Legal note

Generali Investments TFI S.A. shall not be held liable for any mistakes, inaccuracies or omissions in the aforementioned information. In the case of detection of such defects, Generali Investments TFI S.A. shall make every effort to promptly correct the information.
 
This material is distributed to advertise or promote services provided by Generali Investments TFI S.A.

Closed-end investment fund (the “Fund”) does not guarantee the achievement of the assumed investment objectives or obtaining the specified investment result. The Fund Participant has to consider the possibility of losing at least a part of the invested money.

Legally required information, including a detailed description of risks associated with investing in the closed-end investment fund, is available in the conditions of issue of the Fund’s investment certificates of a given series (the “Conditions of Issue”), which shall be communicated to persons to whom Generali Investments TFI S.A. will direct its offer regarding the purchase of the Fund’s investment certificates.

Before making a decision to subscribe for the Fund’s investment certificates, the Investor should consult the Conditions of Issue containing detailed information about the Fund’s investment policy and fees, and in particular the front load fees charged at the subscription for the Fund’s investment certificates, subject to the purchase proposal, as well as information on income taxes associated with holding and trading in the Fund’s investment certificates. 

Presented financial information concern the indicated period in the past and do not constitute a guarantee of achievement of similar results in the future.

The result presented does not include front-load fees associated with investing in a given sub-fund or taxes. Front-load fees and applicable taxes may be deducted from the result.

The Generali Euro sub-fund is denominated in EUR. Incoming and outgoing payments by way of purchase or sale of participation units in the sub-fund are made in EUR. In the event a participant intends to obtain investment returns in a currency other than EUR, the participant must take into account the fact that any returns may increase or decrease as a result of currency fluctuations.
The Generali Dolar sub-fund is denominated in USD. Incoming and outgoing payments by way of purchase or sale of participation units in the sub-fund are made in USD. In the event a participant intends to obtain investment returns in a currency other than USD, the participant must take into account the fact that any returns may increase or decrease as a result of currency fluctuations.
 
No guarantee of achievement of the objectives of the investment funds; there is a possibility of a decrease in value, including the loss of a part of the invested funds.

Due to the composition of the portfolio and the management strategy pursued, the value of the participation unit may be subject to moderate, high or very high volatility. A high volatility of the net asset value: Generali Akcje Małych i Średnich Spółek, Generali Akcje Value, Generali Akcji Rynków Wschodzących, Generali Korona Akcje, Generali Korona Zrównoważony, Generali Stabilny Wzrost, Generali Surowców, Generali Akcji: Megatrendy in Generali Fundusze FIO, Generali Obligacje Aktywny, Generali Obligacje: Globalne Rynki Wschodzące, Generali Złota, Generali Euro, Generali Akcji: Lifestyles, Generali Akcji Ekologicznych Globalny, Generali Akcji Ekologicznych Europejski in Generali Fundusze SFIO.

The possibility of the deposit more than 35% of assets of Generali Korona Dochodowy, Generali Akcji: Megatrendy, Generali Korona Obligacje, Generali Stabilny Wzrost, Generali Korona Zrównoważony, Generali Złota, Generali Aktywny Dochodowy, SGB Dłużny, Generali Akcji: Lifestyles in securities issued or guaranteed by the Polish Treasury or the Polish National Bank, and in the case of Generali Dolar, Generali Konserwatywny, Generali Surowców, Generali Akcji: Megatrendy and Generali Oszczędnościowy also in securities issued or guaranteed by: Australia, Austria, Belgium, Bulgaria, Canada, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Great Britain, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Mexico, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, South Korea, Spain, Sweden, Switzerland, Turkey, United States of America and the European Investment Bank and World Bank (The International Bank for Reconstruction and Development).

Information prospectuses, Key information documents, information for clients of AIF, tables of fees, information on investment risk and taxes are available through the website: www.generali-investments.pl. Generali Investments TFI S.A. operates under a licence from the Securities and Exchange Commission (currently: Polish Financial Supervision Authority) of 1 June 1995, no. of decision KPW-4073-1\95.

