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Privacy Policy

Last updated: October 2026

This notice explains how personal data are processed in connection with this website, in accordance with Articles 13 and 14 of the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”) and the Maltese Data Protection Act (Cap. 586).

1. Data controller

The data controller is TGA Funds SICAV p.l.c., registration number SV 132, with registered office c/o CC Fund Services (Malta) Ltd, Ewropa Business Centre, Triq Dun Karm, Birkirkara BKR 9034, Malta. For any data-protection matter you can write to info@tgasicav.com.

2. Data we process

Browsing data: when you visit the site, the hosting provider's servers automatically record technical data such as IP address, date and time of the request, page requested, referring page and browser type. Data you send us: if you write to us by email, we process your email address, your name and any other information you include. The site has no forms, registration or user accounts, and uses no analytics, profiling or advertising tools. No automated decision-making takes place.

3. Purposes and legal bases

Browsing data are processed to deliver the site and keep it secure, on the basis of our legitimate interest (Art. 6(1)(f) GDPR). Data you send us by email are processed to answer your request and, where you ask for it, to send you the offering documentation: the legal bases are steps taken at your request before a possible contract (Art. 6(1)(b) GDPR) and our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR). Any subsequent investment is governed by the offering documents and the related data-protection information.

4. Retention

Browsing data are kept by the hosting provider for a limited period for security purposes and then deleted, unless they are needed to investigate an incident. Email correspondence is kept for up to 24 months after your request has been dealt with, unless a longer period is required by law.

5. Recipients

Data are processed on our behalf, under appropriate agreements, by the website hosting provider and by the email service provider (Microsoft 365), acting as data processors. Where needed to answer your request, data may be shared with the investment manager of the sub-funds (Replica SIM SpA) and with the administrator (CC Fund Services (Malta) Ltd). Data may also be disclosed to public authorities where required by law. Data are not sold or used for marketing.

6. Transfers outside the EEA

Some service providers may process data outside the European Economic Area, in particular in the United States. In that case transfers are based on a European Commission adequacy decision, such as the EU-US Data Privacy Framework, or on the Standard Contractual Clauses approved by the Commission.

7. Cookies and local storage

The site does not use cookies. It stores a single technical item in your browser to remember your professional-investor confirmation, and that item is never sent to us. Details are in the Cookie Policy.

8. Providing your data

Providing data by email is voluntary. Without it we cannot answer your request.

9. Your rights

Under Articles 15 to 22 GDPR you may ask for access to your data, their rectification or erasure, restriction of processing and data portability, and you may object to processing based on legitimate interest. To exercise these rights write to info@tgasicav.com. You also have the right to lodge a complaint with the Information and Data Protection Commissioner in Malta (idpc.org.mt) or with the supervisory authority of the EU Member State where you live or work.

10. Security

We use appropriate technical and organisational measures to protect data, including encrypted (HTTPS) connections.

11. Links to other websites

The site may contain links to other websites, such as those of regulators. Their own privacy notices apply to them.

12. Changes to this notice

This notice may be updated. The date of the latest version is shown at the top of the page.