Privacy and cookie policy

NCI Advisory Privacy Policy

NCI Advisory is fully committed to protecting client information and personal data. NCI Advisory is committed to maintaining the privacy and security of the personal data we collect about our business contacts (e.g. clients, investors, prospective clients, former clients), suppliers, applicants, newsletter subscribers, website visitors and other individuals we interact with, as well as other third parties or their employees, directors, officers or representatives (any of whom are referred to as “you” in this Privacy Policy).

In this Privacy Policy we describe how we collect, use, store and share personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Danish Data Protection Act (databeskyttelsesloven).

If you are a legal entity or partnership, you must provide your employees, directors, officers or representatives with adequate notice, including the information set out in this Privacy Policy. When you engage in the provision of services with us, we may use and transfer personal data about e.g. your employees or other relevant parties such as directors, management, beneficial owners, authorised representatives, associated parties, officers or representatives in accordance with this Privacy Policy as amended from time to time in accordance with the “Notification of changes” section below.

Data controllers

The following companies, jointly referred to as “NCI Advisory”, “us” or “we”, are each a data controller for the personal data you share with each of them:

  • NCI Advisory A/S, CVR no. 31332443
  • Nordic Corporate Investments A/S, CVR no. 31332818
  • NCI EUR A/S, CVR no. 46866142
  • NCI Credit Opportunity Fund A/S, CVR no. 41283750
  • NCIC EUR A/S, CVR no. 46866134
  • NCIA Finance ApS, CVR no. 42328944

Our contact information is:
NCI Advisory A/S
Annexstræde 6
DK-2500 Valby
+45 4199 8250
jb@nciadvisory.com
www.nciadvisory.com

We ensure that your personal data is protected. We are subject to a duty of confidentiality, and our systems are protected with appropriate technical and organisational measures.

Our internal rules on IT security contain instructions and measures protecting your personal data against destruction, deletion or changes, and against unauthorised or unlawful loss or disclosure.

In case of a personal data breach we will notify the Danish Data Protection Agency within the time limits of the GDPR, and we will inform you without undue delay if the breach is likely to result in a high risk to your rights and freedoms.

The purposes and the legal basis for the processing of personal data

We process personal data for the following purposes:

  • General client and investor administration in relation to our fund management business, including subscriptions, redemptions, the register of shareholders and investor reporting, ref. sections B and C below.
  • Performing investment analysis of investment opportunities as part of our services, ref. section D below.
  • Complying with anti-money laundering regulation and reporting obligations, ref. section C below.
  • Handling complaints, ref. section C below.
  • Sending our newsletter and invitations to events if you have given your consent, ref. section A below.
  • Operating and securing our website, ref. section D below, and, if you have given your consent, statistics and third-party content such as maps, ref. section A below and our cookie policy.

Information as to how and why we process your personal data can also be found in the contracts with you, which include any terms of business applicable to the services.

Our legal basis for the processing of personal data is:

A: You have given consent to the processing of your personal data for one or more specific purposes (GDPR article 6(1)(a)). You can withdraw your consent at any time, for example via the unsubscribe link in every newsletter or by contacting us. Withdrawal does not affect the lawfulness of processing before the withdrawal.

B: The processing is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract (GDPR article 6(1)(b)).

C: The processing is necessary for compliance with a legal obligation to which we are subject (GDPR article 6(1)(c)):

  • Know Your Customer requirements and AML monitoring, reporting etc., including sanctions screening, pursuant to the Danish Anti-Money Laundering Act (hvidvaskloven)
  • The Danish Bookkeeping Act (bogføringsloven)
  • Reporting to the tax authorities in accordance with the Danish Tax Control Act (skattekontrolloven)
  • Reporting to supervisory authorities according to the Danish Alternative Investment Fund Managers etc. Act (lov om forvaltere af alternative investeringsfonde m.v.) and the Danish Financial Business Act (lov om finansiel virksomhed)
  • The register of shareholders under the Danish Companies Act (selskabsloven)
  • Handling complaints under the rules on complaints officers (klageansvarlige)
  • Other obligations related to service-specific legislation, e.g. securities trading legislation

D: The processing is necessary for the purposes of our legitimate interests, e.g. when performing investment analysis as part of our services, keeping in contact with business partners, and operating and securing our website (GDPR article 6(1)(f)).

When you invest in one of our funds, we are required by law to collect certain information, e.g. for anti-money laundering purposes. If you do not provide this information, we cannot accept your investment.

We may collect personal data about contact persons who are employees of our suppliers and business partners when such a person is acting on behalf of the other party. We collect such information as part of entering into a contract with the business partner or when receiving services from suppliers. Further, we might need to collect contact information about employees of the authorities.

Categories of personal data

The personal data is in most cases collected directly from you or generated as part of the usage of our services. Sometimes additional information is required to keep information up to date or to verify information we collect. The personal data may include the following categories:

  • Identification information: name, identification number (incl. CPR number where required by law), documentation of such information, for instance a copy of a passport, driver’s licence or the like
  • Contact information: postal address, email address, telephone number(s)
  • Employer or position
  • Information about your investment, e.g. number of shares, transactions and bank account details
  • Messages you have sent to us, including complaints
  • Recording of phone conversations related to securities trading
  • Publicly available information from external sources such as registers held by governmental agencies, sanction lists, and other commercial information providers providing information on e.g. beneficial owners and politically exposed persons
  • Newsletter: email address and, if you have consented to it, whether you open the newsletter and click on its links

Use of personal data collected via LinkedIn Lead Gen Forms

When you submit your information through a LinkedIn Lead Gen Form associated with NCI Advisory, we may collect personal data such as your name, email address and phone number. This data is used for the following purposes:

  • To contact you with relevant information about our services.
  • To invite you to events or webinars, or send newsletters, if you have given explicit consent.
  • To contact you by phone, if you have consented to being contacted by telephone.

