AMUF Website privacy notice

This privacy notice (the “Privacy Notice”) informs you about the processing of your persona data (i.e. data by which you may be directly or indirectly identified, hereafter the “Personal Data”) by AMUF (as defined hereunder) when accessing and browsing the website www.eif-umbrella.org (the “Website”), as well as your rights in accordance with the Data Protection Legislation.

Data Protection Legislation means Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”), as well as any other applicable laws, regulations and sector recommendations containing rules for the protection of individuals with regard to the processing of Personal Data, as such legislation and guidance may be complemented, amended, replaced or repealed from time to time.

Who is the data controller and who to contact?

Any Personal Data provided to or collected by Asset Management Umbrella Fund SCA, an investment company with variable capital incorporated under the form of a corporate partnership limited by shares, having its registered office at 5 rue Guillaume J. Kroll, L-1882 Luxembourg, Grand Duchy of Luxembourg, and registered with the Trade and Companies Register of Luxembourg under number B218830 (hereafter “AMUF”) will be processed (i.e. used, stored, transmitted, etc.) in accordance with this Privacy Notice.

Should you have any requests concerning your Personal Data, you can contact AMUF at the address indicated in clause 1 “Contact”.

What personal data is processed?

AMUF receives and collects the Personal Data directly from you or through the use of automated technology when you use and interact with the Website.

In particular, the Personal Data AMUF processes about you may include:

  • personal data that you provide by filling in forms on the Website or using the contact details (this may include your country of residence, your quality of professional or non-professional investor, identification data such as your name, email address; and information related to your personal situation (employment and occupation)),
  • if you contact AMUF by email, any records of these exchanges;
  • data technically transmitted when you access or browse the Website, and data notably obtained through the use of cookies (including date and time of access, operating system used, number of visits, pages of the Website you have visited, etc.). Please also refer to clause 4 “Cookies” and to the cookie policy for further information on Personal Data gathered through the use of cookies.

For which purposes doES AMUF process your Personal Data and on which legal basis?

  • For purposes that are in AMUF’s or a third party’s legitimate interest, such as:
  • helping AMUF to administer, evaluate and improve its business, products and the services AMUF offers;
  • helping AMUF to improve the performance and usability of the Website;
  • personalising your experience on the Website so as to assure you the best possible user experience;
  • sending you updates and announcements about AMUF’s products and services, the establishment of statistics and the conduct of Website trends, performance and commercial analysis;
  • assuring the safety and continuity of AMUF’s IT services and systems;
  • fraud detection
  • the establishment, exercise and defence of legal claims; and
  • in connection with any business reorganisation, transfer, disposal, merger or acquisition on the level of AMUF.
  • With your consent

Insofar as you have given AMUF your consent for the processing of your Personal Data, such consent will serve as a legal basis for the referred processing.

This includes the consent you may have given in relation to the use of cookies or the possibility to be contacted in relation to offers and promotions (e.g. about products and services of members of AMUF or those of its commercial partners).

You can withdraw your consent at any moment by contacting AMUF at the address indicated in clause 1 “Contact”.

Cookies

A “cookie” is a small piece of text that a website places in the cookie file of your browser and that allows the website to remember who you are.

Like many other websites, AMUF uses cookies to provide you with a safe, effective and user-friendly Website. AMUF also uses cookies to compile certain information to determine visitor’s preferences and trends in web browsing activity.

You have the choice of deciding whether to accept cookies or not by setting your browser to block some or all cookies. However, please be aware that if you do not accept cookies, you may not be able to enjoy a comprehensive experience of the Website features. Strictly technical cookies, necessary to the functioning of the Website cannot be refused.

For more information on the use of cookies, please refer to AMUF’s cookie policy.

Who receives your personal Data?

  • The following recipients may receive your Personal Data:
  • Service providers, including but not limited to IT or website services suppliers, financial, tax or legal advisors, that process your Personal Data on AMUF’s instructions;
  • The operator of the general homepage by which the Website is accessible;
  • Government, judicial and supervisory authorities;
  • Parties involved in the context of a company restructuring, transfer, divestiture, merger or acquisition impacting AMUF; and
  • Other companies or entities within the AMUF Group.

Where is your personal Data transferred to?

