Note: The English version of this website is solely for informational purpose.
Effective May 25, 2018. This policy was last updated on 31.10. 2025.
For us, “SKY Asset Management” AD (the “Company”), the protection of your personal data is of paramount importance. That is why we would like to inform you on what basis, for what purposes, within what time limits and by what means your personal data is processed when you conclude an Order Contract for subscription/redeemment of units from the mutual funds managed by the Company (“Order Contract”), an Agreement for the sale and redemption of units of collective investment schemes when implementing a type B and/or an Individual Portfolio Management Contract (“Agreement”) with the Company.
This policy also aims to inform in an accessible manner about how we process personal data in our capacity as the owner of the website www.skyfunds.bg.
We strictly adhere to the applicable data protection regulations in every personal data processing operation. As of May 25, 2018, the General Data Protection Regulation (GDPR) 679/2016 applies directly to the EU, including Bulgaria. It gives you enhanced rights regarding data protection, which are accompanied by more detailed obligations on our part; you can find out more about this here:
I. General information
1. Who are we?
“SKY Asset Management” AD, UIC: 175040675, is a management company licensed by the Financial Supervision Commission, whose main business is the management of the activities of collective investment schemes (including mutual funds), management of a portfolio of financial instruments and provision of investment advice.
2. How can you contact us?
“SKY Asset Management” AD is a personal data administrator with its registered office and management address: Sofia 1000, Oborishte district, 31 Ekzarh Yosif Str., contact phone number: + 359 2 815 40 00. You can also contact us by email: contact@skyfunds.bg
3. Who in the organization is responsible for the protection of my personal data and how can I contact them?
The person with a focus on personal data protection in the Company can be reached at the email and telephone number indicated above.
II. Security and data protection
The company has taken the necessary technical and organizational measures to protect your data from any unlawful actions, incl. loss and unauthorized access. In order to ensure high security, the measures are taken in two stages – at the design stage of the services offered, as well as at the default stage – when you, as a client, fill out the necessary documents/provide your data in order to receive the relevant service from us. The measures include limiting access to your personal data, strict adherence to the rules in the internal policy, contracts with personal data processors and the agreement for joint administrators (where applicable), appropriate training of the persons responsible for the processing of your personal data and compliance with good practices, guidelines and instructions for personal data protection from the competent supervisory authorities. All measures are subject to regular review and are periodically updated. In the event of a breach of the security of your personal data, we will notify you without undue delay within an appropriate period after becoming aware of it , if there is a possibility that the breach of personal data security will result in a high risk to your rights and freedoms.
In cases where a password may be required to access your data, you are responsible for keeping this password secure and confidential by not disclosing it to third parties and thus contributing to the high security of your data protection.
III. Personal data processing activities and categories of personal data
Your personal data will be processed by the Company only in accordance with applicable data protection regulations. When you correspond with us, through any of the communication channels, you confirm that the data you have provided is accurate, correct and up-to-date . You should keep in mind that if you do not provide the legally required personal data, the Company will not be able to provide you with its services.
