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7 Marjanishvili Str. Tbilisi, Georgia

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info@tbcamc.ge

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Privacy policy Terms

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Usage Agreement

Please note :

The offer provided by this fund is applicable only to sophisticated investors as defined by Georgian legislation.

By confirming this field, you affirm that you meet the criteria of a sophisticated investor as per Georgian legislation, specifically under one or more of the following circumstances: (a) you have verified assets exceeding 3 million GEL or an annual income exceeding 200,000 GEL for the past three years; (b) you are a financial institution; (c) you are a director of a financial institution; (d) you represent a legal entity with capital exceeding 1 million GEL; (e) you represent a person recognized as a sophisticated investor according to the regulations of the National Bank of Georgia.

Terms and Conditions

The terms and conditions below set by TBC Asset Management LLC (identification number: 402184159, address: #7 K. Marjanishvili str. Tbilisi, Georgia) govern the use of this website (the “Terms and Conditions” or “Terms”).

For clarity, references to “TBC Asset Management” and “We” shall imply TBC Asset Management LLC and its group member companies, subsidiaries and/or affiliates (as the context requires). References to “Customer” and “You” shall mean any individual and/or organization using this website: www.tbcamc.ge (the “Website”).

Please read these Terms and Conditions carefully as the use of this Website is subject to your acknowledgement and acceptance of these Terms. By accessing this Website or using the information published thereon, You confirm that You have read, acknowledged and fully agreed with these Terms and Conditions. If You disagree with these Terms, You must not use, and must cease using, our Website.

Certain pages of this Website may be subject to additional rules or rules different from these Terms. We request You to read such rules carefully (if any). For clarity purposes, in case of collision between such rules and these Terms, the latter shall prevail.

Upon TBC Asset Management’s decision, the information published on this Website may not be available in all geographical areas.

LEGAL DISCLAIMER

Informational purposes

This Website is for informational and/or marketing purposes only. Nothing contained on this Website constitutes an advice (including, investment, business, legal, regulatory and/or tax advice), recommendation, trading idea or any other type of encouragement to invest or conclude any transaction. This Website contains general information with respect to the investment matters and should not be relied upon as a professional advice, recommendation, forecast or research.

No offer

Unless specifically stated otherwise, nothing contained on this Website shall constitute a solicitation, an invitation to treat or an offer made by TBC Asset Management or any of its respective director(s), employee(s), partner(s), affiliate(s), adviser(s) or agent(s) (“Representatives”) to make any investment, buy or sell any securities, futures, options or any other type of financial instruments.

Nothing contained on this Website shall be construed as a solicitation, invitation to treat or offer to make any investment or purchase or sell any abovementioned securities, futures, options or any other type of financial instruments to any person in any jurisdiction in which such solicitation, invitation to treat, offer, sale or purchase would be unlawful under the applicable laws of such jurisdiction.

No relationship

Nothing published on this Website shall be construed as (a) creating any type of relationship between TBC Asset Management and the Customer, (b) a promise for a service/product or (c) any ground for contractual relations with TBC Asset Management.

No guarantees

The information published on this Website (including with respect to the investments, financial instruments and trading strategies) may not be suitable for all investors. TBC Asset Management makes no representations that the information contained or all products, services, transactions, securities or other instruments discussed on this Website are appropriate or available for use/sale in all locations, jurisdictions or countries, or by all investors or counterparties. All Customers access our Website on their own initiative and are fully responsible to be in compliance with all applicable laws and regulations.

Nothing contained on this Website shall be construed as a guarantee given by TBC Asset Management with respect to any investment result, improvement of investment performance, achievement of investor’s investment objectives or other types of benefits. For the avoidance of any misunderstanding, nothing published on this Website shall be construed as representation or warranty that the investor will profit from making investment or trading in accordance with the information contained on this Website.

Limitation of responsibility

The information contained on this Website is for informational purposes only. Any decision based on the information/materials published on this Website shall be the sole responsibility and discretion of the Customer or any recipient of the information. TBC Asset Management strongly encourages any Customer or recipient of the information to make its own independent investigation and consult respective professional(s) of the relevant field prior to making any investment or concluding any transaction. TBC Asset Management and/or its Representatives shall not be liable for any loss or damages (including, but not limited to lost profits, lost opportunities or costs), however arising, directly or indirectly, caused by the use of this Website or any information/material published hereon or otherwise arising in connection with this Website.

TBC Asset Management disclaims all responsibility for any damage or loss resulted from the use of this Website, including in cases of technical delays, cancellations or suspensions of operation, defects, or system disruptions.

Availability of the information contained on this Website may depend on the functions and restrictions of the search system. TBC Asset Management shall not be held liable in case certain components of this Website are not available to You.

