Privacy Policy

Effective date: 18 August 2026

1. Who we are

Finforest Fund Usaldusfond (registry code 17461892) is an Estonian limited partnership managed by P11 Management OÜ (registry code 14576146), with its registered office at Vesivärava tn 50-301, 10152 Tallinn, Estonia (together, "we"). We are the controller of the personal data described in this policy. Contact: hello@finforest.fund.

2. What data we collect

• Contact data: when you contact us by email or WhatsApp: your name, contact details, and the content of your message.
• Investor onboarding data: if you request access to fund documentation or subscribe to the Fund: identification and eligibility information collected under the Fund's Subscription Agreement, Investor Questionnaire and AML/KYC procedures.
• Technical data: limited technical information processed when you visit this website (see the Cookie Policy).

3. Why we process it and on what legal basis

• Responding to your enquiry: legitimate interest (Art. 6(1)(f) GDPR).
• Investor eligibility assessment, onboarding and administration: performance of a contract or steps prior to entering one (Art. 6(1)(b)).
• AML/CTF, sanctions screening and regulatory obligations: legal obligation (Art. 6(1)(c)).
• Analytics cookies, where enabled: consent (Art. 6(1)(a)), which you may withdraw at any time.

4. Who receives your data

Personal data may be shared with our service providers (IT, fund administration, legal and audit advisers) under appropriate safeguards, and with supervisory or law-enforcement authorities where required by law. If you contact us via WhatsApp, your communication is also processed by WhatsApp/Meta under its own privacy terms.

5. International transfers

We do not transfer personal data outside the European Economic Area unless appropriate safeguards under Chapter V GDPR are in place (for example, when you choose to contact us via WhatsApp).

6. How long we keep it

Enquiry correspondence is retained for as long as needed to handle your enquiry and for a reasonable period thereafter. Investor and AML/KYC records are retained for the periods required by applicable Estonian law (generally at least five years after the end of the business relationship).

7. Your rights

Subject to applicable law, you have the right to access, rectify or erase your personal data, restrict or object to its processing, receive it in a portable format, and withdraw consent where processing is based on consent. To exercise these rights, contact hello@finforest.fund. You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or your local supervisory authority.

8. Changes

We may update this policy from time to time. The current version, with its effective date, is always available on this page.