Personal data are processed on the grounds set out in Article 6 of the General Data Protection Regulation, as set out below:
1. Purpose and basis of the processing of personal data collected for the purposes of the Order Contract for subscription/redemption of units from the mutual funds managed by the Company and an Agreement for the sale and redemption of units of collective investment schemes when implementing a type B:
| Personal data | Purpose | Foundation |
| Three names, personal identification number or other relevant identifier, date and place of birth, data from an identity document | Identification of an individual/contact person; Making contact; Law on Measures Against Money Laundering [1]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destruction; Conclusion of a contract; Provision of a requested service; Fulfillment of obligations under a concluded contract-order; Consideration of complaints | Fulfillment of a legal obligation |
| Copy of ID card or other identification document | Identification of an individual; Identification under the Law on Measures Against Money Laundering [1]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction | Fulfillment of legal obligations |
| Phone/email | Contact with the person/Performance of obligations under a concluded contract-order. Handling of complaints Informing about promotions of new similar products and services of the Company Offering new similar products and services | Conclusion/implementation of a purchase order contract Legitimate interest |
| Address | Making contact; Identification under the Law on Measures Against Money Laundering [1]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction; Providing a requested service; Fulfilling obligations under a concluded contract-order; Handling complaints | Fulfillment of a legal obligation Conclusion/implementation of a purchase order contract |
| Citizenship(s), Jurisdiction(s) of residence for tax purposes and tax identification number(s), Residential address | Declaration under DOPK[2] | Fulfillment of a legal obligation |
| Data from the Ministry of Interior website on the validity of Bulgarian personal documents | Verification of data provided by the client | Legitimate interest from avoiding fraud |
| Handwritten signature | Submitting and signing a purchase order contract | Conclusion and execution of a purchase order contract |
| In certain cases – A document containing credit and/or debit card data and/or a document certifying the charging or payment of a utility service; In order to verify the client’s identity, the Company may request additional data and/or documents, as well as check the provided data in registers. | Submitting and signing a purchase order contract Identification under the Law on Measures Against Money Laundering [1]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction | Fulfillment of a legal obligation |
| Personal data of beneficial owner, where applicable Data on holding a high-ranking public office or connection to such a person, where applicable Source of funds details, where applicable | Submitting and signing a purchase order contract Identification under the Law on Measures Against Money Laundering [1]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction | Fulfillment of a legal obligation |
2. Purpose and basis of the processing of personal data collected for the purposes of the Individual Portfolio Management Agreement with the Company and when providing investment advice:
| Personal data | Purpose | Foundation |
| Three names, personal identification number or other relevant identifier, date and place of birth, data from an identity document | Identification of an individual/contact person; Making contact; Identification under the Law on Measures Against Money Laundering [3]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioctio; Conclusion of a Contract; Provision of a requested service; Fulfillment of obligations under a concluded Contract; Handling complaints | Fulfillment of a legal obligation |
| Copy of ID card or other identification document | Identification of an individual; Identification under the Law on Measures Against Money Laundering [3]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction. | Fulfillment of legal obligations |
| Phone/email | Contact with the person/Performance of obligations under a concluded Contract. Handling of complaints Informing about promotions of new similar products and services of the Company Offering new similar products and services | Conclusion/implementation of a Contract Legitimate interest |
| Address | Making contact; Identification under the Law on Measures Against Money Laundering [3]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction; Providing a requested service; Fulfilling obligations under a concluded Contract; Handling complaints | Fulfillment of a legal obligation Conclusion/implementation of a Contract |
| The client’s knowledge and experience in the investment field Educational level and occupation or significant previous occupation of the client Investment objectives, risk appetite, financial situation of the client (monthly income, regular income, property/assets, regular financial obligations, etc.) | Client categorization and assessment of the suitability of the offered service for the purpose of best execution for the client under the LDCIPCI [4], LMFIA [5], Delegated Regulation (EU) 2017/565 | Fulfillment of a legal obligation |
| Information on sustainability preferences as described in Article 2(7) of Delegated Regulation (EU) 2017/565 | According to Art. 73a, 77, 77a, 77b of Regulation No. 38 of 21.05.2020 on the requirements for the activities of investment intermediaries | Fulfillment of a legal obligation |
