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    • Data Protection Policy

    This privacy policy aims to provide all relevant information regarding the processing of personal data carried out by Independencia Internacional Administradora General de Fondos S.A. (hereinafter, “Independencia”) in relation to users of the website www.indafi.cl (hereinafter, the “Website”) and contributors to Independencia’s investment funds. 

    “Users” shall be understood as all natural persons who access, browse, and use the Website (hereinafter, the “Users”).

    “Contributors” shall be understood as all natural persons and the legal representatives of legal entities who invest in the funds managed by Independencia (hereinafter, the “Contributors”).

    This Privacy Policy will always be available on the Website.

    1. ¿WHO ARE WE?

    The company responsible for the processing of personal data is Independencia Internacional Administradora General de Fondos S.A., a company incorporated under Chilean law, RUT No. 76.800.115-4, with its registered office at Rosario Norte No. 100, 15th floor, Las Condes district.

    2. ¿WHAT IS PERSONAL DATA PROCESSING?

    Personal data refers to any information about an identified or identifiable natural person, such as their name, national ID number, phone number, or email address, as well as any other elements related to a person’s identity.

    Such an identified or identifiable natural person, to whom the personal data relates, is referred to as the data subject.

    Personal data processing involves any operation or set of operations carried out on personal data, such as its collection, recording, storage, use, and communication.

    3. ¿HOW DO WE COLLECT YOUR PERSONAL DATA?

    We collect personal data through the following channels:

    1. When you invest in any of the funds managed by Independencia.
    2. When you fill out forms available on the Website, such as the contact form or the whistleblower channel form.
    3. When you register for and participate in events organized by Independencia.
    4. When you interact with and use the Website’s features.

    In cases where Independencia collects personal data through third parties, it will first require them to declare and guarantee that they have obtained the appropriate consent or legal authorization to share such personal data with us, and that they fully comply with applicable data protection laws.

    4. ¿WHAT PERSONAL DATA DO WE PROCESS?

    To carry out the processing activities described in this Privacy Policy, Independencia collects and uses the following categories of personal data from Users and Contributors, as applicable:

    1. Identification data: Full name, national ID number, nationality, date of birth, and gender.
    2. Contact data: Mobile phone number, email address, and residential address.
    3. Employment and financial data: Professional activity, income, current position, among other similar information.
    4. Banking data: Bank account number, credit card or current account number.
    5. Website data: Type of internet browser used, search engine used, time spent browsing the site, access and exit date and time, number of visits, and IP address.
    6. Politically Exposed Person (PEP) information: Type of relationship, name, position, and entity of the person identified as a PEP.
    7. Legal and background data: Identification of the legal entity.

    5. ¿WHAT PROCESSING DO WE CARRY OUT AND FOR WHAT PURPOSES?

    This section explains the types of data processing we perform, the purposes we pursue, and the legal basis for each type of processing.

    a) Managing the relationship with Contributors to the funds managed by Independencia.

    ¿For what purpose?

    • Properly manage the relationship with Contributors in relation to contributions, quota redemptions, and other matters concerning investments in funds managed by Independencia.
    • Properly manage the relationship with Contributors in relation to contributions, quota redemptions, and other matters concerning investments in funds managed by Independencia. The legal basis is the Contributor’s express consent.
    • Manage the participation of Contributors in shareholders’ meetings and informational sessions, as well as the development of such events.
    • Send electronic communications to keep Contributors informed about their investments and other commercial or financial news that may be of interest to them.
    • Manage communications regarding information about financial instruments.
    • Handle any incidents related to the relationship with Contributors.
    • Address and resolve questions or requests from Contributors.
    • Take appropriate actions in cases where a Contributor fails to meet their obligations.

    ¿On what legal basis?

    The legal basis is the Contributor’s express consent.

    b) Analysis of the Contributors’ investments

    ¿For what purpose?

    • Control, detect, prevent, and/or report fraudulent and/or criminal behavior.
    • Investigate the origin of the Contributors’ funds.
    • Maintain the security of Independencia’s investment funds.

    ¿On what legal basis?

    The legal basis is compliance with legal obligations established under Laws No. 21.595, No. 20.393, No. 19.913, the Penal Code, and other regulations related to the prevention of fraud, corruption, money laundering, and other crimes.

    c) Contact and User Support Service.

    ¿For what purpose?

    • Process and respond to inquiries, questions, or other information requests submitted through the available communication channels.
    • Contact and provide the requested information to Users.
    • Manage any report submitted by Users through the corresponding form.

    ¿On what legal basis?

    The legal basis is the User’s express consent.

    d) Management of Participation in Events Organized by Independencia

    ¿For what purpose?

    • Properly manage the registration and participation in events (webinars, demos, courses, activities, among others) organized by Independencia.
    • Ensure the correct and proper development of the event.

    ¿On what legal basis?

    The legal basis is the participant’s express consent.

    e) Management of Data Subjects’ Rights Requests

    ¿For what purpose?

    • Process and contact data subjects regarding their rights requests as established in Law No. 19.628 on the Protection of Private Life.
    • Keep records proving compliance with the exercise of such rights.

    ¿On what legal basis?

    The legal basis is compliance with a legal obligation.

    f) Website Usage Management and Analysis

    ¿For what purpose?