The above information has been provided in order to advertise and promote the portfolio management service, regarding portfolios comprising one or more financial instruments offered by Generali Investments TFI S.A. The information does not constitute an offer to conclude an Agreement on the management of portfolios comprising one or more financial instruments by Generali Investments TFI S.A.
Each investment strategy entails specific risk factors, described in the Agreement on the management of portfolios comprising one or more financial instruments by Generali Investments TFI S.A., and in the Information Prospectus on the provision of management services regarding financial instrument portfolios by Generali Investments TFI S.A.
Generali Investments TFI S.A. has been authorized by the Polish Securities and Exchange Commission (currently the Polish Financial Supervision Authority) to extend the scope of its activities by the management of third party’s package of securities upon request (currently: activities constituting the management of portfolios comprising one or more financial instruments). The Polish Financial Supervision Authority is not the body which has approved or endorsed the rules of the service.

2. How long will the company store my data?
Personal data will be kept for the period of: performance of the contract, fulfillment of legal obligations incumbent on the administrator, and investigation and defense against claims for the period resulting from the general limitation periods for claims, counted from the termination of participation. In the case of giving marketing consents, personal data will be kept for the period necessary to provide commercial information, no longer than until the consent's withdrawal or objection to processing for direct marketing purposes.
 

3. How does Generali Investments make use of cookies?

1. Generali Investments, while providing content within this site ("Site”), uses cookies, i.e. files with computer data, particularly text files that are stored in the Site user's end device and are intended for use of the web pages of the Site. Typically, they contain the name of the website from which they originate, storage time in the end device and a unique number.
2. The cookie files are used to:

• adapt the content of the web pages of the Site to the user's preferences, and to optimize the use of the web pages; in particular, these files make it possible to recognize the user's device and display a web page tailored to their individual needs;
• generate statistics that demonstrate how users take advantage of the Site’s web pages, to improve the Site's structure and content;
• maintain Site user's session (after logging in), so that the user does not need to retype his login and password in every page of the Site;
• provide the users with advertising content more suited to their interest.

3. In general, the Site uses two types of cookie files: session cookies and persistent cookies. Session cookies are temporary files that are stored in the user's end device until the user logs off, leaves the web page or exits the software (web browser). Persistent cookies are stored in the user’s end device for the time period defined in the cookie file parameters or until they are removed by the user.
4. The Site uses the following types of cookie files:

• "required" cookie files which allow using the services available at the Site, for example, authentication cookie files used for the services that require authentication as part of the Site;
• cookies used to ensure security, e.g. used to detect abuse of authentication within the Site;
• "performance" cookies which collect information about how the pages of the Site are used;
• "functional" cookie files which make it possible to "store" the settings selected by the user and user interface personalizations, for example, with regard to the user’s language or region or the font size, page appearance, etc.;
• "advertising" cookies, enabling delivery to users of the advertising content that is more suited to their interests.

5. In many cases, the software used to view web pages (web browser) allows storing cookies by default in the user’s end device. Users of the Site may, at any time, change the settings for cookie files. These settings can be changed, in particular in such a way as to block automatic handling of cookies in the Web browser settings or so that the Site user is notified each time about storage of a cookie file in the Site user's device. Detailed information about the options and methods of handling of cookie files is available in the settings of the software (web browser).
6. The Site's operator wishes to inform you that restrictions on the use of cookies may affect some functionalities available on the Site's web pages.
7. The cookie files stored in the Site user’s end device can also be used by advertisers and partners of the Site operator.
    

4. May the privacy policy change?
Generali Investments TFI SA reserves the right to change the above privacy policy through posting the new privacy policy on this website.
 

5. How may I contact the data administrator?
You provide us with your data voluntarily, and we use it in accordance with your will and in accordance with the purpose of their provision. In any case, if you agree on the processing of your personal data, you can correct or remove these data simply by sending us an e-mail with your request, entitled “My Personal Data”, to the following address: rodo-tfi@generali.pl.

2. the data inspector can be contacted in writing: to the address of the Company given above or electronically: to the e-mail address: rodo-tfi@generali.pl.

