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Privacy Notice

In this privacy notice, we explain what personal data we collect, how we use your personal data and your rights relating to your personal data. 

WHO WE ARE

FundProcess S.A.R.L. of 8 Rue Victor Prost L-6758 Grevenmacher Luxembourg, registered with the Luxembourg Registre de Commerce et des Sociétés under number B212276 and its representative offices, are the data controller for the purposes of this privacy notice.

WHAT WE DO 

As data controller, we collect, store and process, by electronic or other means, your personal data in accordance with the Luxembourg law of 1 August 2018 on the organisation of the National Data Protection Commission and the general data protection framework and the Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the data protection laws).

Personal data is any information that is related to an identified or an identifiable individual, such as you, that we may collect and process. 

HOW WE COLLECT PERSONAL DATA

We collect information from you in one or more ways:

  1. directly from you during your ongoing relationship with us; 
  2. from publicly available sources; or 
  3. from third parties providing us with services or acting on our behalf.
PERSONAL DATA WE COLLECT

We may collect and process the following types of personal data about you:

  1. personal details, such as your name, address, date and place of birth, nationality, contact details, employment or marital details;
  2. details of our ongoing relationship and your engagement with us, such as communication preferences, IP address, data obtained through cookies or similar technologies, attendance to events;
  3. financial information, such as banking information, source of wealth and source of funds; and
  4. any other personal data you may provide to us. 
HOW WE USE YOUR PERSONAL DATA

We collect and process your personal data for the purposes of:

  1. handling your queries;
  2. providing you with the services requested by you;
  3. managing our files and our client relationships; 
  4. reporting and management information, and our legitimate interests such as our governance;
  5. complying with our legal obligations, such as our client due diligence requirements; 
  6. maintaining and updating our contacts; and
  7. promoting our services.

We may also collect and process your personal data for other purposes with your consent. 

YOUR RIGHTS

You have the right to:

  1. access your personal data;
  2. request your personal data to be corrected or erased where it is incorrect, incomplete or irrelevant;
  3. object to your personal data being processed;
  4. withdraw your consent if you have consented to processing of your personal data for an explicit purpose, 
  5. request to receive your personal data or to have it transferred to another controller to the extent we process your personal data based on consent or if it is necessary to fulfil an agreement.

You may exercise your rights by sending an email to contact@fundprocess.lu. 

In some cases, if you refuse to provide us with personal data or withdraw your consent to our processing of your personal data, this may result in us not being able to provide services to you.

If you feel that we have not addressed your request appropriately, you may lodge a complaint with the National Commission for Data Protection.

WHEN AND HOW WE SHARE YOUR PERSONAL DATA 

We may share your personal data:

  1. within FundProcess; 
  2. with any service provider to the extent necessary for such service provider to provide services to us and to assist us in providing services to you;
  3. with non-third parties working on our or your behalf, such as banks, other professionals of the financial sector, chartered accountants, notaries, bailiffs, independent experts and other lawyers to the extent that it is necessary for the performance of the agreement or because it is required by law; or
  4. with government or regulatory bodies as may be required by law or other valid legal process brought against us. 

We may transfer your personal data to other organisations located in and outside the European Economic Area (EEA), but we will not transfer your personal data to any country outside the EEA that does not ensure an adequate level of protection, unless (i) you consent to that transfer, or (ii) we have taken specific measures (such as adequate contractual arrangements) to ensure that we comply with the data protection laws. 

HOW WE PROTECT YOUR PERSONAL DATA

We take precautions to safeguard your personal data against loss, theft and misuse, unauthorised access, disclosure and destruction through the use of appropriate administrative, physical and technical security measures.

HOW LONG WE KEEP YOUR PERSONAL DATA

We apply different retention periods for different categories of personal data. In general, we will keep your personal data for as long as required for the provision of our services to you, subject to statute of limitation.

When the processing of your personal data is no longer necessary for the purpose for which it was collected, we will erase it.

CHANGES TO THIS PRIVACY NOTICE

This privacy notice was last updated on 21 October 2024.

We may update this privacy notice at any time. Any changes to this privacy notice will be posted to this page.