This Privacy Policy (the “Policy”) provides information on how UAB Alpha Asset Management, legal entity code 306190748, with its registered office at Lvivo g. 25-702, LT-09320 Vilnius, Lithuania, email: info@aam.lt (hereinafter referred to as “Alpha Asset Management”, “we”, “us”, or the “Company”), processes the personal data of clients and other data subjects, as well as information regarding the exercise of data subjects’ rights.
Alpha Asset Management processes personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (the General Data Protection Regulation, “GDPR”), the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other applicable legal acts.
This Policy may be updated from time to time to reflect changes in legal requirements or in the services provided by the Company. The latest version of the Policy is available on our website at www.aam.lt.
Additional information regarding the processing of clients’ personal data may be provided in agreements and other documents relating to the Company’s services, as well as on the Company’s website at www.aam.lt.
This Privacy Policy explains how we process your personal data and the personal data of our other clients, including what personal data we collect and process, how we obtain it, for what purposes we use it, to whom it may be disclosed, how we ensure its security, and how we protect your right to privacy.
Please note that this Privacy Policy applies solely to the activities of Alpha Asset Management. Alpha Asset Management is not responsible for any data provided when visiting third-party websites or interacting with other companies or organisations.
Data Controller – UAB Alpha Asset Management, a management company engaged in the management of collective investment undertakings intended for informed investors.
Client, Data Subject, or You – a natural person whose personal data is processed by the Company, including a prospective, current, or former client, any other person related to our services, representatives of such persons, as well as individuals visiting the Company’s website or otherwise expressing interest in the Company’s services.
Personal Data – any information relating directly or indirectly to a Client whose identity can be established.
Processing of Personal Data – any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation or alteration, consultation, use, disclosure, and other forms of processing.
Services – the products and services provided by us.
Performance of a Contract – the processing of your personal data necessary for the performance of a contract entered into between you and us (for example, to provide services to you) or in order to take steps at your request prior to entering into such a contract.
Legal Obligations – the processing of your personal data where necessary for compliance with legal obligations to which we are subject (for example, responding to court orders, regulatory requests, or fulfilling statutory requirements).
ersonal data is necessary for the Company's business activities. The Company processes personal data lawfully, fairly, and transparently in relation to the data subject, solely for specified, explicit, and legitimate purposes. Personal data is not processed in a manner incompatible with those purposes. The amount of personal data processed is adequate, relevant, and limited to what is necessary for achieving the purposes for which it is collected. Personal data is retained in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the data is processed.
The Company processes personal data for the following purposes:
Conclusion of Contracts and Pre-Contractual Measures
For the purpose of entering into agreements with prospective clients and/or taking steps prior to entering into a contract (including customer identification and verification), the Company processes identification data, financial information, contact details, and other information provided by the data subject.
Performance of Contracts
For the purpose of performing contractual obligations, the Company processes identification data, financial information, contact details, and other personal data provided by the Client, submitted on the Client’s behalf, or generated by the Company while providing services to the Client.
Responding to Enquiries
For the purpose of responding to enquiries submitted through our website or other communication channels, the Company processes identification and contact data, as well as any other information provided by the Client, submitted on the Client’s behalf, or generated by the Company in connection with the provision of services.
Communication Management
For the purpose of ensuring accurate responses to enquiries and maintaining records of correspondence, the Company processes the contact details of the person submitting the enquiry (such as email address and telephone number), name, surname, and any other information provided. Where additional documents are submitted together with an enquiry, the Company may review such documents to provide a complete response. We recommend that you do not provide information that is not necessary for handling your enquiry. If additional information is required, a representative of the Company will contact you and specify what information is needed.
Compliance with Legal Obligations
The Company processes personal data where necessary to comply with legal obligations, including responding to court orders, requests from competent authorities, and other applicable legal requirements.
Communication Through Social Media
When you contact us through third-party social media platforms (such as LinkedIn, Meta, or other social networks) or use social media functionalities integrated into our website, you may grant us access to certain information associated with your social media account, including your name, email address, profile picture, gender, date of birth, messages, or liked pages.
If you publish information while interacting with us through social media platforms or social media integrations, such information may become publicly available on the internet depending on your selected privacy settings. Certain social media platforms allow you to control what information is publicly visible. For more information on managing your privacy settings and understanding how third-party social media platforms process your personal information, please refer to the relevant privacy policies and terms of use of those platforms.
The Company processes your personal data only where there is a lawful basis for doing so, including the following:
• Performance of a Contract – where processing is necessary for the performance of a contract to which the Client is a party, or in order to take steps at your request prior to entering into a contract.
• Legitimate Interests – where processing is necessary for the purposes of the Company's legitimate interests, provided that such interests are not overridden by your interests, fundamental rights, and freedoms. For example, we may use personal information provided by our Clients in connection with the delivery and improvement of our services, where such processing is not strictly necessary for the performance of a contract.
• Compliance with Legal Obligations – where processing is necessary for compliance with legal obligations applicable to the Company, including accounting, tax, anti-money laundering, regulatory, and reporting requirements, or where we are required to provide information to courts, supervisory authorities, or other competent institutions.
• Consent – in limited circumstances, we process personal data based on your consent, for example when we are required to obtain your consent in order to send you marketing communications.
We process only such personal data as is necessary to achieve the purposes described in this Privacy Policy. If you provide inaccurate, incomplete, or insufficient information, we may be unable to provide our services properly or fulfil our legal and contractual obligations.
We generally collect personal data directly from the data subject when personal data is provided to the Company (either directly or through the Company's partners), as well as from public authorities, official registers, and other lawful sources, to the extent necessary to achieve the purposes described in this Privacy Policy.
The sources of personal data may vary depending on the purpose for which the Company processes the data. However, in all cases, we adhere to the principle of data minimisation and collect only such personal data as is necessary for the relevant purpose.
When processing personal data, we always comply with applicable confidentiality obligations. Such obligations arise under the GDPR, the Civil Code of the Republic of Lithuania, the Law on Legal Protection of Personal Data, and other applicable legislation. Personal data may only be disclosed to third parties where permitted by law, where there is a valid legal basis for such disclosure, and only to the extent necessary for the relevant purpose.
Where a data processor acts on behalf of the Company, we take all necessary measures to ensure that the processor has implemented appropriate technical and organisational security measures and maintains the confidentiality of personal data.
Sources of Personal Data
Personal data may be obtained from the following sources:
• Directly from the data subject, when you contact the Company regarding our services, become our client, submit information electronically, or otherwise provide information to us.
• From third parties, public registers, and other lawful sources, where permitted by applicable law, including government registers, public authorities, institutions, other legal entities, and similar sources.
Disclosure of Personal Data
The Company may disclose and/or transfer your personal data only in compliance with applicable legal requirements and confidentiality obligations to the following categories of recipients:
• Business partners and service providers involved in the provision of our products and services, such as custodians, banks, and similar institutions. These entities generally act as independent data controllers and are responsible for compliance with applicable data protection requirements. We encourage you to review their respective privacy policies.
• Professional service providers and business partners, including IT service providers maintaining our systems, accounting service providers, and similar contractors. Such providers are contractually required to process personal data only to the extent necessary to provide services on our behalf or comply with legal requirements. They are obligated to maintain appropriate security measures and may process personal data only for the purposes for which it was collected.
• Public authorities and other third parties, where disclosure is required by law or is necessary for the performance of a contract to which the data subject is a party, including tax authorities, supervisory authorities, and regulatory bodies such as the Bank of Lithuania.
• Law enforcement authorities, courts, bailiffs, notaries, and other competent institutions, where disclosure is required by applicable laws or official requests, including in connection with investigations, legal proceedings, or regulatory requirements.
• Other recipients authorised by the Client or otherwise entitled to receive personal data on a lawful basis, including banks, financial institutions, or other parties involved in transactions or contractual arrangements relating to the Client.
Children's Privacy
We do not provide our services directly to individuals under the age of 18 and do not knowingly collect personal data directly from persons under the age of 18.
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or for such period as required by applicable laws and regulations.
The retention period applicable to personal data depends on the nature of the contractual relationship, the Company's legitimate interests, and/or legal requirements, including statutory limitation periods, civil law provisions, accounting and tax regulations, and other applicable legal obligations.
Where the laws of the Republic of Lithuania do not prescribe a specific retention period for personal data, the Company will determine an appropriate retention period based on the legitimate purpose of processing, the applicable legal basis, and the principles governing the lawful processing of personal data.
Once personal data is no longer required for the purposes for which it was collected, and where there is no legal obligation to retain it, the data will be securely deleted, anonymised, or otherwise disposed of in accordance with applicable legal and regulatory requirements.
As a data subject, you have the right to contact Alpha Asset Management regarding the processing of your personal data. In particular, you have the following rights:
Right to Information and Access
You have the right to obtain information about whether the Company processes your personal data and, where this is the case, to access such personal data. You may request information regarding the categories of personal data processed, the source of the data, the purposes of processing, the retention period, the recipients of the data, and other relevant information.
Please note that your right of access may be restricted where required by applicable law, the rights and freedoms of other individuals, or legitimate business and operational considerations.
Right to Rectification
You have the right to request the correction of inaccurate or incomplete personal data concerning you.
Right to Erasure ("Right to be Forgotten")
You have the right to request the deletion of some or all of your personal data where the Company no longer has a lawful basis for processing such data or where other grounds for erasure apply under applicable law.
Right to Restriction of Processing
You have the right to request the restriction of the processing of your personal data, other than storage, in certain circumstances. This right may apply, for example, where you contest the accuracy of your personal data or believe that the processing is unlawful and require the Company to verify the relevant circumstances.
Right to Data Portability
Where provided by applicable law, you have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format. You may also request that such data be transmitted directly to another data controller where technically feasible.
Right to Object and Withdraw Consent
You have the right to object to the processing of your personal data where such processing is based on the Company's legitimate interests or, where applicable, your consent.
Where the processing of personal data is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent shall not affect the lawfulness of processing carried out prior to the withdrawal of consent.
Right to Lodge a Complaint
If you believe that the processing of your personal data by the Company infringes your rights or violates applicable data protection laws, you have the right to lodge a complaint with the State Data Protection Inspectorate of the Republic of Lithuania.
For more information, please visit:
https://vdai.lrv.lt/lt/veiklos-sritys-1/skundu-nagrinejimas/
The rights described above may be exercised only upon receipt of your written request and after your identity has been duly verified by the Company.
Requests may be submitted by post or by email to: info@aam.lt.
Requests submitted electronically must be signed using a qualified electronic signature. The use of a qualified electronic signature enables the Company to properly verify your identity and ensure that any information disclosed is provided only to the person entitled to receive it.
The Company does not accept scanned copies of requests that are not signed with a qualified electronic signature. If you do not possess a qualified electronic signature, you may submit your request through other means specified in this section.
Upon receipt of your request, the Company will assess its content and determine whether your identity can be adequately verified. To ensure the security of personal data, we may request additional information or require you to identify yourself using alternative verification methods.
Requests concerning the exercise of your rights under the General Data Protection Regulation (GDPR) will be responded to within one month of receipt. Depending on the complexity of the request and the number of requests received, this period may be extended by an additional two months.
Where an extension is necessary, the Company will inform you in writing of the reasons for the delay and the expected response timeframe.
If you have any questions regarding the processing of your personal data or wish to exercise any of your rights as a data subject, you may contact us at:
Email: info@aam.lt
Postal Address:
UAB Alpha Asset Management
Legal Entity Code: 306190748
Lvivo g. 25-702
LT-09320 Vilnius
Lithuania