3. the personal data will be processed if the processing is necessary for:

• conclusion and performance of the agreement to which the data subject is a party, or to take action at the request of the data subject before concluding the agreement, based on Article 6(1)(b) of the 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, and repealing Directive 95/46/EC (“GDPR”),
• compliance with legal obligations to which the controller is subject based on Article 6(1)(c) of GDPR, arising under the Act on investment funds and on managing alternative investment funds of 27 May 2004 (hereinafter “Funds Act”), the Anti-money laundering and counter-terrorist financing act of 1 March 2018 (hereinafter “AML Act”), the Act on the performance of the Agreement between the Government of the Republic of Poland and the Government of the United States of America to Improve International Tax Compliance and to Implement FATCA of 9 October 2015 (hereinafter “FATCA Act”) and the Act on exchange of tax information with other states (CRS) of 9 March 2017, hereinafter “CRS Act”,
• the purposes of the legitimate interests pursued by the controller or by a third party on the basis of Article 6(1)(f) of GDPR, which, according to the controller, include in particular: direct marketing, pursuit and defence of claims, fraud prevention, running statistics and performing analyses, ensuring security of the ICT environment, use of internal control systems, as well as anti-money laundering and terrorism financing procedures, also within the structures of Generali Group,
• where marketing consents have been given, the personal data shall also be processed for marketing purposes, particularly for the purpose of sending information on products and services offered and for profiling. The Company is the data controller with regard to personal data processed for marketing purposes.

4. the recipients of personal data may include in particular: the transfer agent maintaining the unitholder register, custodian, distributors of the participation units, entities providing advisory, audit, accounting, IT, document archiving and destruction services, marketing services and certified auditors in connection with an audit, as well as the entities the belong to the Generali Group,

5. the personal data may be transmitted to entities with registered offices in third countries (i.e. countries outside the EEA) only in case of the existence of an adequacy decision by the European Commission or – in the absence of an adequacy decision – only if appropriate safeguards are ensured (such as standard contractual clauses approved by the European Commission or binding corporate rules approved by the competent supervisory authority). The above measures are used for the exercise of rights in regard to personal data and for ensuring effective legal protection. Upon request, the Data Controller will make available a copy of the safeguards applied or information about where they have been made available,

6. the personal data will be stored for the period of: performing the agreement, performing legal obligations to which the controller is subject, and pursuing and defending claims for a period resulting from the general periods of limitation on the validity of claims, calculated from the end of the participation,

7. if marketing consents have been given, the personal data will be stored for the period necessary to provide commercial communications, no longer than until the moment of withdrawing the consent or objecting to the processing of data for direct marketing purposes,

8. Assicurazioni Generali S.p.A. with its registered office in Trieste (Italy), Piazza Duca degli Abruzzi 2, registered in the Venezia Giulia company register under number 00079760328, with share capital of EUR 1,569,773,403.00, paid up in full, being a holding company of the Generali Group, and other companies of the Generali Group may be a co-controller of personal data in the field of data exchange within the framework of anti-money laundering and terrorist financing procedures. The list of the Generali Group companies and the main content of the data co-administration arrangements is available on the website: www.generali-investments.pl,

9 the provision of personal data entitles the person whose data is processed to:

• request access to, rectification, erasure or restriction of processing concerning personal data, as well as data portability,
• object to the processing of personal data for reasons related to particular situation of the person whose data is processed, if the basis for processing is Article 6(1)(f) of GDPR, i.e. processing is required for the purposes of the legitimate interests pursued by the data controller or a third party,
• withdraw consent to the processing of data for marketing purposes, at any time, without affecting the lawfulness of processing based on the consent before its withdrawal,
• lodge a complaint with a supervisory authority, which is: President of the Office for Personal Data Protection, Stawki 2, 00-193 Warsaw.

10. the provision of personal data is voluntary but necessary for the participation in the Fund(s) and failure to provide such data will preclude the conclusion of the agreement. The provision of the data is also a statutory requirement resulting from the Funds Act, AML Act, FATCA Act and the CRS Act. The consequence of failure to provide the data is a refusal to conclude a fund participation agreement, non-execution of a transaction with the Fund or termination of a concluded agreement,

11. the provision of data for marketing purposes is not a statutory or contractual requirement, or a precondition for the conclusion of the agreement. It is not obligated to provide the data for marketing purposes,

12. if marketing consents have been given, there is right to object at any time to the processing of data for direct marketing purposes, which includes profiling, to the extent that the processing is related to such direct marketing,

13. the processing of personal data may be automated, which may result in automated individual decision-making, including decisions based on profiling. This applies to an assessment of money laundering and terrorism financing risk, where the assessment is made on the basis of data declared in documents presented while placing an order, instruction or while entering into an agreement based on the criteria set (geographical, behavioural, subject-related and economic ones). As a consequence of such an assessment, clients may be automatically assigned to a group of unacceptable risk which may result in an automatic blockade and a decision not to enter into a relationship or not to make a transaction.