Introduction
This Privacy Policy explains how MB Lady Christina ("MBLC", "we", "us", or "our") collects, uses, stores, and protects personal data in connection with your visits to www.mblc.lt, any communication you send us, or any services you request.
MBLC operates strictly as an On-Demand Hedge Fund Materials Provider and a Request-Only Hedge Fund Consultant. Our business model is built exclusively on explicit mutual agreement. We are not a marketing firm, we do not conduct mass marketing campaigns, we do not solicit clients or investors, and we do not provide investment advice, brokerage, asset management, or any regulated financial services. All services are provided solely within a narrow, specialized niche of technical and operational consulting, and materials support for institutional clients and professional counterparties who have specifically granted permission for such engagement.
By accessing our website or submitting any information to us, you acknowledge that you have read, understood, and agree to the practices described in this Policy. We are committed to the highest standards of data protection and transparency in line with the General Data Protection Regulation (GDPR) and other applicable laws in the European Union and the Republic of Lithuania.
Scope of This Policy
This Policy applies to any personal data that MBLC collects, processes, or otherwise controls, including data obtained through our website, email communications, contact forms, or any other interaction where you voluntarily provide information to us.
It covers all individuals who interact with MBLC, whether as website visitors, enquirers, or institutional clients. The Policy does not apply to personal data processed by third-party websites or services linked from our site, nor to any data collected by our institutional clients in their own operations.
Processing of personal data is carried out on the lawful bases of legitimate interest, contractual necessity, legal obligation, or consent where required.
Personal Data We Collect
We collect and process only the minimum personal data that is strictly necessary to respond to your explicit requests and to deliver the requested services. We do not collect data proactively or for any speculative purposes.
The categories of personal data we may collect include:
- Your full name
- Email address
- Company or organisation name
- Job title or professional role
- Business contact details (telephone, postal address)
- Content of communications or enquiries submitted through our forms or email
- Technical website usage data (IP address, browser type and version, operating system, referral source, pages visited, and timestamps – collected automatically for security and functionality)
We do not collect financial, trading, investment, or sensitive personal data (as defined under GDPR Article 9) unless it is voluntarily provided by an institutional client as part of a specific, requested engagement and is strictly necessary for the delivery of the agreed services.
You may visit and browse our website completely anonymously without providing any personal data. No cookies or tracking technologies are used for marketing or profiling purposes.
How We Use Personal Data
We use personal data solely for the following legitimate, narrowly defined purposes:
- To respond to your enquiries and process requests you have explicitly submitted
- To provide the specific information, materials, or consulting services you have requested
- To maintain professional, request-driven communication with existing institutional clients
- To keep accurate records of business communications for legal and compliance purposes
- To ensure the security, functionality, and performance of our website
- To comply with legal and regulatory obligations applicable to MBLC
- To generate anonymised and aggregated website statistics and maintain cybersecurity and system integrity
We do not use personal data for any other purpose, including advertising, profiling, or any commercial activity outside the strict scope of your explicit request. Our legal bases under GDPR include Article 6(1)(b), 6(1)(c), and 6(1)(f).
No Marketing or Solicitation
MBLC may engage in selective, professional outreach to institutional counterparties and industry partners regarding potential collaborations, partnerships, or service offerings. Such communications are strictly business-to-business in nature and are not directed at retail investors or the general public and should not be considered as Marketing emails.
To ensure absolute clarity and legal certainty, we expressly and irrevocably state the following:
No Investment Advice Disclaimer
MBLC does not provide, and does not purport to provide, any investment advice, financial advice, brokerage services, asset management, portfolio management, or any regulated financial services. Our role is strictly limited to the provision of specialized technical, operational, and materials support within a narrow niche scope for institutional clients who have specifically requested such services.
Any information, documents, software, or materials we supply are of a purely technical or operational nature and must not be interpreted, relied upon, or used as investment advice, a recommendation, an endorsement, or a solicitation to buy, sell, or hold any investment, security, or financial instrument.
Risk Disclosure and Client Responsibility
All institutional clients and recipients of our services remain fully and solely responsible for their own due diligence, independent evaluation of any third-party partner firms, and all investment, operational, or strategic decisions.
MBLC does not verify, guarantee, endorse, assess the suitability of, or accept any liability for any third-party partner firms, materials, software, or services. Any engagement with third parties is undertaken solely at the client's own risk and discretion.
MBLC expressly disclaims any and all liability for losses, damages, or consequences arising from the use of any information, materials, or services provided by us or any third parties.
Disclosure of Personal Data
We do not sell, rent, or otherwise monetize personal data under any circumstances.
Personal data may be shared only when strictly necessary and only with the following categories of recipients, each bound by contractual obligations of confidentiality and data protection:
- Technical service providers (e.g., website hosting, secure email delivery systems)
- Professional advisers (legal counsel or compliance consultants) where required for legitimate business or regulatory purposes
- Public authorities or regulators when required by applicable law or court order
- Professional data storage platforms and secure systems used to manage professional partnerships and business client data.
All third parties are contractually required to maintain appropriate data protection standards equivalent to or exceeding those required by the GDPR.
International Data Transfers
Our service providers may store or process personal data in the European Union or in other jurisdictions that have been deemed to provide an adequate level of protection under GDPR, or where appropriate safeguards are in place (such as Standard Contractual Clauses approved by the European Commission or other valid transfer mechanisms).
We take all reasonable steps to ensure that any international transfer of personal data is carried out in full compliance with applicable data protection laws and that your rights are adequately protected.
Data Security
We implement and maintain appropriate technical and organisational security measures designed to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, damage, or disclosure. These measures include, but are not limited to, encryption, access controls, regular security audits, and staff training.
Access to personal data is strictly limited to authorised personnel who require it for legitimate business purposes and who are bound by confidentiality obligations. Passwords are always encrypted using no less than minimum industry-standards are are not accessible in any form even hashed to any company personnel.
Data Retention
We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, to maintain accurate business records, or to comply with legal and regulatory obligations (including tax, accounting, and anti-money laundering requirements).
When personal data is no longer required, it is securely and irreversibly deleted or anonymised in accordance with our data retention policy and applicable law (ip address collection for statistical review is unrelated).
Professional contact data may be retained for ongoing business relationship management and future partnership communications where lawful.
External Links
Our website may contain links to third-party websites for your convenience. We are not responsible for the privacy practices, content, or data handling of any external websites. We encourage you to review the privacy policies of any third-party sites you visit.
Your Rights (GDPR)
Under European law, you have the following rights in relation to your personal data (subject to applicable legal limitations):
To exercise any of these rights, please submit a written request to info@mblc.lt. We will respond to your request within the timeframes prescribed by applicable law.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the most recent version will always be displayed at the top of this page. We encourage you to review this Policy periodically. Continued use of our website or services after any update constitutes your acceptance of the revised Policy.
Contact
For any questions regarding this Privacy Policy or our handling of your personal data, please contact us using the details below.
This Privacy Policy is a legally binding document forming part of the terms of engagement with MB Lady Christina. It is designed to be clear, transparent, and fully compliant with European law.
Intermediary Non-Interference & Allocator-Only Review Policy
MBLC operates a strictly controlled, request-only partner portal environment designed exclusively for professional institutional allocators and investors.
To preserve independence, regulatory neutrality, and decision integrity, MBLC enforces the following principles: