Anna Asset Management

Privacy Notice

Last updated: September 2026

This privacy notice (the "Privacy Notice") provides information about how Anna Asset Management AS and its funds under management (collectively "Controller", "we" or "us") collect and process personal data. Controller's business involves processing of personal data relating to natural persons affiliated with the companies to which Controller has a business relation, such as the investors in funds managed by Controller.

Controller and its funds under management process your personal data in accordance with the Norwegian Personal Data Act implementing the European General Data Protection Regulation (EU) 2016/679 (the "GDPR"). If you have any questions concerning our processing of personal data, please contact Controller (martin@anna.fund).

Anna Asset Management AS is the data controller as defined in the GDPR. The funds managed by Controller will also process certain personal data as independent data controllers.

If we make significant changes to our Privacy Notice or to our privacy practices, an updated version of this Privacy Notice will be made available.

Categories of personal data, purpose and legal basis

Controller will process personal data for the following purposes:

  1. For the purpose of complying with our obligations pursuant to the Norwegian Money Laundering Act, hereunder customer due diligence, confirming and verifying identity and screening against sanctions lists. Such personal data may include, but is not limited to, name, national identity number, address and proof of identity. The legal basis for this processing is the GDPR article 6 (1) letter c, whereas the processing is necessary for the purpose of compliance with legal obligations. If the processing involves special categories of personal data, the legal basis is the GDPR article 9 (2) letter g.
  2. For the purpose of complying with our obligations pursuant to the Norwegian Tax Management Act. Such personal data may include, but is not limited to, name, national identity number, citizenship, tax residence and financial information. The legal basis for this processing is the GDPR article 6 (1) letter c, whereas the processing is necessary for the purpose of compliance with legal obligations.
  3. For the purpose of complying with our obligations pursuant to the Norwegian Alternative Investment Funds Management Act, hereunder conducting "professional client" checks. Such personal data may include, but is not limited to, investment experience, financial information and information about profession and education. The legal basis for this processing is the GDPR article 6 (1) letter c, whereas the processing is necessary for the purpose of compliance with legal obligations.
  4. For the performance of contracts with the companies the natural persons are affiliated with, hereunder administering our relationship with investors. Such personal data may include, but is not limited to, contact details and information regarding the natural person's role in the company. The legal basis for this processing is the GDPR article 6 (1) letter b, whereas the processing is necessary for the performance of a contract.
  5. For the purpose of keeping you informed about the general business of Controller, including offering opportunities to invest in other funds or investment vehicles. Such personal data may include, but is not limited to, contact details and information regarding the natural person's role in the company. The legal basis for this processing is the GDPR article 6 (1) letter f, whereas the processing is necessary for the purpose of Controller's legitimate interests.
  6. Marketing of other investment products and services with your prior consent. Such personal data includes inter alia contact information, information of what services you have used and information about financial matters. The legal basis for such processing is the GDPR article 6 (1) letter a, as the processing is based on the data subject's consent.

The personal data is collected directly from the natural person, or from the companies the natural persons are affiliated with. In some cases, we may also collect personal data from other sources, including publicly accessible sources such as public registers and the internet, within the framework of applicable law.

Data security and retention

Controller is required to prevent unauthorised access to personal data. We utilise reasonable and appropriate physical, technical, and administrative procedures and measures to safeguard the personal data we collect and process.

Controller will not retain personal data longer than necessary, and will assess the need for retention of personal data on an ongoing basis. Controller is required by law to retain certain personal data for a longer period. For example, personal data collected pursuant to the Norwegian Money Laundering Act and the Taxes Management Act may be retained for at least five years.

Disclosure to third parties

Use of service providers

Controller may provide its service providers access to the personal data if they provide services such as maintenance, operations or other technical solutions to Controller. To safeguard the rights pursuant to the Norwegian personal data regulations, Controller has entered into data processing agreements with the service providers who may gain access to or process personal data on behalf of Controller. Our service providers are not entitled to make use of the personal data for other purposes than those set out in this Privacy Notice. Our service providers have an equal obligation to enter into a data processing agreement with their respective service providers (sub-processors), ensuring that the sub-processors are imposed the same obligations as the service providers.

In the event that a service provider is located outside of the EU/EEA, Controller will ensure that sufficient safeguards are implemented in order to ensure that such transfer is safe and in accordance with the Norwegian personal data regulations.

Disclosure to third parties

Controller will only disclose personal data to third parties if (i) such disclosure is required by law or is in accordance with the GDPR, and (ii) the disclosure is made for the purposes set out in this Privacy Notice. Such third parties may include banks, the fund administrator, the depositary, financial and legal advisors, and national authorities.

Personal data may be disclosed to the Norwegian Tax Administration, pursuant to Controller's reporting obligations under the Norwegian Taxes Management Act. Personal data may be disclosed to the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim), pursuant to Controller's reporting obligation under the Norwegian Money Laundering Act. Personal data may be disclosed to the Financial Supervisory Authority, pursuant to Controller's obligations under the Norwegian AIFM Act (AIF-loven).

In the event that a third party is located outside of the EU/EEA, Controller will ensure that sufficient safeguards are implemented in order to ensure that such disclosure is safe and in accordance with the Norwegian personal data regulations.

Rights

The natural persons concerned have the right to request access to and rectification or erasure of personal data or restriction of processing, to object to the processing and may have the right to data portability. Please see the contact section below for information about how to exercise these rights.

Complaints regarding processing of personal data may be submitted to the Norwegian Data Protection Authority (Datatilsynet).

Cookies and analytics

This website only uses cookies that are necessary for its technical operation. To understand how the website is used, we use a privacy-friendly analytics tool that collects aggregated, anonymous statistics, such as the number of visits and which pages are viewed. The analytics tool does not set cookies, does not store any information on your device and does not collect personal data. We do not use cookies for tracking or marketing.

Contact

Any questions regarding this Privacy Notice and our privacy practices should be sent by e-mail to martin@anna.fund, or by writing to Anna Asset Management AS at Fridtjof Nansens vei 19, 0369 Oslo. Alternatively, you may call +47 900 83 850. Inquiries in relation to the rights set out above should be sent to Controller in the same manner.