If TBC Asset Management at any time and for any reason, should become liable for the loss of any person and/or entity, the liability shall be limited to such person’s and/or entity’s documented direct loss. For the avoidance of any misunderstanding, TBC Asset Management shall in no circumstance become liable for the lost profits, damages for lost opportunity, incidental or consequential losses, punitive damages, damages for costs (including, but not limited to legal costs) or for any other indirect loss.

Accuracy of information

Despite our efforts to provide truthful information to our Customers that may be developed internally and/or obtained from the sources believed to be reliable, TBC Asset Management disclaims liability for the accuracy of the information/materials published on this Website. Unless stated otherwise, any information/material published on this Website is provided on an "As Is" basis and without warranties of any kind (expressed or implied). TBC Asset Management does not assure or warrant that any information/material contained on this Website is accurate, truthful, up-to date or complete.

TBC Asset Management does not warrant that the functions of this Website will be uninterrupted, without technical delays or error-free, that defects will be corrected or Website will be free of harmful components.

The use of this Website and any information/material published hereon is totally related to the Customer’s personal risk and TBC Asset Management disclaims all liability for the use of this Website or any information published hereon (including, but not limited to any error, omission, subsequent change in the information and/or interpretation of the information/materials published on this Website by third parties).

USE OF THIS WEBSITE

The information/materials published on this Website are intended solely for your own personal use. By visiting this Website, You hereby acknowledge and undertake that You will not distribute, disseminate, transfer, sell, republish, duplicate, make a copy, reproduce or otherwise exploit (including in social media) any information/material from this Website (including, the Website structure, image, and/or design) for commercial purposes, without obtaining a prior written consent from TBC Asset Management. Granting the consent represents TBC Asset Management’s sole discretion. Prior written consent would not be required if: (a) the information/materials published on our Website are utilized for personal use for educational or informative purposes or (b) the use of the information/materials published on our Website is permitted by TBC Asset Management.

You hereby undertake that You will use this Website only for lawful purposes. You are strictly prohibited to: (1) use this Website for any purpose that is fraudulent, tortious or unlawful/illegal; (2) damage this Website by any harmful programme or committing any other similar actions. In addition, unauthorized use of this Website and the system (including, under unknown name and code) is also strictly prohibited.

It is your sole risk if any programme module (telephone, computer, etc.) used for visiting the Website is not streamlined.

TBC Asset Management shall not be held responsible for any consequences in case the access to the Website becomes restricted or impossible due to the TBC Asset Management's technical delay, or due to any other reason.

INTELECTUAL PROPERTY

The intellectual property rights with respect to this Website (including but not limited to its structure and design) and any information/material published on this Website and products/services mentioned herein are owned solely by TBC Asset Management. The foregoing works are protected by applicable copyright law and all such rights are hereby reserved by us. Apart from that, TBC Asset Management’s exclusive rights apply to any object of copyright that is created and registered by us, including our own trademarks.

You are strictly prohibited to use, process and/or publish (including, in social media) any information/material/content (including but not limited to images, graphs, designs, logos, patents) created by us or any other type of our intellectual property without our prior written consent. The latter would not be required if our intellectual property is used for non-commercial, personal purposes only or the applicable law/international treaty does not require preliminary consent. Nothing on this Website shall be construed as permission granted to Customers to use our intellectual property.

Downloading from this Website or making copies of any information/material published hereon for commercial purposes shall be considered as the breach of the applicable law of Georgia.

Please note that respective names, trademarks, and logos of the companies published on the TBC Asset Management's Website belong to relevant entities.

Confidentiality and Personal Data Protection

TBC Asset Management LLC ensures protection of confidential information provided to us in accordance with the applicable laws of Georgia. We will disclose provided confidential information only upon your consent or as mandated by the applicable law.

We may request your personal information if necessary and to the extent required for the purposes of efficient service provision in compliance with the applicable law. Please review our Privacy Policy that constitutes an integral part of these Terms and Conditions and are hereby incorporated by reference in order to learn how your personal data is protected with us.

For the avoidance of any misunderstanding, TBC Asset Management shall not be held liable for the third party’s unauthorized access to or unauthorized acquisition of the confidential information/personal data when the latter is being transferred to us (including through online platforms and email). TBC Asset Management disclaims all liability for the disclosure of information that became public by You or was spread through a less secure electronic communication medium.

By agreeing to these Terms and Conditions, You confirm and agree that:

(a) your digital footprint generated by your visits may be used for statistical purposes, improvement of the Website quality or our technical operations;

(b) TBC Asset Management has a right to send You information regarding our products/services mentioned on this Website through email, SMS or other type of electronic communication medium.

Links Published on the Website

Any hyperlinks to the sites or resources of the third parties published on this Website are provided only for the informational purposes. Such websites and resources are operated by third parties and are not subject to the TBC Asset Management's control. TBC Asset Management disclaims all liability for the use of such websites and resources (including, the accuracy of the information published thereon and their privacy policies). Therefore, your access to and use of such linked websites and resources, as well as becoming acquainted with their terms and conditions shall be your sole responsibility.

