Processing of personal data

MD Global Capital Group and its subsidiaries, including:

MD Global Investments & Financial Group
MD Global Defense & Security Group
MD Global Agriculture & Biotechnology Group
MD Global Industrial & Manufacturing Group
MD Global Equity & Holdings Group

processes personal data in accordance with applicable data protection laws, including:

Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)
California Consumer Privacy Act (CCPA)
New York State Privacy Act (SHIELD Act – Stop Hacks and Improve Electronic Data Security Act)
Federal Financial Privacy Act (GLBA – Gramm-Leach-Bliley Act)

Personal data processed by MD Global is protected in accordance with the highest standards of security and transparency, both within the European Union and in the United States and other jurisdictions in which we operate.

The administrator of personal data is:

MD Global Capital Group
Headquarters address:
30 Rockefeller Plaza (31st - 63rd Floor),
New York, NY 10112, United States

Capital Group Management Entity:
Financial Credit Investment IV Manager LLC
Address: 9 West 57th St., 43rd Floor, New York, NY 10019, United States

Subsidiary Management Entity:
Raiffeisen Kapitalanlage-Gesellschaft m.b.H.
Address: Mooslackengasse 12, 1190 Vienna, Austria

Tax Identification Number (UID): ATU1535720
US Corporations and Business Entities Database Number: 5426659

MD Global processes personal data for the following purposes:

Business Purposes – conducting business activities, offering products and services, managing customer relationships.

Administrative Services – managing customer accounts, handling payments, handling complaints and inquiries.

Fulfillment of Contracts – fulfillment of obligations arising from concluded contracts and provision of services.

Fulfillment of Legal Obligations – fulfillment of regulatory requirements, fraud prevention and ensuring operational compliance.

Marketing and Data Analysis – personalization of offers, research on customer behavior and analysis of market trends.

Personal data is processed on the basis of:

Legal provisions – to the extent resulting from EU regulations (GDPR) and American regulations (CCPA, GLBA, SHIELD Act).

Agreements concluded with customers – processing of data to the extent necessary to fulfill contractual obligations.

Consent of the data subject – in the case of direct marketing or other activities requiring consent.

Legitimate interest of the administrator – e.g. in the scope of ensuring security, preventing abuse and analyzing business data.

In accordance with the GDPR and the provisions of the CCPA, SHIELD Act and GLBA, data subjects have the right to:

Access to their personal data – the possibility of obtaining information on what data is being processed.

Rectification of personal data – correction of incorrect or outdated information.

Delete personal data ("right to be forgotten") – in the event that the data is no longer necessary for the purposes for which it was collected.

Limitations on data processing – in certain situations, e.g. when their accuracy is questioned.

Transferring personal data – the ability to receive your data in a structured format and transfer it to another administrator.

Objecting to data processing – especially in the case of marketing or profiling activities.

People residing in states covered by CCPA regulations have the additional right to:

Request information on how the administrator processes data

Submit a request not to use data for the purposes of sale or sharing with third parties

MD Global may transfer personal data:

To subsidiaries within the capital group, in accordance with applicable regulations.

To third parties that provide services to MD Global, e.g. IT suppliers, audit firms, legal advisors.

To regulatory and administrative authorities, if required by applicable law.

Data transfers outside the European Union are carried out in accordance with mechanisms approved by the European Commission, such as:

Standard Contractual Clauses (SCCs)

Privacy Shield for transfers to the US (if required by law)

Binding Corporate Rules (BCRs)

Personal data is stored for the period necessary to achieve the purposes for which it was collected, in accordance with legal regulations. This period may vary depending on the category of data and obligations arising from tax, accounting and anti-money laundering law.

Any questions, concerns or requests regarding the processing of personal data can be directed to:

Data Protection Officer
Justyna Wincent
E-mail: iodo@md-gcm.com

Department for Personal Data Protection (GDPR)
E-mail: rodo@md-gcm.com

Data subjects also have the right to lodge a complaint with:

EU Data Protection Office

US Federal Trade Commission (FTC)

National data protection regulators in relevant jurisdictions

MD Global reserves the right to update this policy in order to adapt it to legal changes and evolution in the way data is processed. Any changes will be published on the official MD Global website and communicated to interested parties.

Updated as of: 17.02.2025