Privacy Policy

1. Introduction

AI Alpha Lab ApS is committed to protecting your individual rights and keeping your personal data safe. This Privacy Policy describes how AI Alpha Lab ApS (“we” or “us”) process personal data we have collected. It is meant to help you understand what information we collect about you, why we collect it, our storing and sharing practices, and what your privacy rights are.

We process personal data in accordance with the General Data Protection Regulation (“GDPR”) and the Danish Data Protection Act (“DPA”).

2. Data controller

AI Alpha Lab ApS is the data controller and responsible for the processing of your personal data. In case of any questions or inquiries about our processing of your personal data, please feel free to contact us. You will find our contact information below:

AI Alpha Lab ApS
Fruebjergvej 3
2100 Copenhagen
Denmark

Company Registration No. (CVR): 40415599
Mail: contact@aialphalab.com
Telephone: +45 60 43 65 78

3. Description of processing

AI Alpha Lab ApS process your information for one or more specific purposes and in accordance with the data protection regulations. We only process personal data where processing is necessary for legitimate purposes. If we need to process personal data for another purpose than originally intended, we will inform you about this prior to any such further processing.

Below you can read more about the types of processing we do, the purposes for which we process your personal data as well as the legal basis for processing.

3.1 Clients

When we provide services or products to clients, we process personal data about our clients and contact persons affiliated with them to be able to enter into a contract with the client. This also applies to communication and contract negotiations at the request of the clients prior to entering into a contract.

The purpose with processing the personal data is to be able to provide the agreed services or products to our clients. We process the following information for this purpose:

  • Contact information such as name, address, phone number, e-mail address etc.
  • Information about authorized signatories.
  • Information about knowledge and experience with investments, financial information, risk tolerance, ability to bear losses etc. (only advisory clients).

We obtain the personal data we process from you or from your employer.

The legal basis for processing of personal data is the performance of a contract with our clients, cf. GDPR Article 6 (1)(b). In special cases, we process personal data based on the rule of legitimate interests, cf. GDPR Article 6 (1)(f), where the legitimate interest is communication with our clients and contact persons affiliated with them to be able to offer professional services to our clients. Finally, we process your personal data to comply with legal obligations, cf. GDPR Article 6 (1)(c), for example the investment advisor regulation.

We retain your personal data as long as they are necessary for the purpose(s) for which they are being processed. As a general rule, data are retained for 5 years following the termination of a business relationship but under special circumstances such periods may be shorter or longer for the purpose of complying with legal requirements for the deletion or storage of data.

3.2 Implementation of an AML-procedure

For the purpose of complying with the Danish Act on Measures to Prevent Money Laundering and Financing of Terrorism (the “Anti-Money Laundering Act”), we have established an AML-procedure to ensure we know the identity of our clients and where their financial assets originate from. Consequently, if you or your undertaking is a client with us, you may be asked to provide documentation enabling us to determine the identity of the involved legal entities and physical persons as well as the origin of financial assets.

To comply with the Anti-Money Laundering Act and our AML-procedure, we process the following data:

  • Name, address, place of birth, nationality, country of residence, personal identification number (CPR number in Denmark).
  • Identification documentation, for example a scanned copy of passport or driving license.
  • Information about beneficial owners and politically exposed persons etc. When the beneficial owners are not Danish or do not have permanent residence in Denmark, it may be necessary to collect additional data.
  • Information about financial assets.

Such data will always be collected from the persons concerned.

We process these personal data in compliance with legal obligations, cf. GDPR Article 6 (1)(c). The legal obligation is laid down in the Anti-Money Laundering Act. Data concerning personal identification numbers are processed to comply with the legislation, cf. DPA section 11 (2)(1).

If a public authority (for example, the Danish FSA or the Danish Public Prosecutor for Serious Economic and International Crime) take an interest in our clients, we are obliged under the Anti-Money Laundering Act to disclose data to the authorities in question.

Personal data collected for the purpose of complying with the requirements of the Anti-Money Laundering Act are retained for a minimum of 5 years after termination of a business relationship. In special cases such periods may be shorter or longer, including for the purpose of complying with legal requirements for deletion and storage.

We are obliged to ensure that the data we collect are still relevant to the client relationship and are updated regularly. As a result, we may contact you for the purpose of updating data.

3.3 Marketing material and newsletters

If you have signed up to receive marketing material, newsletters, or other information from AI Alpha Lab ApS, we need to process your personal information when we send out newsletters, marketing initiatives or other requested information.

We only process the following information for this purpose:

  • Contact information such as name, phone number, e-mail address etc.
  • Information preferences.

The legal basis for processing of personal data is your consent, cf. GDPR art. 6 (1)(a). You have the right to withdraw your consent at any time by contacting us in writing, cf. section 2.

If you have registered to receive newsletters from AI Alpha Lab ApS, we will retain your personal data for as long as you wish to receive information from us plus 2 years. If you have registered to receive marketing material or other information from AI Alpha Lab ApS, we will retain your personal data for as long as the relevant activity is ongoing plus 2 years.