Amendments

TBC Asset Management reserves the right to change the present Terms and Conditions from time to time unilaterally without giving prior notice to Customers. The amended Terms and Conditions will be effective immediately upon publishing on this Website, unless stated otherwise. You are obliged to review the Terms and Conditions regularly. By accessing this Website after publishing the amended Terms and Conditions, You confirm that You have read, acknowledged and fully agree to the Terms as modified.

Translation Discrepancies

These Terms and Conditions, as well information published on this Website may be provided in Georgian and English languages. In case of any discrepancy between these versions, Georgian version shall prevail.

Governing law and dispute resolution

These Terms and Conditions shall be governed by and construed in accordance with the laws of Georgia.

Any dispute arising out of or in connection with these Terms and Conditions shall be resolved by the courts of Georgia.

Severability

If any provision of these Terms and Conditions is for any reason held to be illegal, invalid or unenforceable, such provision shall be severable from these Terms and shall not affect the validity and enforceability of the remaining provisions.

Contact Information

Should You have any questions regarding the Terms and Conditions and the information published on this Website, please send us a letter at #7 Marjanishvili street, Tbilisi, Georgia or mail us at info@tbcamc.ge.

Privacy Policy

WHO WE ARE

TBC Asset Management (hereinafter referred to as - “TBC Asset Management”, “Company”, “We”, “Our” or “Us”) is an asset management company duly registered under the laws of Georgia and licensed by the National Bank of Georgia.

Our identification number is: 402184159.

Our legal address is situated at: #7 K. Marjanishvili str. Tbilisi, Georgia.

INTRODUCTION

TBC Asset Management and its group member companies, subsidiaries and/or affiliated companies are committed to protecting privacy of our customers (hereinafter referred to as - “You” or “Customer”) and ensuring the security of any personal data We receive from You (hereinafter referred to as – the “Personal Data”, “Data” or “Information”). We have implemented this privacy policy (the “Policy”) to inform You about the purposes and legal grounds of processing of your Personal Data, how We safeguard it, as well as your rights regarding the foregoing.

This Policy:

Covers the information that TBC Asset Management acquires as part of its relationship with You.
Is addressed to Customers who may provide Information to TBC Asset Management or who visit or use TBC Asset Management’s website and/or social media sites

TBC ASSET MANAGEMENT HEREBY PROMISES:

To ensure safety and privacy of your Personal Data;
Not to process your Personal Data in any unlawful manner;
To furnish You with full and exhaustive information regarding processing of your Personal Data.

LEGAL GROUNDS OF PERSONAL DATA PROCESSING:

TBC Asset Management will only process your Personal Data if:

You explicitly consent to process your data for one or more specific purposes;
Processing is essential in order to fulfill an obligation arising from an agreement executed with You or to execute a transaction at your request (if any) Processing is mandatory under the applicable law;
Processing is essential to fulfill obligations imposed on TBC Asset Management by Georgian legislation;
Your personal data is accessible to the public or You have voluntarily made it publicly accessible;
Processing is essential to protect significant public interests;
Processing is required to protect the legitimate interests of TBC Asset Management or third parties;
Processing is required to provide services to You (review your application);
Processing of data is grounded on other legal basis.

PURPOSES OF PERSONAL DATA PROCESSING:

TBC Asset Management will process your Personal Data only for the lawful purposes listed below:

To generate and maintain website statistics for optimizing processes, fields, and design.
To safeguard website visitors and prevent fraudulent activities.
To evaluate website visitor flow and marketing campaigns.
To use obtained information to customize the website and its components according to user needs.

DIRECT MARKETING

We may use your Personal Data for direct marketing purposes, in particular to provide You with information regarding relevant products, services, publications and/or news. We process your data to study your preferences and needs, in order to inform You on products, services, publications and/or news that would be most suitable and preferable to You.

Your Data is processed upon your explicit consent. You are entitled to contact us at any time through the communication means listed below and request termination of processing of your Personal Data for direct marketing purposes. We hereby promise to satisfy your request within 7 (seven) business days upon the receipt of your request.

WHAT DO WE COLLECT

The Data processed by us may include information from the categories below:

IP address, type of device, operating system and browser, through which the website is visited;
Pages opened via our website, session duration and other parameters;
Information on the actions taken on our website: using interactive elements of the website, etc;
Information You are providing while communicating with us by sending letter by mail or e-mail.

HOW DO WE COLLECT YOUR PERSONAL DATA

We may collect Information about You from the following sources:

When You visit and/or use our website;
When You send us letters by mail or e-mail;
Publicly available sources.

