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Privacy Policy

When you visit our website or you are in contact with us by investing in our funds, receive our newsletters or attend our seminars, Holberg Fondsforvaltning will process personal data about you. Below you will therefore find information about the personal data that is collected, why we do this, and your rights related to the processing of the personal data.

Why we collect personal data and what information we collect

We collect and use your personal data for various purposes depending on who you are and how we come into contact with you. We collect the following personal data for the purposes stated here:

  • Register new customers. Statutory information about new customers must be registered when creating a customer relationship. The personal information is your name, social security number, address, bank account number, e-mail address, telephone, fund holdings, transaction history, VPS accounts, identification documents, citizenship, customer reports etc. as well as information from Trapets whether you are on a sanctions list or is a politically exposed person (PEP) . The personal data will be stored in accordance with the Money Laundering Act, or as long as necessary for the customer relationship.
  • Sending out newsletters/Holberggrafene, invitations to our professional seminars and information about our funds: e-mail address, name, telephone, address. The processing takes place on the basis of your consent. We store the personal data in this connection when you subscribe to the newsletter/Holberggrafene. On the basis of a balancing of interests, we can carry out troubleshooting and internal statistics to improve the service, e.g. see whether the email actually reached you, whether you have unregistered as a recipient, your geographical location when you opened the email (e.g. "Oslo") and whether you have clicked on links in the email. Your consent can be revoked at any time by clicking Unsubscribe at the bottom of our newsletters/Holberggrafene or by sending an e-mail to
  • Respond to inquiries and requests we receive. Name, telephone number, e-mail address and any personal information that may result from the inquiry. The processing of personal data takes place on the basis of a balancing of interests for our funds. We have considered it so that this is often necessary for us to be able to provide good customer service. Holberg Fondene deletes personal data when it is no longer necessary to fulfill the purpose for which it was collected. 
  • Recruitment for new positions with us. CV, application, certificates and references. Processing of personal data takes place on the basis of our legitimate interest by reviewing the application documents in an application round. If you do not get the position you applied for, your personal data will be deleted within 300 days after the application deadline. For applicants who are employed, application documentation is kept throughout the employment period. If employees leave, all personal data is deleted as a general rule within 60 days to 5 years after the employment has ended. 
  • On our website we use cookies. Cookies do not contain personal data in themselves, but they support core functionality related to CMS (Content management system), security, and navigation on the websites. We have assessed these as necessary, and they are therefore stored without consent."

Personal data that is necessary for our customer relationship with you or required by legislation will need to be handed over to us before we can carry out our contractual obligations with you.

For portfolio management, we use the Cairo system from Centevo internally. Cairo runs on Centevo's servers. Cairo is run daily by HFF, but Centevo's consultants are used when upgrading the system for the time the work takes.

Disclosure of personal data to others

We do not pass on your personal data to others unless there is a legal basis for such disclosure. Examples of such a basis would typically be an agreement with you or a legal basis that requires us to release the information.

Data processors

Holberg Fondsforvaltning AS uses data processors as suppliers of IT system solutions for internal systems and customer systems, and thus safeguard or otherwise process personal data on our behalf. We have entered into agreements to safeguard information security in the processing of personal data with our cooperating data processors. All processing of personal data that we undertake takes place within the EU/EEA area.

Your rights when we process personal data about you

You have the right to demand access, correction or erasure of the personal data we process about you. You also have the right to demand limited processing, object to the processing and demand the right to data portability.

You can read more about the content of these rights on the Norwegian Data Protection Authority's website:

To exercise your rights, you must send a written inquiry to Holberg Fondsforvaltning AS at We will respond to your inquiry as quickly as possible, and within 30 days at the latest.

We will ask you to confirm your identity or provide additional information before we allow you to exercise your rights with us. We do this to be sure that we only give access to your personal data to you, and not to someone pretending to be you.

Automated decisions

Holberg Fondsforvaltning AS does not make automated decisions based on your personal data.


If you believe that our processing of personal data is not in accordance with what we have described here or that we are in breach of privacy legislation in other ways, you can complain to the Norwegian Data Protection Authority. You can find information on this here:


If there is a change to our services or changes to the regulations on the processing of personal data, this may result in changes to the information you are provided here. Updated information will be readily available on our website.