1. About SKAGEN AS
SKAGEN AS (SKAGEN) manages mutual funds (SKAGEN Funds). This includes arranging for the subscription and redemption of fund units on behalf of clients. By SKAGEN’s clients we mean anyone who avails himself of SKAGEN’s products or services in any way.
2. What is personal data?
Personal data is any piece of information that may be either directly or indirectly associated with an individual, such as name, address, telephone number, email address and national identification number.
3. The need for personal data / purpose
The purpose of SKAGEN’s processing of personal data is to fulfil client agreements and to provide clients with the best possible service, follow-up and communication. Moreover, the processing is necessary in order to comply with disclosure requirements imposed by laws or agreements with authorities, securities registries and other enterprises (data processors) that process personal data in cooperation with or on behalf of SKAGEN.
4. Which personal data is processed by SKAGEN?
SKAGEN records personal data for which the company has a justifiable requirement, for example, the client’s name, date of birth, contact information and bank account information. Furthermore, SKAGEN will record changes to the contractual relationship and correspondence with the client. SKAGEN will also record personal information regarding any legal guardians, beneficiaries and other persons, provided that SKAGEN has a justifiable need to record the information.
SKAGEN may record telephone conversations for documentation and quality control purposes. Recordings will be catalogued and stored on a secure storage medium subject to regulated access.
5. How does SKAGEN process personal data?
In order to be able to fulfil client agreements, as well as comply with disclosure requirements to authorities, SKAGEN needs to process personal data by, for example, storing, systematising, scanning and delivering information.
SKAGEN is bound by law to treat client information confidentially. The same applies to SKAGEN’s cooperation partners.
SKAGEN has established a proprietary address registry, in which clients may opt out of receiving marketing communication. However, clients may not refuse to receive information that SKAGEN is legally bound to provide.
6. Disclosure of personal data - use of partners.
If legislation permits and SKAGEN’s obligation of confidentiality is not an impediment, personal data may be disclosed to external partners to be used within the purposes stated for processing. External partners may be financial institutions, the securities register, addressing and distribution entities as well as other SKAGEN subcontractors.
7. Marketing
Personal data may be used for the marketing of SKAGEN’s products and services, provided that the client has not opted out of receiving this type of communication (see last paragraph under section 5 above).
8. Access - Correction - Deletion
A client may request information about SKAGEN’s processing of personal data related to the client by sending a written and signed communication to SKAGEN. The client may ask for a printout of recorded information, how the information is processed, and security measures implemented for processing, on condition that providing this type of information does not impede security. A client may further demand that inadequate/incorrect personal data be corrected and unnecessary information deleted.
Personal data is deleted when storing is no longer necessary to fulfil the purpose of the processing or as a consequence of legislation.
The client’s consent to the processing of personal data by SKAGEN is voluntary and may be withdrawn at any time. If a client withdraws consent and demands that information be deleted, SKAGEN may, however, no longer be able to fulfil its obligations to the client, and the client relationship may as a result be terminated.
9. Personal data ombudsman
On behalf of SKAGEN, the operations director is responsible for the processing of personal data in SKAGEN. SKAGEN has appointed a personal data ombudsman who shall ensure that information is processed in accordance with the applicable law. 
You may find further information about personal data and data protection on the Data Inspectorate website.
July 2010
