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Privacy Policy respects your privacy and is committed to protecting your personal data. This privacy policy explains what personal data we collect from you when you use our services and how we use and protect it. This privacy policy is dated May 2018 and may be updated from time to time.

When referring to “we”, “us” or “our” we are referring to and it’s affiliates.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out at the end of this privacy policy.

Our services include your use of our websites and any other websites we may operate on at a later moment, web and mobile applications, application program interfaces and any other
products or services we operate on or will operate on at a later moment. Links to websites or applications we do not control and which may collect information about you are not subject of this privacy statement.

For the purpose of the present privacy policy, the following terms shall be understood as follows:
Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by
reference to an identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.

Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording,
organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure
by transmission, dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction.



We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar
    identifier and in some cases, marital status, title, date of birth and gender;

  • Contact Data includes billing address, delivery address, email address and telephone

  • Financial Data includes bank account and payment card details;

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;

  • Technical Data includes internet protocol (IP) address, your login data, browser type and
    version, time zone setting and location, browser plug-in types and versions, operating
    system and platform and other technology on the devices you use to access this website

  • Profile Data includes your username and password, purchases or orders made by you,
    your interests, preferences, feedback and survey responses;

  • Marketing and Communications Data includes your communication preferences in
    receiving marketing information from us and our third parties.

We do not collect any special categories of personal data about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health and genetic and biometric data).


We primarily obtain data by direct interaction with you by filling in forms or by corresponding
with you via email, post, phone or otherwise. On an ancillary basis, we may also obtain personal
data from third parties in relation to you.

Where appropriate and permitted by law, we may seek more information about you from other
sources generally in relation to due diligence and client on-boarding process.

If any information you provide to us relates to someone else, by providing us with such
information you confirm that you have obtained the necessary permissions from the relevant

If you do not provide certain information when requested, we may not be able to manage our
relationship with you effectively, enter a contract with you or fulfil our legal obligations.


Depending on the purpose of the processing activity, the legal basis for processing your personal
data will be either:

  • necessary for compliance with our legal obligations; or

  • necessary to ensure the performance of a contract between you and us (or in order to
    take steps at your request prior to entering into a contract);

  • otherwise we shall obtain your prior explicit consent for processing. This legal basis will apply in limited circumstances and we will obtain your consent prior to processing.


We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into
    with you;

  • where it is necessary for our legitimate interests (or those of a third party) and your
    interests and fundamental rights do not outweigh those interests;

  • where we need to comply with a legal or regulatory obligation;

  • performing any pre-employment checks (so far as permitted by law);

  • for the purposes of recruitment;

  • engaging in marketing and business development activity in relation to our existing and
    future investment opportunities. This may include sending you newsletters,
    presentations, performance reports and other marketing material.


We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with
the original purpose.

Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.

You can ask us to stop sending you marketing messages at any time by unsubscribing from the
email you have received from us. Opting out of receiving marketing messages will not apply to
personal data provided to us in the process of a product/service purchase, warranty registration,
product/service experience or other transactions.


Your personal data may be transferred to and stored by persons outside the European Economic
Area (the “EEA”).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection
is afforded to it by ensuring at least one of the following safeguards is implemented:



We have put in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and other third parties
on a need to know basis. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.



We will only retain your personal data for as long as necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We may consider the following when determining the appropriate data retention period:

  • The period required to fulfil our purpose for processing; and

  • Any legal obligations we have in relation to your personal data such as law or regulation requiring us to hold the data for a set period.


If you are a resident of the EEA, we would like to inform you that you are entitled to the
following rights in relation to your personal data:


  • Request access to your personal data (commonly known as a “data subject access
    request”). This enables you to receive a copy of the personal data we hold about you and
    to check that we are lawfully processing it.


  • Request correction of your personal data that we hold about you. This enables you to have
    any incomplete or inaccurate data we hold about you corrected, though we may need to
    verify the accuracy of the new data you provide to us.


  • Request erasure of your personal data. This enables you to ask us to delete or remove
    personal data where there is no good reason for us continuing to process it. You also have
    the right to ask us to delete or remove your personal data where you have successfully
    exercised your right to object to processing (see below), where we may have processed
    your information unlawfully or where we are required to erase your personal data to
    comply with local law. Note, however, that we may not always be able to comply with
    your request of erasure for specific legal reasons which will be notified to you, ifapplicable, at the time of your request.


  • Object to processing of your personal data where we are relying on a legitimate interest (or
    those of a third party) and there is something about your particular situation which makes
    you want to object to processing on this ground as you feel it impacts on your fundamental
    rights and freedoms. You also have the right to object where we are processing your
    personal data for direct marketing purposes. In some cases, we may demonstrate that we
    have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us
    to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not
    want us to erase it; (c) where you need us to hold the data even if we no longer require it as
    you need it to establish, exercise or defend legal claims; or (d) you have objected to our
    use of your data but we need to verify whether we have overriding legitimate grounds to
    use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to
    you, or a third party you have chosen, your personal data in a structured, commonly used,
    machine-readable format. Note that this right only applies to automated information which
    you initially provided consent for us to use or where we used the information to perform a
    contract with you.

  • Right to withdraw consent at any time where we are relying on consent to process your
    personal data. However, this will not affect the lawfulness of any processing carried out
    before you withdraw your consent. If you withdraw your consent, we may not be able to
    provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


You have the right to make a complaint at any time to the Commission Nationale pour la
Protection des Données (CNPD), the Luxembourg supervisory authority for data protection issues
( We would, however, appreciate the chance to deal with your concerns
before you approach the CNPD so please contact us in the first instance.

Our full details are:

Full name of the legal entity:

Name of the data privacy manager:

Rob Boerman

Email address:

Postal address: 

17, boulevard Prince Henri
L-1724 Luxembourg
Grand-Duchy of Luxembourg

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