Privacy Policy

Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we explain how we collect, use, and protect your personal data.

We also explain what rights you have regarding your personal data and how you can exercise those rights.

Who we are

www.fundstructuring.com is a site operated by Fundstructuring.com S.A., registered in Luxembourg under RCS Luxembourg B286.071, with its registered office at 12C, rue Guillaume J. Kroll, L-1882 Luxembourg.

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at info@fundstructuring.com.

Collection of personal data

We collect personal data from you or about you for one or more of the following purposes:

• To enable you to submit a profile on fundstructuring.com that other users can view;
• To sell our products and services to you if you are a prospective user of fundstructuring.com;
• To market our products and services to you if you are an existing user of fundstructuring.com;
• To identify and recommend vacancies that may be of interest to you;
• To provide you with services such as training or development;
• To manage any non-marketing communications between you and us;
• To ensure the security and safe operation of our websites and underlying business infrastructure.

Technical information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

• Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet.
• Your login information, browser type and version, time zone setting, browser plugin types and versions.
• Operating system and platform.
• Information about your visit, including the URL to, through and from our site.

From time to time, we may use technologies, such as tracking pixels (also called 1x1 pixels or pixel tags), to collect the above information from your interaction with emails we send you. This enables us to focus our marketing to your needs, leading to more relevant emails to our subscribers. It also helps us to identify subscribers that are not engaged with our marketing emails, enabling us to remove them from our send lists.

Our Cookies Policy describes how we use cookies on our website. In this document below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

Lawful basis for the processing of personal data

The organisation of our business architecture, accounting and systems infrastructure and compliance means that all personal data is processed on common, group-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. Some data are collected for multiple purposes, as shown, and some data are shared with third parties, again as shown.

When we process on the lawful basis of legitimate interest, we apply the following tests to determine whether it is appropriate:

• The purpose test – is there a legitimate interest behind the processing?
• The necessity test – is the processing necessary for that purpose?
• The balancing test – is the legitimate interest overridden, or not, by the individual’s interests, rights, or freedoms?

Storage of personal data

We are an organisation registered in Luxembourg, with our primary business infrastructure hosted in Europe.

• Our website and web application may be hosted in the EU and accessed only by our designated staff and development teams.
• Our customer relationship management, marketing, and accounting systems are hosted within the EU.
• We use CSPs (Cloud Service Providers) as part of our processing environment. Unless specifically stated otherwise, we are, in respect of all these CSPs, the data controller. Our CSPs may include providers such as Amazon, Hubspot, Stripe, etc.
• Unless specifically stated otherwise, all the CSPs that we use utilise EU-based processing facilities.
• Our payment processors and banking arrangements are based in the EU.
• We operate a data retention policy in respect of all data, whether paper-based or digital, and those aspects of it that relate to personal data are contained in this document above.

Your rights as a data subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email info@fundstructuring.com or use the information supplied in the ‘Contact us’ section below. To process your request, we will ask you to provide two valid forms of identification for verification purposes.

Your rights are as follows:

The right to be informed
As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice and any related communications we may send you.

The right of access
You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:

• The purposes of the processing.
• The categories of personal data concerned.
• The recipients to whom the personal data has been disclosed.
• The retention period or envisioned retention period for that personal data.
• When personal data has been collected from a third party, the source of the personal data.

If there are exceptional circumstances that mean we can refuse to provide the information, we will explain them. If requests are frivolous or vexatious, we reserve the right to refuse them. If answering requests is likely to require additional time or occasion unreasonable expense (which you may have to meet), we will inform you.

The right to rectification
When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.

The right to erasure (the ‘right to be forgotten’)
Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.

The right to restrict processing
You may ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies, you may exercise the right to restrict processing:

• The accuracy of the personal data is contested.
• Processing of the personal data is unlawful.
• We no longer need the personal data for processing, but the personal data is required for part of a legal process.
• The right to object has been exercised and processing is restricted pending a decision on the status of the processing.

The right to data portability
You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was based on consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.

