Last Updated September 2023

Implementation of recent legislative and regulatory developments as well as editorial amendments, addition of new fund under “IV. Sustainability-related disclosures”

Publication Date March 2021

Sustainability-Related Disclosures Pursuant to Regulation (EU) 2019/2088 (“SFDR”)


    1. We at 468 Management GmbH (LEI: 391200C6AMOLCYIK2A09) (hereinafter referred to as “468”, “Us” Or “We”) know that you, the user, care about how information about you is used, shared, and processed, and We appreciate your trust in using Our services.
    2. This privacy policy (the “Policy”) explains how and for what purposes We use the Personal Data collected about you via (the “Website”).
    3. The Website is not intended for use by persons under thirteen (13) years of age (“Children”), and by no means do We knowingly collect Personal Data in relation to Children, except with the consent of parents or legal guardians.
    4. Any Processing of Personal Data gathered as a result of the use of this Website by consumers or other persons is governed by the provisions of data protection legislation, in particular Regulation (EU) 2016/679 (“GDPR”) and the Maltese Data Protection Act (Chapter 586 of the Laws of Malta).
    5. Please read this Policy carefully. It can easily be accessed via a link at the bottom of each web page. By using the Website and any services We offer, you are agreeing to be bound by this Policy in respect of the information collected about you.
    6. By visiting the Website, you agree to Us handling your Personal Data as set out below. If you do not agree to 468 using your Personal Data in those ways, then you should not visit the Website.
    7. If you have any queries or comments about the Policy, Our use of your Personal Data or wish to unsubscribe from messages from Us, please get in touch through via email on
    8. Any capitalised terms used in this Policy, and not defined, shall have the same meaning assigned to them in the GDPR and their cognate terms shall be construed accordingly.
    1. The Data Controller of the Website is 468 Management GmbH situated at Wielandstraße 26-26A, 10707 Berlin, Germany.
    1. We collect your Personal Data in order to be able to provide you with a better-quality service.
    2. The following is a list of Personal Data We collect:
      1. name;
      2. surname; and
      3. email address.
    3. Any other information you voluntarily provide.
    4. With respect to the collection, use and Processing of Personal Data of Children, We will only collect, use and Process such data with the consent of their parents or legal guardians.
    5. How We collect your Personal Data:
      1. information provided at the time of sign up for Our email newsletters;
      2. when you request that promotional emails be sent to you;
      3. information provided when you contact our team; and
      4. any other time you provide any information about yourself.
    1. We use your Personal Data in the following ways:
      1. to improve the website and our services;
      2. to send you service messages by email;
      3. to provide customer care and support;
      4. for security and to verify your identity;
      5. to provide you with marketing or promotional material (where you have consented for us to do so); and
      6. to communicate with you.
    2. No matter how We specifically use the information provided to Us, We have been careful to ensure that, at all times, We have a lawful basis for Processing your Personal Data in accordance with the relevant provisions of the GDPR. Our lawful basis for Processing your Personal Data may include:
    3. where you specifically consent to Our Processing of your Personal Data for one or more specific purposes; for example, if you have agreed to the terms of this Policy, you have specifically provided Us with consent to use your Personal Data for the purpose of sending you service messages, for instance; and
    4. where Processing your Personal Data is necessary for compliance with a legal obligation to which We may be subject: for example, in certain situations, We may be obligated by law to provide your Personal Data to the lawful authorities. For instance, if you are the subject of criminal compilation proceedings, We may be required to provide certain Personal Data relating to your activity on the Website.
    5. Any Personal Data that you provide Us with will be stored in Our database and may not need to be provided again, in order to provide a smoother user experience.
    6. No Personal Data will be stored, in any circumstance, beyond the legal retention periods allowed by Maltese law and, where applicable, European Union law.
    1. In certain circumstances We may share your Personal Data that you provide Us with other organisations outside of 468. The Third Parties with whom We may share your Personal Data include:
      1. Our service providers;
      2. Third Party support services;
      3. referring websites;
      4. business affiliates; &
      5. law enforcement authorities.
    2. Whilst 468 has procedures and security features in place to protect your Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction, and damage, 468 does not control the privacy practices of any of the abovementioned organisations and therefore you are encouraged to review their privacy policies where appropriate.
    3. Furthermore, any information that you provide directly to Third Parties is not covered under this Policy.
    1. If you opt in to receive marketing communications from Us, you consent to the Processing of your Personal Data to send you such communications, which may include newsletters, blog posts, surveys and information about new events. For the avoidance of doubt, We will retain a record of your consent.
    2. You can choose to no longer receive marketing communications by contacting Us at [-] or clicking ‘unsubscribe’ from a marketing email. If you do unsubscribe to marketing communications, it may take up to five business days for your new preferences to take effect. We shall therefore retain your Personal Data in Our records for marketing purposes until you notify Us that you no longer wish to receive marketing emails from Us.
