Data Protection

The data controller is the natural person or legal entity that determines the purposes and means by which your personal data are processed.

In general, the data controller will be March, Asset Management, S.G.I.I.C., S.A.U. (“March A.M.”), with tax number A-82734807 and registered office at calle de Castelló, nº 74 (Madrid 28006), Spain, for most of the data processing activity. However, March A.M., as an entity belonging to the Banca March Group, may act as joint controller for certain data processing activities together with the other Group companies, deciding jointly on the objectives and means used for the processing of your personal data.

In the appendix to this section, you will find the list of entities that belong to the Banca March Group, of which March A.M. is a member. These entities may process your personal data, depending on the service provided to you.

However, as a result of the services to be provided under the framework of our relationship with our customers, situations may arise in which other entities (third-party service providers) act as data controllers alongside March A.M. An example of this joint controller relationship would be the case of couriers, which decide on the means and purposes of the processing in order to provide a certain service.

Data that the customer, have provided to us directly or to your sales representative when entering into contracts or during your relationship with us.

• Identification and contact data (including postal and email addresses).
• Sociodemographic data, such as nationality.
• Details of your professional or occupational activity and socio-economic status.

We process your personal data for various purposes and on various lawful bases. Notably:

Processing related to the execution of your orders at March A.M.:

• To manage the funds of customers delivered by the marketing companies.
• To manage any complaints, claims or suggestions that customers may raise in relation to the performance of the contract signed between them and March A.M.

Processing necessary to comply with our legal obligations:

• March A.M. shall process your data in order to comply with its legal obligations in relation to the prevention of fraud and the financing of terrorism, as set forth in the Law of 28 April 2010, on anti-money laundering and counter terrorist financing, and related regulations, in order to carry out formally identify those parties who apply for, or are otherwise involved in, our products, and to identify their professional or business activities.
• To comply with the obligations imposed, inter alia, by Law 35/2003 of 4 November 2003, on collective investment schemes, and its implementing regulations, by Law 22/2014 of 12 November 2014, on venture capital entities.
• To comply all pertinent legal obligations, including the management of withholding taxes based on you are located for tax purposes.
• To comply with the legal obligations arising from the CRS (Common Reporting Standard) and FATCA (Foreign Account Tax Compliance Act), under which we must deliver annual financial information on foreign customers who meet certain requirements. The main objective of this obligation is to prevent tax evasion.
• To send you periodic information, which will be sent, in the first instance, via electronic channels, preferably email. If we do not have your address, we will request it from Banca March, S.A. so that we may send it to you.

Processing based on the legitimate interest of March, A.M.:

• March A.M. will process your personal data in order to satisfy its legitimate interests and to send you commercial communications, promotions and information related to the products offered by the management company, insofar as you, as a customer, have not objected to this processing through the various channels at your disposal.

Data processing based on the customer's express consent.

All the Personal Data that March, A. M., processes of its clients are those data provided by the potential client requesting information through the web or by its marketers, which are delivered on the occasion of the formalisation of the contracting of a product or service, either through the bank's web, the call centre or the different offices of Banca March, Allfunds and Abanca.

Investors' data will be collected mainly through the digital channels set up with the different marketers established for this purpose.

Furthermore, Banca March may obtain Personal Data from:

• La Agencia Tributaria (Tax Agency.)
• Banca March, S. A.
• Allfunds, S. A.
• Abanca, S. A.

The Personal Data to which we have access will be processed as long as you maintain the corresponding contractual relationship with us. Once this relationship has ended, March A. M., will keep the personal data, duly blocked, to be made available to the competent Public Administrations, Judges and Courts or the Public Prosecutor's Office during the period of prescription of the actions that could derive from the relationship maintained and/or the periods of conservation legally established. Once this period has elapsed, we will proceed to the physical deletion of your Personal Data.

In the case of SICAVs, they will act the controllers of the personal data relating of the shareholders, proxies, representatives, contact persons for specific contracts and members of the board of directors. In order to fulfil its duties, the SICAV shall process identification and contact data, mainly for the purpose of managing the relationship with you as a shareholder, proxy, representative or member of the board of directors.