For the purposes listed above, your Personal Data may be transferred to any of the aforementioned recipients and service providers in countries located in or outside of the European Economic Area (the EEA).


Your Personal Data may be transferred to a country outside of the EEA on the basis of the fact that the European Commission has decided that such country ensures an adequate level of protection. Certain countries in which recipients and data processors may be located and to which your Personal Data may be transferred may however not have the same level of protection of your Personal Data as the one afforded in the EEA. Personal Data transferred to countries outside of the EEA in such case will be protected by appropriate safeguards such as standard contractual clauses approved by the European Commission. You may obtain a copy of such safeguards by contacting AMUF by using the contact details provided in clause 11.

How long does AMUF retain your Personal Data?

The retention periods for your Personal Data are based on AMUF’s business needs and legal requirements.

AMUF may notably retain:

  • Personal Data you have submitted to AMUF through a specific request until we have responded to your request or until the end of the exchange relating thereto, plus ten (10) years as of the end of such communication; and
  • cookies up to six (6) months after your last use of the Website.

AMUF may also retain your Personal Data other than related to cookies for up to two (2) years for statistics, business analysis and marketing purposes.

Do you have the obligation to provide the Personal Data?

In the context of AMUF’s business and the functioning of the Website, you only have to provide the Personal Data that is necessary for AMUF to reply to your requests or necessary for the Website to run properly.

However, please be aware that without certain types of Personal Data (notably Personal Data relating to cookies technically required to be able to browse the Website), AMUF will not be able to duly reply to your requests or some parts of the Website may become inaccessible.

What are your rights?

Right to information, rectification, erasure and restriction of processing

You may request to obtain at no costs, within reasonable intervals, and in a timely manner, the communication of your Personal Data being processed, as well as all information on the origin of those Personal Data.

You also have the right to rectify your Personal Data that is inaccurate.

In cases where the accuracy of the Personal Data is contested, the processing is unlawful, or where you have objected to the processing of your Personal Data, you may ask for the restriction of the processing of such Personal Data. This means that Personal Data will, with the exception of storage, only be processed with or for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of an EU Member State. In case a processing is restricted, you will be informed before the restriction of processing is lifted.

You may request the deletion of Personal Data, without undue delay when the use or other processing of such Personal Data is no longer necessary for the purposes described above, and notably when consent relating to a specific processing has been withdrawn or where the processing is not or no longer lawful for other reasons.

Right to object

You may object to processing of your Personal Data which is based on the legitimate interests pursued by AMUF or by a third party. In such a case AMUF will no longer process your Personal Data unless AMUF has compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Your right to object is not bound to any formalities.

Right to withdraw consent

You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. The withdrawal only affects future processing.

Right to data portability

Where the processing of your Personal Data is based on consent or the execution of a contract with you, you also have the right to data portability for information you provided to AMUF – this means that you can obtain a copy of your Personal Data in a commonly use electronic format so that you can manage and transmit it to another controller.

Right to lodge a complaint

In the event that you wish to make a complaint about how AMUF processes your Personal Data, and/or if you want more details on the processing of your Personal Data and/or if you have any specific queries or concerns regarding the processing of your Personal Data, please contact AMUF in the first instance using the contact details provided in clause 11 and AMUF will endeavour to deal with your request as soon as possible.

This is without prejudice to your right to file a complaint with the Luxembourg data protection authority, the Commission nationale pour la protection des données, or any other competent data protection authority (e.g. that of your country of residence), in the event you have concerns on the processing of your Personal Data.

Links to third party websites

The Website might contain link to third party websites.

This Privacy Policy solely concerns the Website, and AMUF’s processing of personal data.

Please check the privacy policy or these third parties’ websites to learn about how they process your Personal Data under their own responsibility.

Contact

If you have any questions regarding this Privacy Notice or Personal Data AMUF holds about you, you may contact AMUF at its registered office (see clause 1 above) or at privacy@eif-umbrella.org.

To protect your privacy and security, AMUF may takes steps to verify your identify before complying with the requests.

Amendments of this privacy notice

AMUF may amend this Privacy Notice from time to time to ensure that you are fully informed about all processing activities and AMUF’s compliance with applicable Data Protection Legislation. You will be notified of changes to the Privacy Notice by appropriate means.

Last update: 01.08.2019