of LFP I SICAV umbrella fund |
This Privacy Notice explains how LFP I SICAV, represented by its directors ("the directors", "we", "us" or "our"), uses, shares and otherwise processes your Personal Data in connection with your relationship with us as a shareholder or investor in accordance with the data protection laws applicable to the Grand-Duchy of Luxembourg and the EU General Data Protection Regulation n°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 "GDPR").
We control the ways your Personal Data are collected, and the purposes for which we use your Personal Data in our role of "data controller" under the meaning of data protection laws that apply to us, including the GDPR.
When using the term "Personal Data" in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold. Your Personal Data may include for example your name, your contact details or information on how you interact with us.
We process your Personal Data only:
We may collect the following personal information from you in the course of the liquidation:
Data category | Type |
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Personal identification information |
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Professional information |
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Financial Information |
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Tax information |
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If relevant for the liquidation, where you are a shareholder, we may also collect information about your business partners (including other shareholders or beneficial owners), directors, representatives and authorized signatories. Before providing the liquidators with this information, you should provide a copy of this notice to those individuals.
In the course of providing services to you, we may collect information that could reveal your racial or ethnic origin or conviction of criminal offences. Such information is considered as "sensitive personal data" under the GDPR. We only collect this information in the case you have given your explicit consent, it is necessary according to legal obligations, or you have deliberately made it public.
For example, we may collect this information when you provide us with your personal documentation copy of passport or ID card, your nationality and/or photo may imply your racial or ethnic origin.
By providing any sensitive personal data you explicitly agree that we may collect and use it for the purposes of the liquidation and in accordance with this Privacy Notice.
We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. In particular, we process your Personal Data for the following purposes:
We will only use your Personal Data for the purposes for which we collected it and which we informed you about, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Under the GDPR you have various rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:
If you want to exercise one of these rights please contact us using the contact details provided below.
If you are not satisfied with our response, you also have the right to lodge a complaint with the National Commission for Data Protection ("CNPD"), the Luxembourg supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.
We are committed to taking appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing and against accidental loss, disclosure, destruction or damage.
Your Personal Data is stored in Luxembourg in electronic and physical form. Any physical documentation is kept in a restricted and secure location. Electronic files that contain Personal Data are stored within a secured IT infrastructure.
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
Where we need to further process your Personal Data for purposes other than that for which it was collected, we shall provide you with any relevant additional information prior to doing so.
Personal Data may be transferred to other entities or individuals located in and outside the European Economic Area ("EEA") including:
Personal Data will nevertheless not be transferred to any country outside the EEA which does not ensure an adequate level of protection unless:
In any case, any transfer of Personal Data will be undertaken in compliance with the strict professional secrecy rules under Luxembourg law.
We will only retain your Personal Data for as long as we need it, subject to the legal limitation periods, in order to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
Upon expiry of the applicable retention period we will either securely destroy your Personal Data in accordance with applicable laws and regulations or anonymise your Personal Data so that it can no longer be associated with you (in which case it is no longer considered as Personal Data).
Data subjects will in general not have to pay a fee to exercise any of their individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if a request to exercise individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We are committed to keeping your Personal Data accurate and up to date. Therefore, if your Personal Data changes, please inform us of the change as soon as possible using the contact information provided below.
We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Notice at any time, and we will make an updated copy of such privacy notice publicly available.
If we make any material changes to this Privacy Notice, we will notify you accordingly, by email or by means of a notice on our website.
If you have questions or concerns regarding this Privacy Notice or you wish to exercise your rights in relation to your Personal Data, please contact us at the below address.