In this case, we will process your personal for various purposes and on different lawful bases. Thus, we will process you data on the basis of:

• Compliance with our legal obligations under, among other laws, Law 35/2003, of 4 November, on collective investment schemes, or Royal Decree 1/2010, of 2 July, approving the revised text of the Capital Companies Act, as well as the corresponding implementing regulations.
• The contractual and/or corporate relationship we maintain with you or the entity you represent.

We will retain your data over the duration of your relationship with the SICAV. Once this relationship ends, we will retain your data for a further period of ten years, whereupon your data will be destroyed.

The accessible personal data will be processed as long as the contractual relationship remains in place. To this end, there are certain rules that require that March A.M. store documentation for a period of time. March A.M. , pursuant to the obligation set out in the Law on Anti-Money Laundering and Counter Terrorist Financing will store personal data for a period of 10 years following the termination of the business relationship.

As a general rule, March A.M. will not pass on your personal data to third parties, unless, by legal obligation, it is necessary in order to provide the product or service arranged, or we are legally obliged to do so.

March A.M. may communicate the data of its clients to:

• Public authorities and institutions of the General State Administration, or of regional or local administrations, including any courts to which it is under the legal obligation to disclose the data.
• National and international tax authorities.
• Supervisory authorities in the finance industry in order to comply with legal obligations.
• If you, as the client, request a transfer after arranging other products and this entails communication with a third-party entity, the data will be transferred to that entity according to the client's request. In these cases, March A.M. will communicate the personal data of the subject concerned to the management or marketing entity of the destination collective investment scheme to which you have requested the transfer.
• For administrative purposes and to prevent fraudulent conduct, customer data may be sent to other Banca March Group companies, third-party companies or centralised information systems.
• With your consent, the data may be sent to the different companies belonging to the Banca March Group, investee companies and external partners.
• External service providers who may access the personal data of customers to provide their services, including, without limitation, lawyers, solicitors, auditors, or providers of consultancy services, advisory services, IT maintenance and development, physical security, video surveillance, administrative services and document destruction. March A.M. pre-selects these suppliers based on their compliance with data protection regulations and has entered into specific contracts in relation to this matter to ensure that they comply with their obligations.
• Administration and management services for digital platforms.

The personal data of March A.M. customers may be transferred to suppliers located in third countries for the provision of certain services associated with the performance of their contracts. In any case, prior to such transfers, March A.M. shall take all necessary safeguards to ensure that the conditions affecting these transfers are adequate.

In particular, and depending on the processing activity and third country concerned, March A.M. shall adopt one or more of the following safeguards:

• Standard data protection clauses (of those typically applied);
• Binding corporate rules;
• Codes of conduct;
• Certification mechanisms.

The customer can exercise their rights of access, rectification and erasure and limitation of processing, opposing the processing of their data or requesting the portability of their data through Banca March's Customer Service.

If a customer believes that their data protection rights have been infringed or if they have any complaints about their personal information, they may contact the Data Protection Officer of Banca March at the following email address dpo@bancamarch.es. Data subjects can also contact the Spanish Data Protection Agency, the data protection control authority. Calle Jorge Juan, 6, 28001, Madrid. Tel.: 901 100 099 / 912 663 517.

The Banca March Group is divided between the two activities it performs. Firstly, banking activities, in addition to insurance and the management of collective investment schemes; secondly, investment activities, dedicated to investing in industrial holdings.

Banca March S.A., the parent company, has been undertaking the Group's banking activity since 1926.

The insurance business is delivered through March Risk Solutions and March Vida, S.A. de Seguros y Reaseguros. The management of collective investment undertakings is delivered through March Asset Management, S.G.I.I.C., S.A.U. and March Gestión de Pensiones, S.G.F.P., S.A. respectively. The Group also has a risk capital management company under the name of March Private Equity, S.G.E.I.C., S.A.

Furthermore, Banca March, S.A. holds 100% of the shares in Banco Inversis, S.A., a leader in the Spanish financial system, specialising in the provision of investment services related to the execution, safekeeping and settlement of securities (including investment funds), the administration and depositary of collective investment schemes and pension funds and the distribution of investment funds for the main international managers through its fund platform.