    • Enable Users to navigate the Website and properly use its functionalities.
    • Ensure the security of the Website.
    • Differentiate Users and sessions.
    • Analyze User behavior and browsing activity.

    ¿On what legal basis?

    The legal basis is your express consent.

    6. ¿HOW LONG DO WE RETAIN YOUR DATA?

    Independencia will process and retain personal data only for as long as necessary to fulfill the provision of services or to meet the purpose for which the data was collected.

    Notwithstanding the above, whenever the processing is based on your consent, you may exercise your right to cancellation or blocking, unless there is a legal basis that allows us to retain your data.

    7. ¿WHO DO WE SHARE OR GRANT ACCESS TO YOUR DATA?

    Independencia may share your personal data in the following cases and with the following entities:

    1. With affiliated companies and/or those belonging to the same corporate group, when necessary to fulfill the purposes of data processing.
    2. With service providers who help improve and optimize the Website, as well as technology and data storage providers (e.g., investment management software providers).
    3. With third-party providers whose involvement is necessary to fulfill the general fund agreement entered into with Contributors, such as registration agents, accountants, and auditors.
    4. With legal advisors, courts, supervisory authorities, and public entities, whether national or foreign, when necessary to: (i) comply with legal obligations applicable to Independencia, (ii) initiate legal proceedings, or (iii) exercise legal rights before courts.
    5. In the event of a reorganization, restructuring, merger, sale, or any other transfer of assets involving Independencia, provided that the recipient agrees to handle personal data in accordance with this Privacy Policy.

    In any case, we will only share personal data when necessary to fulfill the relevant processing purposes, and in strict compliance with this Privacy Policy and applicable legislation.

    8. ¿WHEN DO WE PERFORM INTERNATIONAL DATA TRANSFERS?

    We will only transfer your personal data to service providers or other third parties located in other countries when necessary to fulfill the specific purposes of processing.

    In line with the previous section, Independencia may transfer your personal data to third-party providers located outside the country to carry out investment and asset management processes required to fulfill its contractual relationship with Contributors.

    Likewise, Independencia may transfer your personal data to affiliated companies or those within the same corporate group located abroad, when necessary for the purposes of data processing. Transfers may also be made to international supervisory authorities or public entities when required to comply with legal obligations, such as those established by FATCA (Foreign Account Tax Compliance Act) or the Corporate Transparency Act (CTA).

    In all cases, for any international transfer of personal data, Independencia ensures that the recipient provides an adequate level of data protection, as defined by applicable legislation

    9. ¿WHAT RIGHTS CAN YOU EXERCISE AS A DATA SUBJECT?

    1. Right of access: To request confirmation as to whether your personal data is being processed and, if so, to learn what data is processed, its origin, recipient, purpose of storage, and the persons or organizations to whom the data is disclosed.
    2. Right of rectification: To modify, update, or correct any data that is partially or wholly incorrect, inaccurate, misleading, or incomplete. The data subject must specify the data to be corrected and provide appropriate documentation.
    3. Right of cancellation: o delete personal data you voluntarily provided when its storage lacks legal basis or it is obsolete, unless a legal exception applies. In certain cases, deleting specific data may result in Independencia being unable to carry out certain operations or investments contracted by the data subject.
    4. Right of blocking: o temporarily suspend data processing operations in cases where (i) the data was provided voluntarily and is used for informative communications, or (ii) the accuracy or validity of the data is in doubt, and deletion is not appropriate.
    5. Right of objection: To object to the use of your personal data for advertising, market research, or opinion surveys.

    10 ¿HOW CAN YOU EXERCISE YOUR RIGHTS?

    You may exercise your rights free of charge by sending an email to aportes@indepasset.com, indicating in the subject line: “Request to exercise the right of [type(s) of right(s) being exercised]” and including the following information:

    1. Full name of the data subject.
    2. Documents proving the identity of the data subject.
    3. Address or email to receive notifications.
    4. Description of the right being exercised through the request.

    Once the request is received, Independencia will contact the data subject to properly process the request and will keep them informed of any progress until the process is concluded by an official response from Independencia.

    If you have any questions about how we process your data, you can contact us at aportes@indepasset.com.

    11. ¿IS YOUR DATA SAFE?

    Independencia applies proper procedures and information systems and implements the necessary technical and organizational security measures to ensure a level of protection appropriate to the risks involved in the data processing described in this Privacy Policy. To protect the confidentiality of your information, we use strict security procedures to prevent unauthorized access or processing.

    Employees and any personnel of Independencia who have access to personal data are required to maintain its confidentiality indefinitely, even after their contractual relationship with Independencia ends.

    We also ensure that our service providers and any third parties who process data on our behalf maintain appropriate security standards for the protection of the data they access, in compliance with applicable legislation.

    12. CHANGES TO THE PRIVACY POLICY

    Independencia may modify this Privacy Policy when necessary. If such modifications involve relevant aspects of personal data processing – such as the type of processing, its purposes, or if required by data protection regulations – Independencia will notify you of the changes via electronic means using your contact information and will request your renewed consent.

    In other cases, Independencia may update this Privacy Policy at any time, and such changes will become effective upon publication on the Website. Data subjects who disagree with the Privacy Policy or the aforementioned changes may withdraw their consent at any time.