| Marital status, employment | Additional information on client categorization and assessment of the suitability of the offered service for the purpose of best execution for the client under Regulation 38 of 21.05.2020 on the requirements for the activities of investment intermediaries | Legitimate interest in assessing customer suitability |
| Citizenship(s), Jurisdiction(s) of residence for tax purposes and tax identification number(s), Residential address | Declaration under DOPK[6] | Fulfillment of a legal obligation |
| Data from the Ministry of Interior website on the validity of Bulgarian personal documents | Verification of data provided by the client | Legitimate interest from avoiding fraud |
| Handwritten signature | Signing a Contract | Conclusion and execution of a Contract |
| In certain cases – A document containing credit and/or debit card data and/or a document certifying the charging or payment of a utility service; In order to verify the client’s identity, the Company may request additional data and/or documents, as well as check the provided data in registers. | Signing a Contract Identification under the Law on Measures Against Money Laundering [3]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction | Fulfillment of a legal obligation |
| Personal data of beneficial owner, where applicable Data on holding a high-ranking public office or connection to such a person, where applicable Source of funds details, where applicable | Signing of the Agreement Identification under the Law on Measures Against Money Laundering [3]; Fulfillment of obligations under Law on Measures Against the Financing of Terrorism and the Proliferation of Weapons of Mass Destructioction | Fulfillment of a legal obligation |
3. Purpose and basis of the processing of personal data collected on the website www.skyfunds.bg:
| Personal data | Purpose | Foundation |
| Names, email address, phone number, other data filled in the contact form on the website | Enabling customers and potential customers to receive answers to specific inquiries made through the contact form on the website | Consent |
| Email address | Enabling clients and potential clients to subscribe to receive newsletters, news and financial analyses | Consent |
IV. Storage period. Destruction
Personal data is stored for the period necessary to achieve the purposes for which it was collected. After achieving the purposes for which the personal data was collected, we will destroy it immediately. In the event that after achieving our purposes we decide to store the processed personal data for statistical purposes, this will be done in the form of storing anonymous data that cannot identify you in any way.
The Company takes all necessary technical and organizational measures to destroy data that is no longer needed, except in cases where there is a legal basis for the Company to process it for a longer period of time; upon your request to restrict processing, in accordance with your rights, detailed below; or for a purpose compatible with the original purpose of processing, of which you will be promptly informed.
Most of the personal data we collect is based on our legal obligation and will likely be stored for 5 to 7 years, starting from the beginning of the calendar year following the year of termination of the relationship between the Company and you; respectively, up to a maximum of 10 years under the Accountancy Act (AA). The criteria for the term are specified in the LMPI and the ZS.
V. Will my personal data be accessible to third parties?
The company does not transfer personal data to a third country or international organization outside the European Union.
Access to your personal data will be available to the persons who maintain the Company’s information systems, located in Bulgaria, as well as to the persons who maintain the Company’s accounting services, also located in Bulgaria. Personal data may be provided to trusted partners and contractors who work on behalf of the Management Company on the basis of contractual relationships and under confidentiality agreements. These persons and companies may use such information to enable the Management Company to conclude transactions, execute orders, and provide services.
However, these companies do not have the right to independently share this information. These companies are: bank/IP depository, payment systems and institutions, transaction repositories, auditors, financial/legal advisors and other data processors, and the Management Company in such cases takes action to ensure that such data processors process data for the Management Company’s clients in accordance with regulatory requirements, the Management Company’s instructions and with certain data security measures.
Access to your personal data when providing the portfolio management service will also be available to the selected investment intermediary who executes the orders under your portfolio. The Company and the selected investment intermediary have signed an agreement for joint administrators, which has the following main features: The joint administrators exchange personal data regarding the movement of funds and financial instruments under your portfolio, including costs, fees, etc. The exchange of personal data under the previous sentence is carried out using secure technical means in order to prevent violations in data processing.
The company regularly provides personal data about clients to the Central Depository (“CD”) or to the relevant other depository institution, in order to be registered as clients by virtue of its legal obligation.
By virtue of a legal obligation, your personal data may be transferred to the following state authorities/companies: FSC, NRA [7], DANS [8], CD and BSE [9].
Personal data may be provided in compliance with the lawful prescriptions of court orders upon legitimate requests from authorized authorities (under the Electronic Communications Act, the Criminal Procedure Code, the Criminal Code, etc.), including regulators, courts, bailiffs, DANS, NRA, LPDP, notaries, receivers, liquidators, etc.
