Privacy Policy

This Privacy Policy explains how Janus Capital Partners AIFP, SIA processes your Personal Data when you use our Website and services, and describes your rights under the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and Latvian data protection law.

1. Data Controller
The data controller responsible for your Personal Data is:
Janus Capital Partners AIFP, SIA
Dzelzavas iela 76–149, Rīga, LV-1082, Latvia
Email: info@januscapital.fund
For all privacy matters, including to exercise your rights, contact us at the address above marked "Data Protection".

2. Definitions
"Personal Data" means any information relating to an identified or identifiable natural person. "Processing" means any operation performed on Personal Data. "You" means the individual whose Personal Data we process. Other capitalised terms have the meaning given to them in this Policy.

3. Categories of Personal Data we process
Depending on your relationship with us, we may process:

Identity and contact data: first and last name, email address, telephone number, postal address, date of birth, nationality.
Verification and regulatory data (where you are or seek to become an investor): identity documents, tax identification, source of funds/wealth information, and other KYC/AML data we are legally required to collect.
Usage Data: IP address, device and browser type and version, pages visited, dates/times and duration of visits, unique device identifiers and diagnostic data.
Cookie and tracking data as described in Section 8.
We collect Personal Data directly from you, automatically through your use of the Website, and, where applicable, from third parties such as identity-verification and sanctions/PEP-screening providers.

4. Purposes and legal bases (Art. 6 GDPR)
We process Personal Data only where a lawful basis applies:

Purpose	Legal basis
Provide, maintain and secure the Service; manage your account	Performance of a contract (Art. 6(1)(b)); our legitimate interest in Service security (Art. 6(1)(f))
Perform a contract with you and process transactions	Performance of a contract (Art. 6(1)(b))
KYC/AML, sanctions screening, regulatory and tax reporting	Compliance with a legal obligation (Art. 6(1)(c)); for special categories, Art. 9(2)(g) where applicable
Respond to your requests and provide support	Contract (Art. 6(1)(b)) and legitimate interests (Art. 6(1)(f))
Direct marketing of similar products to existing clients	Legitimate interests (Art. 6(1)(f)), subject to your absolute right to object
Other marketing / non-essential cookies	Your consent (Art. 6(1)(a))
Analytics and Service improvement	Consent for non-essential cookies (Art. 6(1)(a)); otherwise legitimate interests (Art. 6(1)(f))
Business transfers, legal claims, fraud prevention	Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c))

Where we rely on legitimate interests, we have carried out a balancing assessment and you may request information about it. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

5. We do not rely on bundled or implied consent
We do not treat your mere use of the Website as consent. Any consent we rely on is collected through a separate, specific, affirmative action.

6. Automated decision-making and profiling
We do not make decisions producing legal or similarly significant effects about you based solely on automated processing. Any automated screening (e.g. sanctions/PEP checks) is subject to human review. If this changes, we will inform you and provide the safeguards required by Art. 22 GDPR.

7. Recipients and disclosures
We disclose Personal Data only as necessary, to: service providers acting as processors under written data-processing agreements (hosting, analytics, identity verification, communications); our affiliates under common control, bound by this Policy; competent authorities, regulators, courts and tax authorities where legally required; and acquirers or their advisers in a merger, acquisition or asset sale, with prior notice to you. We do not sell your Personal Data.

8. Cookies and tracking
We use strictly necessary cookies without consent. All non-essential cookies (analytics, functionality, advertising) are set only with your prior consent through our cookie banner, and you may withdraw or change consent at any time via the banner or your browser settings. Withdrawal does not affect prior lawful processing.

9. International transfers (Ch. V GDPR)
Where we transfer Personal Data outside the EEA, we ensure an adequate level of protection through an adequacy decision of the European Commission, or the Standard Contractual Clauses, together with any supplementary measures required. You may request a copy of the relevant safeguard by contacting us.

10. Retention
We retain Personal Data only as long as necessary for the purposes above and applicable law. Indicatively:

Account data: for the account relationship plus up to 24 months after closure.
Support/chat records: up to 24 months from closure.
Usage/server logs: up to 24 months from collection.
KYC/AML and regulatory records: for the period required by anti-money-laundering and financial law (generally 5 years, extendable where legally mandated).
On expiry we securely delete or anonymise Personal Data; residual encrypted backup copies are deleted on our routine backup cycle.

11. Your rights (Arts. 15–22, 77 GDPR)
You have the right to: access your Personal Data; rectify inaccurate data; erase data ("right to be forgotten"); restrict processing; data portability; object to processing based on legitimate interests, and to object to direct marketing at any time with no exception; withdraw consent at any time; and not be subject to solely automated decisions with significant effects. To exercise any right, contact us using Section 1. We respond within one month (extendable by two months for complex requests) and do not charge unless requests are manifestly unfounded or excessive. Some rights are limited where we must retain data to meet legal obligations (e.g. AML records).

12. Right to lodge a complaint
If you believe we have infringed your data protection rights, you may complain to the Latvian supervisory authority:
Datu valsts inspekcija (Data State Inspectorate), Elijas iela 17, Rīga, LV-1050, Latvia — www.dvi.gov.lv — pasts@dvi.gov.lv. You may also complain to the authority in your EU country of residence.

13. Security and breaches
We apply appropriate technical and organisational measures to protect Personal Data. In the event of a personal data breach likely to result in a risk to your rights, we will notify the supervisory authority within 72 hours and affected individuals without undue delay where required by Arts. 33–34 GDPR.

14. Children
The Service is not directed to persons under 16, and we do not knowingly collect their Personal Data. If you believe a child has provided us data, contact us and we will delete it.

15. Links to other websites
We are not responsible for the privacy practices of third-party sites linked from our Service. Review their policies before providing data.

16. Changes to this Policy
We may update this Policy and will post changes here, updating the "Last updated" date, and notify you by email or a prominent Website notice before material changes take effect.

17. Contact
Janus Capital Partners AIFP, SIA — info@januscapital.fund — Dzelzavas iela 76–149, Rīga, LV-1082, Latvia.