The right to object
You have the right to object to our processing of your data where:

• Processing is based on legitimate interest;
• Processing is for the purpose of direct marketing;
• Processing is for the purposes of scientific or historic research; or
• Processing involves automated decision-making and profiling.

Contact us

Any comments, questions or suggestions about this privacy notice or our handling of your personal data should be emailed to info@fundstructuring.com.

Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner. Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority. In the EU, this would be the CNPD Luxembourg, or the relevant authority in your country.

Disclaimer

You have reached a webpage of the fundstructuring.com domain for Fundstructuring.com S.A., 12C, rue Guillaume J. Kroll, L-1882 Luxembourg, registered with the Luxembourg Chamber of Commerce under number RCS Luxembourg B286.071. Certain regulatory requirements of your local authorities or countries may prevent certain visitors from (1) being solicited, (2) offered certain services or financial products and (3) engaging in business with certain entities of the Fundstructuring Group.

You are strongly recommended to consult our Website Terms & Conditions. Access to the information contained on this website may be restricted by laws and regulations applicable to the user. Persons in respect of whom such prohibitions apply must not access the fundstructuring.com website.

Fundstructuring.com does not give tax or legal advice; prospective investors should seek advice from their own tax advisers and/or lawyers before entering into any investment.

Investment performance

The value of investments and the income from them may go down as well as up and investors may not get back the amount invested. Past performance is not necessarily a guide to future performance. Fundstructuring.com is not intending to provide investment or other advice to you or any other party, and no information or material at the site is to be relied upon for the purpose of making or communicating investments or other decisions.

Linked websites

On this website you may be offered automatic links to other sites. Following links to any other off-site pages or other websites shall be at your own risk. Fundstructuring.com has not reviewed any of the websites linked to the Fundstructuring.com website and does not endorse or accept any responsibility for their content nor the products, services or other items offered through them.

Privacy Policy

The Fundstructuring.com website collects technical data about visitors, such as their provenance, the number of pages visited, the type of device and browser being used, as well as the time of day and length of stay on the site. For more information, please read our Cookie Policy.

No offer

The information on this website is a marketing communication. Neither the information nor any opinion expressed in this website constitutes a solicitation, an offer or a recommendation to buy, sell or dispose of any investment, to engage in any other transaction or to provide any investment advice or service. None of the services, investments or mutual funds referred to in this site are available to persons resident in any country, state or jurisdiction where it would be contradictory to local laws and/or regulations to publicly offer such products. Prospectuses in respect of such products/services will not be distributed in any country, state or jurisdiction in which it would not be lawful to do so.

Local legal restrictions

The Fundstructuring.com website is not directed at any person in any jurisdiction where (by reason of that person's nationality, residence or otherwise) the publication or availability of the Fundstructuring.com website is prohibited.

Sales restrictions

The units of the Fundstructuring.com funds, as more fully described in the menu "Investment Funds", will only be distributed publicly in the countries in which the funds are authorised for public sales. An investment in any of the Fundstructuring.com funds should only be made after reading the related legal documents such as management regulations, prospectuses, annual and semi-annual reports, which can all be obtained free of charge from the funds' representatives in each country where the funds are incorporated or registered.

No reliance and no warranty

Although Fundstructuring.com and its information providers seek to ensure that the information on this website is accurate and complete at the time of publication and has been obtained from sources believed to be reliable, no warranty expressed or implied is made to its accuracy, reliability, actuality and completeness by Fundstructuring.com and its information providers. Opinions and any other contents on the site are subject to change without notice.

Limitation of liability

Fundstructuring.com and its information providers expressly disclaim all liability to any person in respect of anything and in respect of the consequences of anything done or omitted to be done wholly or partly in reliance upon the whole or any part of the contents on the Fundstructuring.com site. Moreover, Fundstructuring.com and its information providers shall have no liability for any losses or damage arising from the use of or reliance on the information contained on the site, including, without limitation, any loss of profit or any other direct or indirect damage.

Copyright and reproduction notice

The entire content of this Fundstructuring.com website is subject to copyright with all rights reserved. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the website without Fundstructuring.com’s prior written permission.

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