Fund – Privacy Notice

This Privacy Notice fulfills the information duty towards the registered persons required by Articles 13 and 14 in the EU General Data Protection Regulation.


PYN Fund Management Ltd (later ”PYN”)
Address: PL 139, 00101 Helsinki (Mannerheiminaukio 1 E)
Phone: 09-270 70 400
Contact person: Eino Laitinen

Name of the filing system

The name of the filing system is Fund Unit Filing System

Publicity of the filing system

The data in the register are not public.

Purpose of personal data processing and legal basis for processing

The legal basis for the processing of personal data is to meet the requirements of legislation as well as the duties that are based on authorities’ regulations and guidelines, such as duties concerning preventing money laundering and terrorist financing, duty to identify and verify the customer and reportage and risk management. In addition, the purposes of processing are customer service, communication and customer relationship management and business development.

The processing of personal data is based on the consent given by the data subject or when it comes to direct marketing, the processing of personal data is based on the controller’s legitimate interest (Article 6 General Data Protection Regulation) to do direct marketing. PYN does not process personal data in automated decision-making.

Data content of the filing system

The filing system that is maintained by PYN contains following categories of personal data of PYN Elite Fund (non-UCITS)’s unit holders:

Know Your Customer information

Name, personal identity code, birth date, birth place, nationalities. The controller has the duty to gather and document the Know Your Customer information, for instance by taking a photocopy of a passport, driver’s license or some other similar document. It is also possible to receive Know Your Customer information via Tupas Identification.

Contacting information

Phone numbers, addresses (including postal address), email addresses, country of residence and banking information.

Customer relationship and fund investment information

Information on investment account, transactions, reportage and information needed to classify a person and role.

Information based on statutory requirements

Country of taxation or foreign Tax Identification Number and information concerning the duty to Know Your Customer and preventing money laundering.

Regular data sources

Registering is based on data received from the data subject, his or her contact person or agent. In addition, PYN uses public registers maintained by the authorities and the credit information register to gather data as well as other reliable public sources as needed.

Regular discloses of data and transferring data to third countries

The data will be disclosed in the situations required by legislation’s and authorities’ (for example Financial Supervisory Authority, Tax Administration, the Police and enforcement authority) orders. The data won’t be disclosed to a third party without the data subject’s own consent.

The data won’t be transferred to third countries or international organisation.

Protection principles regarding the filing system

Protecting personal data is part of PYN’s data protection and risk management. The controller has adequate technical, organisational and administrative security procedures in use with which we protect all data in our possession against loss, misuse, unauthorised use, disclosure, changes and destruction.

Right to inspect 

The data subject has the right to inspect the data concerning him or her that is stored in the filing system. In addition, having submitted sufficiently precise and individualised request, he or she has the right to receive data concerning the data subject and documents’ data. The request should be delivered in written form and signed to the following address: PYN Fund Management Ltd, PL 139, 00101 Helsinki or

The right to require the rectification and erasure of data 

The controller shall rectify the inaccurate data indicated by the data subject in the filing system. In addition, the controller has a duty to independently inspect the accuracy of data and the fact that data is up-to-date in the filing system. The data subject has also the right to obtain from the controller erasure of the personal data concerning him or her in the filing system.

Other rights regarding processing personal data

The data subject has the right to request from the controller restriction of processing the personal data. The data subject has also the right to receive the personal data concerning him or her, which he or she has provided to the controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller. In addition, the data subject is entitled to object to the processing of data, automated decision-making and profiling to the extent that the measurements are not required by law. Where the processing of personal data is based on the consent given by the data subject, the data subject has the right to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. The data subject has the right to lodge a complaint with a supervisory authority.

Informing the data subjects

Privacy Notice is available from the controller and the controller’s website.

Erasure of data and storage period

The data will be deleted from the fund unit systems once legislation does not require else and the data are not necessary regarding business development. For instance, the Know Your Customer information that are in Fund Unit Filing System due to money laundering legislation, will be retained for five years after the customer relationship has terminated. The controller will also delete data subject’s data from the filing system if the data subject obtains from the controller the erasure of personal data based on law.

The data won’t be deleted if it is determined in the law differently or the competent authority has started a process that obliges the controller to retain data or other person has applied for precautionary measures regarding data from the court of Finland.

Approval of Privacy Notice

Privacy Notice has been approved continuously and been inspected May 24, 2018.