All data collected through LinkedIn Lead Gen Forms is processed in accordance with applicable data protection laws and this Privacy Policy. You may withdraw your consent at any time by contacting us at jb@nciadvisory.com.

Where do we receive the information from?

Usually, we receive the information from you. We might also receive it from your employer, from publicly available sources or from LinkedIn. Further, we might receive information you have disclosed to our service providers for performing our investment analysis.

Who we might disclose your personal data to

As part of our fund management business we may share your personal data with the following recipients or categories of recipients:

  • Public authorities, including the Danish National Special Crime Unit (NSK) and its Money Laundering Secretariat (Hvidvasksekretariatet), the tax authorities and the Danish Financial Supervisory Authority (Finanstilsynet)
  • The funds’ depositary, auditors and legal advisers
  • Suppliers and service providers assisting with technical support and services
  • Business partners
  • Data processors

We have entered into data processing agreements with selected suppliers, which as part of their services to us process personal data on our behalf. Examples are suppliers of IT development, maintenance, hosting and support, and our newsletter provider Mailchimp.

Before sharing, we always ensure that we respect relevant financial industry confidentiality obligations.

Transfers to countries outside the EU/EEA

Some of our suppliers, e.g. our newsletter provider Mailchimp (Intuit Inc.) and Google (maps on our website, only after your consent), may process personal data in the USA. Such transfers take place on the basis of the EU-US Data Privacy Framework or the European Commission’s standard contractual clauses. You can contact us to receive more information about the safeguards used.

How long we keep your personal data

We only retain your personal data for as long as needed for the purposes for which the data was collected and processed, or for as long as required by laws and regulations, e.g. the Danish Bookkeeping Act and the Danish Anti-Money Laundering Act.

  • KYC information is stored for 5 years after the client relationship has ended, according to the Danish Anti-Money Laundering Act.
  • Accounting records are stored for 5 years from the end of the financial year to which they relate, according to the Danish Bookkeeping Act.
  • Newsletter data is stored until you unsubscribe.

Automated decisions

We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you.

Your privacy rights

You have certain rights under the General Data Protection Regulation. These include the following:

  • Access to your personal data: You have the right to obtain a copy of the personal data that we hold about you.
  • Correction of incorrect or incomplete data: You have the right to rectification of inaccurate personal data concerning you and to have incomplete personal data completed.
  • Erasure: If there is no longer a legal basis for our processing of personal data, you have the right to obtain the erasure of personal data concerning you, and we have the obligation to erase personal data without undue delay. However, due to financial regulation, we are in many cases obliged to retain personal data during a client relationship and afterwards, e.g. to comply with a legal or regulatory obligation or where processing is carried out to manage legal claims.
  • Restriction of processing: You have the right to ask us to restrict the processing of personal data in certain cases.
  • Object to processing: In certain cases you have the right to object to processing of personal data concerning you that is based on our legitimate interests. We may not be able to comply with such a request where there are compelling legitimate grounds for us to process your personal data or where the processing is required for compliance with a legal or regulatory obligation or relating to legal proceedings.
  • Data portability: You have in certain cases the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller.
  • Withdrawal of consent: Where processing is based on your consent, you can withdraw it at any time.

Your request to exercise your rights as listed above will be assessed given the circumstances in the individual case. Please send your request to jb@nciadvisory.com.

Whistleblower scheme

Reports submitted through our whistleblower scheme are processed in accordance with the separate privacy information available at whistleblower.nciadvisory.com.

Updating your personal data

It is important for us that we maintain accurate records of your personal data. Please inform us of any changes to or errors in your personal data as soon as possible and we will update our records accordingly.

Data protection authority

You have the right to file a complaint about the processing of your personal data with the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, DK-2500 Valby, www.datatilsynet.dk.

Notification of changes

This Privacy Policy was last updated on 27 October 2026. It replaces the version dated 27 September 2018. We may amend this Privacy Policy from time to time as required by applicable data protection legislation.

NCI Advisory cookie policy

Cookies are small text files that are stored on your device when you visit a website. Similar technologies, such as pixels and scripts that read information from your device, are covered by this policy as well.

We only set cookies that are strictly necessary for the website to work. All other cookies, including statistics cookies and cookies from third parties such as Google Maps, are only set if you have given your consent. You can refuse cookies without any disadvantage other than that some content, e.g. the map, is not shown.

1. Necessary cookies
These cookies are needed for the website to function, e.g. to remember your cookie choice and for security. They do not require consent.

2. Statistics cookies (only with your consent)
These cookies help us understand how visitors use the website, so that we can improve it. The information is collected in aggregated form.

3. Third-party content (only with your consent)
The map in the footer of our website is provided by Google Maps (Google Ireland Ltd. / Google LLC). When it is shown, Google can set cookies and collect information such as your IP address. Information may be transferred to the USA, ref. our privacy policy above.

Newsletter
If you have consented to receiving our newsletter, our newsletter provider Mailchimp uses pixels and links in our emails to register whether the newsletter is opened and which links are clicked. The results are stored with your email address. You can unsubscribe at any time via the link in every newsletter.

Change or withdraw your consent

You can delete cookies in your browser at any time. Most modern browsers let you control or block cookies; the settings are usually found in the “Options” or “Preferences” menu. For more information about cookies, see www.allaboutcookies.org.

Contact
If you have questions about our use of cookies, please contact us at jb@nciadvisory.com.

This cookie policy was last updated on 27 October 2026.