3.4 Subscriptions

If you have a subscription with one of our partners and contact us directly about the subscription, we process your personal information when we respond to your inquiry.

The purpose of processing your personal data is to be able to deliver support to the subscribers. We only process the following information for this purpose:

  • Contact information such as name, phone number, e-mail address etc.

The legal basis for processing of personal data is your consent, cf. GDPR art. 6 (1)(a). You have the right to withdraw your consent at any time by contacting us in writing, cf. section 2.

If you have contacted us directly about the subscription, we will retain your personal data for as long as the relevant activity is ongoing plus 2 years.

3.5 Suppliers and partners

When we enter into contracts with suppliers and partners, we process a number of personal data about our suppliers, partners and contact persons affiliated with them. This also applies to communication and contract negotiations at the request of the suppliers and partners prior to entering into a contract.

We process the following information:

  • Contact information such as name, address, phone number, e-mail address etc.
  • Bank details and payment information, if relevant.
  • Information about authorized signatories, if relevant.

We obtain the personal data we process from you or from your employer.

The legal basis for processing of personal data is the performance of a contract with suppliers and partners, cf. GDPR Article 6 (1)(b). In special cases, we process personal data based on the rule of legitimate interests, cf. GDPR Article 6 (1)(f), where the legitimate interest is communication with suppliers and partners to make sure that we will be able to offer professional services to our clients.

We retain your personal data as long as they are necessary for the purpose(s) for which they are being processed. As a general rule, data are retained for 5 years following the termination of a business relationship but under special circumstances such periods may be shorter or longer for the purpose of complying with legal requirements for the deletion or storage of data.

3.6 Job applicants

If you apply for a job at AI Alpha Lab ApS – whether your application is solicited or unsolicited, we process your personal data to assess if you are qualified for an existing or future position with us. We process the following information for this purpose:

  • Information provided by you, including name, contact information, birth date, work related and educational background information.
  • Information on references such as name, phone number, e-mail address etc.

The legal basis for processing of personal data is our legitimate interest in recruiting new employees for our business, including to ensure documentation of the recruitment process, cf. GDPR Article 6 (1)(f), and contract purposes in relation to a potential contract of employment with you, cf. GDPR Article 6 (1)(b).

AI Alpha Lab ApS may also retain your application for a period of up to 1 year after the recruitment process has ended or after your filing of an unsolicited application, provided you have given your consent, cf. GDPR Article 6 (1)(a). You have the right to withdraw your consent at any time by contacting us in writing, cf. section 2.

4. Collection of personal data

The personal data we collect will generally come directly from you, or from companies or persons acting on their behalf as well as from publicly available sources.

5. Recipients of personal data

We treat personal data as confidential, and as a general rule we do not disclose your data to third parties.

However, data may be disclosed to external suppliers and partners, including data processors, who are assisting us with operations.

In special cases, your data may be disclosed to authorities such as the Danish FSA or the Danish tax authorities and/or courts if required by law. 

We may also disclose personal data to our external accountant where it is necessary for compliance with legal obligations.

5.1 Third countries

In general, we do not transfer personal data to countries outside the EU/EEA.

We may entrust your personal data to our system suppliers (data processor) who process personal data on our behalf and according to our specific instructions. Some of our data processors may be located outside the EU/EEA in which cases a transfer to a third country occurs.

The personal data will as a general rule be transferred on the basis of the European Commission’s standard contractual clauses (SCC’s).

6. Your rights

You have a number of rights in relation to our processing of your personal data.

If you want to exercise your rights, please contact us, cf. section 2.

  • You have the right to obtain access to personal data being processed by AI Alpha Lab ApS (right of access).
  • You have the right to have inaccurate personal data rectified (right to rectification).
  • In certain cases, you have the right to have your personal data erased prior to AI Alpha Lab ApS otherwise erasing such personal data (right to erasure).
  • In certain cases, you have the right to have the processing of your personal data restricted (right to restriction of processing).
  • In certain cases, you have the right to object to our otherwise legal processing of your personal data, this includes objection against processing for marketing purposes (right to object).
  • In certain cases, you have the right to receive your personal data in a structured, commonly used, and machine-readable format (right to data portability).
  • To the extent that AI Alpha Lab ApS process personal data based on your consent, you have the right to withdraw the consent at any time in relation to any future processing (right to withdraw consent).

Conditions or restrictions may apply to these rights; it depends on the specific circumstances relating to the processing activities.

7. Complaints

In case of any questions, inquiries, or complaints about our processing of your personal data, please feel free to contact us, cf. section 2.

You are also entitled to file a complaint with the Danish Data Protection Agency via their website www.datatilsynet.dk.

8. Revisions to the Privacy Policy

We reserve the right to revise and modify the Privacy Policy as a consequence of amendments to legislation or adjustment of our procedures. In case of significant changes, we will provide you with a notice, when we are required to do so by applicable law.

The Privacy Policy was last revised on 6 December 2023.