VI. Is my personal data subject to automated decision-making, including profiling?
The Company does not process your personal data entirely automatically and your data is not subject to automated decision-making. When you are a client of the portfolio management service, the Company profiles you by assessing your experience, knowledge and financial situation in order to categorize you as a type of client, to assess the suitability of the service(s) and to act in the best interest of the client. This profiling is based on a legal obligation of the Company. In the event that the Company does not receive this data and does not perform the profiling, there is a legal prohibition on providing the service to the client.
VII. Your rights
As a data subject processed by the Company, you have the following rights, which you may exercise by submitting an application/request to the Company’s office:
a . Right to information
In accordance with the applicable personal data legislation, you have the rights below, and we undertake to respond to each of your requests within 1 month of receipt of the request and without any fee. In the event of any difficulties in timely execution of such requests, the execution period may be extended by another 2 months, of which you will be notified within 1 month of receipt of the request.
b . Right of access
You can request information about what personal data we process about you, as well as whether we process any of it. You can request access to this data.
We will provide you with a statement of the personal data that is being processed. For additional statements, we may charge a reasonable fee based on administrative costs. When you submit a request by electronic means, we will, where possible, provide the information in a commonly used electronic format, unless you have requested otherwise.
c . Right to corrections
If we process incomplete or incorrect personal data from you, you can request its correction or completion at any time.
d . Right to erasure
You can request the deletion of your personal data in the following cases:
• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• you withdraw your consent (in case we process data on this basis) on which the processing of the data is based and there is no other legal basis for the processing;
• you believe that personal data has been processed unlawfully.
Please note that there may be other reasons that prevent the immediate deletion of your data, such as statutory retention obligations, pending proceedings, establishment, exercise or defense of legal claims, etc.
e . Right to restriction of processing
You have the right to request restriction of processing if:
• you contest the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data;
• the processing is unlawful, but you do not want the personal data to be deleted, but instead require the restriction of its use;
• we no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims
• you have objected to the processing of the data pending verification of whether the Company’s legitimate grounds for processing the data override your interests.
If you request restriction of processing, we will inform you before the restriction of processing is lifted.
f . Right to data portability
You can ask us to provide you with the personal data we process about you in a format that can be easily read by a computer and transferred to another financial institution, for example. This only applies where:
• the processing of the specific data is based on your consent or in connection with the conclusion and performance of a contract; and
• the processing is carried out in an automated manner.
g . Right to object
You have the right, at any time and on grounds relating to your particular situation, to object to processing of your personal data which is based on legitimate interest – the grounds are set out in the table above, including profiling based on this ground.
Where you have given your consent to the processing of data for direct marketing purposes, you have the right to object to the processing of personal data at any time without giving reasons.
h . Right to lodge a complaint
If you believe that we have violated applicable data protection legislation when processing your data and as a result have affected your rights, please contact us. Of course, you also have the right to file a complaint with the Personal Data Protection Commission.
VIII. Dispute Resolution and Applicable Law
In case of disputes, the applicable law is the law of the Republic of Bulgaria, and the competent court is the relevant court in the city of Sofia.
Any disputes between the Company and customers regarding personal data may be resolved through negotiations between the parties.
IX. Update
The Privacy Policy shall enter into force on the date indicated at the beginning, and may be amended subsequently. The updated Policy shall enter into force on the day of its publication on the website. If you visit the website after the Policy has been amended/read it when receiving services from the Company, you will be bound by the new Privacy Policy.
Document update date: _______. 2025
[1] Law on Measures Against Money Laundering
[2]Tax and Social Security Procedure Code
[3]Law on Measures Against Money Laundering
[4]Law on the Activities of Collective Investment Schemes and Other Collective Investment Undertakings
[5] Markets in Financial Instruments Act
[6]Tax and Social Security Procedure Code
[7] National Revenue Agency
[8] State Agency “National Security”
[9]” Bulgarian Stock Exchange – Sofia” AD