    1. A cookie is usually a small piece of data sent from a website and stored in a user’s web browser while a user is browsing a website. They are used by web developers to help users navigate their websites efficiently and perform certain functions. Cookies allow the Website to keep track of user activity on the Website and allows Us to analyse such activity to be able to provide you with a better overall experience. As a result when a user browses the Website in the future, the data stored in the cookie would be retrieved by the Website to notify the Website of the user’s previous activity, thereby distinguishing the user from others using the Website. Due to their core role of enhancing and enabling usability or site processes, disabling cookies may result in a sub-optimal user experience.
    2. The Website uses cookies to help Us provide you with the best possible experience and to allow us to improve the Website. By continuing to browse the Website, you are agreeing to Our use of cookies.
    3. We may also collect information about your computer, including, where available your:
      1. operating system;
      2. browser type; and
      3. system information.
    4. We may use this information to report aggregate information to Our advertisers. This is statistical data about Our users’ browsing actions and patterns and shall not be used in any way for the purposes of identifying an individual.
    1. We are committed towards ensuring that any Personal Data collected in relation to the Website is kept safe and secure at all times. We have taken all reasonable measures to prevent unauthorised access or disclosure of such Personal Data through the installation of appropriate physical, electronic and managerial procedures to safeguard and secure any information collected through the Website.
    1. We undertake to store and, or to transmit your Personal Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity. To ensure that your Personal Data is treated securely and in accordance with this Policy, We will endeavor to take all reasonably necessary steps in protecting your privacy and your Personal Data. All information you provide to Us is stored on Our secure servers. However, We have no control over the transmission of information over the internet and therefore cannot guarantee the security of data transmitted to the Website.
    2. While We undertake to take all commercially reasonable steps to guarantee the security of your Personal Data, We unequivocally relieve ourselves from any liability and take no responsibility for any unauthorized access to or use of Our secure servers and/or any and all Personal Data stored therein, and you agree to hold Us harmless for any loss or damage that may result therefrom. Therefore, any transmission of Personal Data is at your own risk.
    3. Some, or all, of your Personal Data may be stored or transferred outside of the European Union for any reason, including for example, if Our email server is located in a country outside of the European Union or if any of Our service providers or their servers are based outside of the European Union. We shall only transfer your Personal Data to organisations that have provided adequate safeguards in respect of your Personal Data.
    1. From time to time the Website may contain links to and from the websites of third parties. If you visit any of these websites, please note that they may have their own privacy policies and therefore, you should review such policies before providing any Personal Data. We shall not accept any responsibility or liability for any third-party policies.
    1. As an individual you may exercise your right to access the data held about you by Us by submitting your request in writing to the Data Controller.
    2. Although all reasonable efforts will be made to keep your Personal Data updated, you are kindly requested to inform Us of any change with respect to the Personal Data held by Us. In any case, if you consider that certain Personal Data about you is inaccurate, you may request its rectification.
    3. If you have any complaints in relation to this Policy or otherwise in relation to Our Processing of your Personal Data, you should contact The Office of the Information and Data Protection Commissioner.
    4. You have the right, at any time, to:
      1. require that We delete your Personal Data and request data portability;
      2. request that We restrict the Processing of your Personal Data, under certain conditions;
      3. object to Us Processing your Personal Data, under certain conditions; and
      4. request that We transfer your Personal Data to another organisation, or directly to you, under certain conditions.
    1. We may change this Policy from time to time without notice as We add new features, or in response to changes in applicable laws or commercial arrangements. Any changes to this Policy will be posted on the Website.
    2. In changing this Policy, We undertake:
      1. not to materially change this Policy in a manner that reduces protection of your Personal Data; 
      2. where changes are made to this Policy, to ensure that the differences between successive versions are readily accessible; and
      3. to maintain all prior versions of this Policy in such a manner that they are dated, and readily accessible. 
    1. This Policy shall be governed by and construed in accordance with the laws of Malta. By accessing the Website, you consent to the exclusive jurisdiction of the courts of Malta in all claims or disputes arising in relation to or in connection with this Website and its use and the Policy.
  14. CONTACT 
    1. Thank you for taking the time to read this Policy.
    2. Any comments or suggestions that you may have, and which may contribute to a better quality of service will be welcomed and greatly appreciated. These may be sent via email on

This Policy was last updated on 24th November 2023.