WHO DO WE SHARE YOUR PERSONAL DATA WITH

Your Personal Data may be shared:

as mandated by law;
in case of using third party services as part of our business if disclosing your Data is required for the purposes of performing specific tasks;
in case the Company undergoes structural changes.

Please note that your Data will only be transferred to the third parties if all statutory requirements are complied with, including taking respective organizational and technical measures by the third parties to safeguard Your Data.

International Transfer

If your personal data is transferred internationally, it will be executed in adherence to the regulations set forth by the applicable legislation. Nevertheless, during such transfers, we will exert every effort to ensure that data is transferred securely and with complete confidentiality, fully complying with this Privacy Policy.

We will take appropriate steps to protect your personal information, including implementing suitable contractual clauses and other safeguards in compliance with relevant data protection laws. These safeguards may include obtaining Your explicit consent for the transfer or ensuring that third-party recipients of the information are trusted partners, bound by contractual obligations.

If you are living in EU/EEA and/or fall under the definition of a data subject according to the General Data Protection Regulation (GDPR), we will ensure a level of protection comparable to what is guaranteed within the European Union.

HOW LONG DO WE KEEP YOUR DATA

We retain your Personal Data for the entire period during which the services are provided to You and for 5 years upon completion of provision of services to effectively respond to your questions/complaints (if any). Please note that We may be required to keep your Data for a longer period if such is mandated by applicable law.

AUTOMATED DECISION-MAKING

Your Personal Data may undergo processing in an automated decision-making process (profiling). We hereby confirm that processing through the automated means will be carried out in accordance with the requirements of the applicable law and may be based on your consent, respective agreement concluded between us and/or fulfilment of obligations imposed onto TBC Asset Management.

You are entitled not to be subjected to any decision made only by the automated means (including profiling), except for the cases when decisions through profiling are made on the basis of your explicit consent, are necessary to conclude an agreement between us or perform the obligations under the existing agreement and/or is mandated by the applicable law/subordinate legal act.

KNOW YOUR RIGHTS

Your rights are protected by Georgian legislation that provides for numerous remedies available to You. In particular, You are entitled to:

Request and receive information about collection and processing of your Data, including, but not limited to which data is being processed, what is the purpose or legal basis for processing, sources for collecting and/or processing of the data, duration for which We keep the information. We hereby promise to respond comprehensively within 10 (ten) business days. The timeframe may be prolonged for additional 10 (ten) business days in exceptional cases regarding which We will inform You immediately.
Request access to your Data and/or the transfer of their copies in accordance with the requirements set by the applicable law.
Request rectification, updating and/or addition of the data if it is erroneous, inaccurate and/or incomplete.
Request us to block, cease processing (including, profiling), erase or destroy your Personal Data if collection and/or processing of the Data were conducted unlawfully. We retain the right to refuse your request in cases provided by the applicable legislation. Please further note that there may be limitations with respect to erasure and/or destruction of your Data under the applicable legislation. These limitations may stem from anti-money laundering, tax, consumer protection and/or other legislative acts that We are required to comply with.
Request receipt of the data provided by You in a structured, usable and electronic format or transmission of such data to another data processor if the personal data is processed on the basis of your consent and fulfilment of your request is technically possible.
Withdraw your consent on data processing at any time and without any explanation. If your consent was the sole basis for data processing, processing of the data will be ceased and such information will be deleted or destroyed.
Apply to respective bodies such as the Personal Data Protection Service and/or the court in case of breach of your rights.

COOKIES

In order to improve the quality of the website functionality and provide best experience for You, We monitor Customer behavior through Cookies i. e. small files stored on the user’s electronic device (computer, mobile, tablet, etc.) during our website visits which We collect.

Type of information We collect:

IP address, type of device, operating system and browser, through which the website is visited;
Pages opened via our website, session duration and other parameters;
Information on the actions taken on our website: using interactive elements of the website, etc.

We use the obtained information for the following purposes:

To generate and maintain website statistics for optimizing processes, fields, and design.
To evaluate website visitor flow and marketing campaigns.
To use obtained information to customize the website and its components according to user needs.
To determine how users visit our website and to compile Google Analytics reports.

Before starting using our website, you are given the option to accept the use of Cookies by clicking the respective button “accept”. You can restrict or refuse to use Cookies by changing the browser parameters. Please note that if you refuse to use Cookies, your experience on our website may be limited.

AMENDMENTS TO THE PRIVACY POLICY

This Privacy Policy may undergo changes from time to time. The amendments will become effective upon publishing the updated Privacy Policy on this website. Therefore, We strongly encourage You to regularly review the Privacy Policy.

HOW TO CONTACT US

Regarding any matter related to Personal Data protection (including exercise of your rights under applicable legislation) You can contact uson the following email: info@tbcamc.ge or reach us at #7 Marjanishvili street, Tbilisi.