Site Privacy Policy

1. Respect for Your Privacy
MD Global is committed to protecting your privacy and complying with applicable data protection laws in the countries where we operate, including:

Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) – applicable in the European Union and the European Economic Area (EEA),
California Consumer Privacy Act (CCPA) – applicable to the protection of personal data of California residents,
Virginia Consumer Data Protection Act (VCDPA) – applicable in the state of Virginia,
New York SHIELD Act (Stop Hacks and Improve Electronic Data Security Act) – regulating the protection of personal data in the state of New York,
Gramm-Leach-Bliley Act (GLBA) – regulating the privacy of data of customers of financial institutions in the USA,
Australian Privacy Act 1988 (APA) – regulating the processing of personal data in Australia,
Personal Information Protection and Electronic Documents Act (PIPEDA) – regulating the processing of data in Canada.

MD Global ensures compliance with the above regulations and applies the highest standards of privacy protection and security of personal data.

2. Personal Data Administrator
The administrator of your personal data is:

MD Global Capital Management Incorporated
Headquarters: 30 Rockefeller Plaza (31st - 63rd Floor), New York, NY 10112, USA

Phone: +1 212-588-8702
E-mail: privacy@md-gcm.com

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

Entity Representing the Group's Subsidiaries:
Raiffeisen Kapitalanlage-Gesellschaft m.b.H.
Address: Mooslackengasse 12, 1190 Vienna, Austria

Tax Identification Number (UID): ATU1535720

The data controller may vary depending on the country of residence of the user and the nature of the data processing.

3. What Data Do We Collect?
When using the MD Global website, we may collect the following personal data:

- Identification data (name, surname),
- Contact data (email address, telephone number, mailing address),
- Financial data (for customers and investors),
- Technical data (IP address, type of device, operating system, cookies),
- Interaction data (visit history, user preferences).

We do not collect sensitive personal data such as data on health, ethnic origin or religious beliefs, unless required by law or you have given your consent.

4. Purposes and Legal Basis of Data Processing
MD Global processes personal data for the following purposes:

User service and provision of services - Execution of the contract (Article 6 paragraph 1 letter b of the GDPR)

Statistics analysis and website optimization - Legitimate interest of the administrator (Article 6 paragraph 1 letter f of the GDPR)

Direct marketing - User consent (Article 6 paragraph 1 letter a of the GDPR)

Compliance with legal obligations - Regulatory obligations (Article 6 paragraph 1 letter c of the GDPR)

Personal data processing is carried out in accordance with the laws in force in the given country of the user.

5. Data Security and Confidentiality
MD Global uses advanced data protection measures, including:

Encryption of data transmission (TLS - Transport Layer Security),

Securing the IT infrastructure against unauthorized access,

Limited access to IT systems,

Constant security monitoring and risk analysis.

Data is stored only for the period necessary to achieve the purposes of processing or until consent is withdrawn, unless applicable law requires longer storage.

6. Sharing Data with Third Parties
MD Global may share data with:

- Related entities within the capital group,

- IT service providers, auditing, law and accounting firms,

- Regulatory authorities and public institutions, if required by law.

Data is not sold or made available to third parties for marketing purposes without your consent.

7. Transferring Data Outside the European Union
In cases where data is transferred outside the EEA (e.g. to the USA, Canada, Australia), MD Global ensures its protection through:

Standard Contractual Clauses (SCCs) of the European Commission,

EU-U.S. Data Privacy Framework,

Binding Corporate Rules (BCRs).

8. Your Rights
You have the right to:

- Access your personal data,
- Rectify incorrect data,
- Delete data ("right to be forgotten"),
- Restrict processing,
- Transfer data,
- Object to processing.

To exercise your rights, contact us:
E-mail: rodo@md-gcm.com

You can also file a complaint with the competent data protection authority in your country.

9. Minors
MD Global does not knowingly collect data from anyone under the age of 18 in the European Union, Canada, Australia, and other jurisdictions where the age of majority is 18.

In the United States, MD Global does not knowingly collect data from anyone under the age of 21, in accordance with applicable privacy laws and regulations governing investment and financial services.

If you are under the age of 18 (or 21 in the United States), you may provide us with your personal data only with the consent and supervision of your parent or legal guardian. If we learn that we have collected data from a minor without the required consent, we will take immediate steps to delete it.

If you are a parent or guardian and have concerns about your child's data, please contact us: Email: rodo@md-gcm.com

10. Changes to Privacy Policy
MD Global may update this privacy policy from time to time. Any changes will be posted on the website.

Last updated: February 17, 2025