General Data Protection Regulation
Data Protection Web Policy

Fundsquare (“Fundsquare”) is dedicated to deal with and process your Personal Data (as defined in point 1 below) with due care, in confidence and in accordance with the requirements of the General Data Protection Regulation.

1. Data Protection – Key definitions and principles

GDPR: the General Data Protection Regulation (EU) 2016/679 is an EU regulation on personal data protection and privacy. GDPR achieves the uniformity in the data protection rules applicable to all individuals within the European Union.

Personal Data: any information related to an identified individual or that may allow to directly or indirectly identify an individual (e.g. name, phone number, job title). Personal Data does not include any information or data related to legal entities (e.g. investment funds, securities issuers…).

Processing: any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means (e.g. collection, recording, organization, storage, consultation).

Data controller: the person or entity that determines the purpose and means of the processing of the Personal Data.

2. Scope of Policy

The present Data Protection Web Policy (the “Policy”) does not apply to any processing of your Personal Data by Fundsquare when you are a client, a commercial counterparty, a provider or supplier, an employee or any person with who Fundsquare has established or is in the process of setting up any contractual, legal or commercial relationship.

The Policy only explains how and why Fundsquare collects and uses your Personal Data when:

  • You use Fundsquare’s website (the “Website”) or any functionalities or request form available on the Website; and
  • You request the sending of communications or invitations from Fundsquare.

In both cases, Fundsquare acts as data controller.

3. Processing of your Personal Data

3.1 Use of the Website

When you use the Website or any functionality of it, Fundsquare collects and processes your Personal Data as follows:

  • Collection of your Personal Data: Your Personal Data are collected through cookies (text files which are stored on your computer by your browser), through the information received from your browser, and/ or when you log in to dedicated or personalized pages of the Website.
  • Personal Data collected by Fundsquare: Fundsquare will collect your IP address, the pages of the Website you visit, the duration and time of your visit as well as in some cases, your name, address, phone number and/or email address.
  • Legal ground(s) for the processing of your Personal Data: legitimate interest (as defined by GDPR): management and security of the website.
  • Processing of your Personal Data: Fundsquare will process your Personal Data for:
    • Obtaining statistical data about the use and access volume of the Website so as to improve the quality and efficiency of Fundsquare’s services and create a better experience by enhancing functionalities and by reaching a better user-friendliness level,
    • Manage and operate the Website, and
    • Make your access to dedicated webpages faster and easier.

Any further use of your Personal Data, out of that context, will require another specific consent.

3.2 External communications and invitations

When you request the sending of communications and/ or invitations by Fundsquare, Fundsquare collects and processes your Personal Data as follows:

  • Collection of your Personal Data: Fundsquare will collect your Personal Data when you complete the subscription/ request form for receiving communications and/ or invitations from Fundsquare (according to your preferences).
  • Personal Data collected by Fundsquare: Fundsquare will solely collect the data you provide when completing the subscription/ request form that is to say your name, first name, job title, email address, the name of your company and in some cases your phone number(s). You do not have any obligation to provide whole of the above information and may decide, at your own discretion, to disclose only part of the requested information.
  • Legal ground(s) for the processing of your Personal Data: legitimate interest (as defined by GDPR): management and security of the website.
  • Processing of your Personal Data: Fundsquare will process your Personal Data for the sole purpose of sending you communications and/ or invitations (according to your preferences).

Any further use of your Personal Data, out of that context, will require another specific consent.

3.3 Sending of requests to Fundsquare by mean of the contact form

  • Collection of your Personal Data: Fundsquare will collect your Personal Data when you complete the contact form.
  • Personal Data collected by Fundsquare: Fundsquare will collect the data you provide when completing the contact form that is to say your name, first name, job title, email address, the name of your company, your phone number(s as well as the contact of your request. You do not have any obligation to provide whole of the above information and may decide, at your own discretion, to disclose only part of the requested information.
  • Legal ground(s) for the processing of your Personal Data: legitimate interest (as defined by GDPR): management and security of the website.
  • Processing of your Personal Data: Fundsquare will process your Personal Data for the sole purpose of handling your request and provide you with an appropriate answer. Such answer may be, when appropriate, an offer or solicitation to subscribe to services supplied by Fundsquare.

Any further use of your Personal Data, out of that context, will require another specific consent.

4. Storage of your Personal Data

Fundsquare takes reasonable and appropriate technical and organizational security measures in order to:

  • Store your Personal Data in secure databases or systems with restricted access,
  • Protect your Personal Data against loss, accidental or intentional misuse, alteration, destruction and access by unauthorized persons.

Fundsquare will notify you without undue delay in the event Fundsquare becomes aware of any unauthorized or improper use, access or disclosure of the Personal Data, which is likely to result in a high risk to your rights and freedoms.

Please kindly note that some of the databases or systems used by Fundsquare for mailing services and storage systems may be hosted and/or maintained by third party service providers located inside or outside of the European Union. Your Personal Data will only be disclosed to such service suppliers if Fundsquare has deemed, in its reasonable opinion, that such service providers offer appropriate guarantees with regard to confidentiality, security and protection of your Personal Data.

Fundsquare also reserves the right to disclose Personal Data to any court, judicial or administrative authority when required or legally compelled to do so.

5. Retention Period

Fundsquare will retain your Personal Data in accordance with the legal retention periods applicable in Luxembourg or where required for Fundsquare to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.

Your Personal Data will be deleted when:

  • It is no longer reasonably required for the purpose the Personal Data were initially collected for,
  • You withdraw your consent (where applicable); or
  • Fundsquare is not legally required or otherwise permitted to continue storing your Personal Data.

6. Your right to access, correct and request the deletion of your Personal Data

You have the right to access, modify, correct and/ or request the deletion of your Personal Data at any time as well as to restrict or oppose to the use of your Personal Data for the purposes mentioned above including:

  • For communications and invitation sent by Fundsquare: You may withdraw your consent to receive communications or invitations at any time by sending an email to privacy@fundsquare.lu. In that case, Fundsquare will immediately cease to send you communications and invitations.
  • For the use of the Website: you may have, at any time, the option to either accept or refuse cookies on the Website by changing the settings of you browser. However, if you choose to refuse cookies, you may not be able to access and use certain portions of the Website. You may also encounter difficulties or restrictions when accessing whole or part of the Website for which Fundsquare disclaims any liability or responsibility of any kind.

If any of the Personal Data that you have provided to Fundsquare changes or becomes no longer up-to-date, you should send an email to privacy@fundsquare.net. Fundsquare will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provided.

7. Amendment to the Policy

The Policy may be amended, replaced or supplemented at any time and without prior or further notice by Fundsquare. You are therefore advised to review it from time to time for any possible changes.

8. Contact

Please feel free to send any queries or requests related to the processing of your Personal Data by Fundsquare, in the context described above, to privacy@fundsquare.net.

   
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