Legal note

The materials relating to the funds offered by the Company, published on website pages in the generali-investments.pl domain, are for information or advertising purposes and do not constitute an agreement or an information document required by law. They are not an offer as defined in Article 66 of the Polish Civil Code, an investment advisory service or a recommendation on financial instruments, nor are they information recommending or suggesting an investment strategy or an investment recommendation referred to in Article 3(1)(34) and (35) of Regulation (EU) No. 596/2014 of the European Parliament and of the Council on Market Abuse, nor are they any form of financial, tax or legal advice.

The information provided in the materials is not sufficient to make an investment decision and assess risks associated with investing in mutual funds. Before making final investment decisions, please first read the Key Information Document (KID) and, in the case of SFIO and FIZ, the Alternative Investment Fund Client Information Document, and the Prospectus to learn more about the investment policy, risk factors, investment fund unit disposal, unit holder rights, fund fees, and applicable taxes. You may find them in our office or on our website: www.generali-investments.pl. Navigate to “Documents”: https://www.generali-investments.pl/contents/pl/klient-indywidualny/dokumenty, and then go to one of the following tabs: “Funds’ Prospectuses,” “KID,” “Documents and Terms and Conditions”. All the documents are in Polish. Individual sub-funds’ investment risks are described in sections Description of risks associated with investing in Sub-fund Units, including risks pertaining to the adopted investment policy of the Sub-fund, and Description of investment risks associated with holding units in a Sub-fund. Unit holders’ rights are specified in the Prospectus in section Concise description of Unit Holders’ rights.

Neither the Company nor the investment funds guarantee that investment goals will be achieved. By investing in sub-funds, you purchase units (shares in these sub-funds) and not the underlying assets invested in by such sub-fund. No investment is risk-free. Unit holders need to be prepared for a possible decrease in or a loss of all or part of the invested funds. The individual return on investment is not the same as the sub-fund’s investment performance and depends on the value of the unit at the time of its disposal and repurchase by the sub-fund, as well as on fees and taxes applicable to the income earned on the investment. Taxes depend on the client’s individual situation and may change in the future. The financial information presented relates to a specific period in the past and the results achieved in the past do not guarantee returns on future investments. The result will differ depending on the market situation and period for which the investment is held. The presented results are exclusive of a given sub-fund’s fees and taxes.

Depending on the adopted investment policy, sub-funds may invest assets in securities, money market instruments, and other investment categories; additionally, given the composition of the portfolio and the adopted management strategy, the unit value may be subject to moderate, high or very high volatility. High volatility of the net asset value of: 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 and Generali Obligacje Aktywny, Generali Obligacje Globalne Rynki Wschodzące, Generali Złota, Generali Euro, Generali Akcji Ekologicznych Globalny, Generali Akcji: Lifestyles, Generali Akcji Ekologicznych Europejski in Generali Fundusze SFIO.

There is a possibility to invest more than 35% of asset value of Generali Korona Dochodowy, Generali Korona Obligacje, Generali Stabilny Wzrost, Generali Korona Zrównoważony, Generali Złota, Generali Aktywny Dochodowy, SGB Dłużny, Generali Akcji: Lifestyles in securities issued, backed or guaranteed by the Polish Treasury or the National Bank of Poland, and in the case of Generali Dolar, Generali Konserwatywny, Generali Surowców, Generali Akcji: Megatrendy and Generali Oszczędnościowy also in securities issued, backed or guaranteed by: Australia, Austria, Belgium, Bulgaria, Canada, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Great Britain, Greece, Hungary, Ireland, Iceland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, South Korea, Spain, Sweden, Switzerland, Turkey, United States of America, as well as the European Investment Bank and the World Bank (The International Bank for Reconstruction and Development), and, in the case of SGB Bankowy, in securities issued by the Polish Treasury, the National Bank of Poland, a local authority, a Member State, a local authority of a Member State, an OECD country or an international financial institution of which the Republic of Poland or at least one Member State is a member.

The materials have been prepared by the Company with due diligence and to the best of the author’s knowledge, and they are based on the author’s judgment at the time of writing and then applicable legal, tax and factual situation, which is subject to change without prior notice. The materials are based on own sources (www.generali-investments.pl) and publicly available information. The Company assumes no liability for any adverse effects the use of the content of these materials might have. The Company is the sole owner of any copyrights thereto. The materials, or any part thereof, may not be copied, published or otherwise disseminated without the Company’s prior consent.

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 my data be retained?

Personal data will be retained for the period permitted by law and will be erased after that time. Due to the varied nature of cookies, the time after which your data will be erased may vary depending on the type of cookies. In case of an investigation and defense of claims, the retention period of your data may be further extended.

3. How does Generali Investments TFI SA use cookies?

When providing content within this website (“Website”), Generali Investments TFI SA uses cookies, i.e. IT data, in particular text files, which are stored on the Website user’s end device and intended for using Website pages. They usually contain the name of the webpage from which they originate, their storage time on the end device and a unique number.

Cookies are used to:

• adapt the content of Website pages to user’s preferences and optimize the use of webpages; in particular, those files allow to recognize the Website user’s device and properly display the webpage, tailored to the user’s individual needs;
• produce statistics that help to understand how Website users use webpages, which allows improving their structure and content;
• maintain the Website user’s session (after logging in), due to which the user does not have to re-enter the login and password on every subpage;
• provide users with advertising content more tailored to their interests.

