right to:

• be informed about the processing of your personal data;
• access your own personal data;
• rectification of inaccurate data;
• erasure (the "right to be forgotten");
• restriction of processing;
• data portability between controllers;
• object to the processing;
• not be subject to a decision based solely on automated processing, including profiling;
• judicial or administrative protection in the event of an infringement of your rights.

These rights are exercised by a written request to the Company (in person, electronically or through an authorised representative). The Company responds within 14 days of the request being submitted, or within 30 days where more time is required. The forms (declaration, access request, requests for rectification/erasure/restriction/portability, objection, complaint) are annexed to the full text of the policy — they are not mandatory and you may submit a request in any form that identifies you as the data holder.

Supervisory authority and complaints

The competent supervisory authority is the Commission for Personal Data Protection (CPDP):

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This page presents the main content of the policy. The full official text, together with the annexed forms, is available in the PDF above and free of charge on paper at the Company's office.