The Website uses two main types of cookies: session cookies and persistent cookies. Session cookies are temporary files stored in the user’s end device until logging out, leaving the webpage or disabling the software (web browser). Persistent cookies are stored in the user’s end device for a definite time specified in the cookies parameters or until removed by the user.

The following types of cookies are used in the Website:

• “necessary” cookies - contribute to the usability of the Website by enabling basic functions such as navigation on the Website and access to secure areas of the Website. The website cannot function properly without these cookies;
• “preference” cookies - allow the Website to remember information that changes the appearance or functioning, such as the preferred language or the region in which the user is located;
• “statistical” cookies - help us understand how different users behave on the webpage by collecting and reporting anonymous information;
• “marketing” cookies - allow to display advertisements that are more tailored, relevant and interesting for individual users;
• “unclassified” cookies - these are files that are in the process of being classified together with the providers of individual cookies or do not fall into any of the categories listed above.

In many cases, the software used for browsing websites (web browser) allows cookies to be stored in the user’s end device by default. Website users can change their cookie settings at any time. These settings can be changed in particular in such a way as to block the automatic handling of cookies in the web browser’s settings or inform about each placement of cookies on the Website user’s device. Specific information about the possibilities and ways of handling cookies is available in the software (web browser) settings.

The Website operator informs that restrictions on the use of cookies may affect certain functionalities available on the Website pages.

Cookies are placed on the Website user’s end device and may also be used by advertisers and partners cooperating with the Website operator.

4. May the Cookie Policy change?
Generali Investments TFI S.A. reserves the right to change the above Cookie Policy by publishing a new Cookie Policy on this page.

5. How may I contact the data controller?
The data controller may be contacted at: rodo-tfi@generali.pl.

2. The data protection officer may be contacted in writing: at the Company’s address provided above, or electronically: at rodo-tfi@generali.pl.

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

• the conclusion and performance of an agreement to which the data subject is a party, or taking of actions at the request of the data subject before the conclusion of an agreement, pursuant to 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”),
• the compliance with legal obligations to which the data controller is subject pursuant to Article 6(1)(c) of the GDPR, arising under the Act of 27 May 2004 on investment funds and on managing alternative investment funds (“Funds Act”), the Act of 1 March 2018 on counteracting money laundering and terrorist financing (“AML Act”), the Act of 9 October 2015 on implementation of the Agreement between the Government of the United States of America and the Government of the Republic of Poland to improve international tax compliance and to implement FATCA (“FATCA Act”), and the Act of 9 March 2017 on exchange of tax information with other states (“CRS Act”),
• the purposes of legitimate interests pursued by the data controller or by a third party pursuant to Article 6(1)(f) of the GDPR, which, according to the controller, include in particular: direct marketing, assertion and defense of claims, fraud prevention, running statistics and performing analyses, ensuring security of the ICT environment, use of internal control systems, as well AML/CTF procedures, also within the structures of Generali Group,
• where marketing consents have been given, the personal data will 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 register of unit holders of the Fund(s), custodian, distributors of the participation units or investment certificates, entities providing advisory, audit, accounting, IT, document archiving and document destruction services, or marketing services, as well as statutory auditors (in connection with an audit), and entities from the Generali Group.

LIST OF THE GENERALI GROUP COMPANIES

5. 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 the 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 on the place where such information is made available.

6. The length of the period of retention of your personal data by us depends on the purpose of the processing and the regulations that form the legal basis for the processing. We will retain your data:

• where the processing is based on consent – until withdrawal of the consent;
• where the processing is based on an agreement – until the statute of limitations for contractual claims;
• where the processing is based on our legal obligation – for the period resulting from the regulations governing our obligation to process data;
• where the processing is based on a legitimate interest and/or entitlement under law – for a period allowing to exercise that interest and/or entitlement or until effective objection to the processing has been raised.

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 with the Register of Companies for Venezia Giulia under number 00079760328, with share capital of EUR 1,569,773,403.00, paid up in full, being the holding company of the Generali Group, and other companies of the Generali Group may act as the joint data controller with respect to the exchange of data as part of procedures aimed at counteracting money laundering and terrorist financing. The list of the Generali Group companies and the main contents of arrangements on joint data control are available at: https://generali-investments.pl/files/plik/8180/Lista_spolek.pdf.

9 The provision of personal data entitles the data subject to:

• request access to the personal data, rectify, erase or restrict its processing, and transfer the personal data,
• object to the processing of personal data on grounds related to the specific situation of the data subject, where the processing is based on Article 6(1)(f) of the GDPR, i.e. the processing is necessary for the purposes resulting from legitimate interests pursued by the data controller or a third party,
• withdraw consent (where the legal basis for processing is consent) at any time. The withdrawal of your consent will not, however, affect the lawfulness of processing made before its withdrawal, lodge a complaint with a supervisory authority, i.e.: the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warszawa.

10. 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. Failure to provide the data will result in the refusal to conclude a fund participation agreement, in the non-performance of a transaction with the Fund, or in the termination of a previously concluded agreement.

11. Provision of data for marketing purposes is not a statutory or contractual requirement or a condition for concluding an agreement. The provision of data for marketing purposes is voluntary.

12. Where marketing consents have been given, you have the 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 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 concluding an agreement based on the criteria set (geographical, behavioral, subject-related and economic ones). As a consequence of such an assessment, you may be automatically assigned to an unacceptable risk group, which may result in an automatic blockade and a decision not to enter into a relationship or not to make a transaction.