Engelwood Asset Management SA

Disclaimer

Procedures GDPR Claim treatment

GDPR

PRIVACY POLICY

INTRODUCTION
To cope with technological change, it is necessary to pay attention to privacy. Engelwood entities (Engelwood Asset Management, Engelwood Fund & Corporate Services and Engelwood Management & Consulting) , hereafter "ENGELWOOD", are committed to complying with the new European General Data Protection Regulation (GDPR) which came into force on 25 May 2018.
The personal data collected by ENGELWOOD is fully subject to this new regulation.


INDEX
1. PERSONAL INFORMATION COLLECTION
2. DATA PROCESSING PURPOSES
- INFORMATION THAT YOU PROVIDE VOLONTURILY
- Contact information
- Transaction information
- INFORMATION WE COLLECT AUTOMATICALLY
- Activity information
- Cookies and similar technologies
3. LEGAL BASIS
4. LOG FILES AND COOKIES
5. LINKS TO THIRD-PARTY SITES
6. THIRD PARTIES
7. STORAGE TIME
8. RIGHT TO OBJECTION, WITHDRAWAL AND TRANSFER
9. RIGHT OF ACCESS AND RECTIFICATION
10. RIGHT TO RESTRICTION OF PROCESSING
11. RIGHTS REQUEST EXECUTION
12. SECURITY


1. PERSONAL INFORMATION COLLECTION
In general, your personal data is not automatically stored when you browse the ENGELWOOD website.
Nevertheless, during your visit, a banner appears at the bottom of the screen informing you of the use of cookies when browsing the site. It is up to you to make a choice between accepting or refusing the use of cookies depending on the purpose pursued by each cookie.
Some cookies do not collect any personal data but simply allow a better browsing experience.
To learn more about the types of cookies and similar technologies we use, why and how you can control these technologies, please see our " Cookies "section.


2. DATA PROCESSING PURPOSES
ENGELWOOD may process your Personal Data for the following purposes:

(a)  provide you with the information or services you have requested (for example, responding to a contact request);

(b) collecting information allowing us to improve our site, products and services;

(c) contacting you about various ENGELWOOD events, including product updates and customer support;

(d) registration and contact information: no account can be created on engelwood.lu but when you contact us, we collect information about you, including your name, address, phone number and email address;
(e) transaction information: there are no possible transactions on the website.

(f) Information about your marketing preferences: no data is collected for advertising purposes.

INFORMATION THAT YOU PROVIDE VOLUNTARILY
Contact Information
The information you provide when you contact us allows us to have a clear understanding of your needs and provide the Services you request.
We also use this information to inform you of significant changes or updates to our Services.

Transaction Information
There is no transaction possible.

INFORMATION THAT WE COLLECT AUTOMATICALLY
When you access our services, we can automatically collect certain information from your device, such as your IP address, MAC address or device ID. In some countries, including Europe, this information may be considered personal information under applicable data protection laws.

Activity Information
We only collect IP addresses in the server logs of our subcontractor.

Cookies and similar technologies
There are no cookies.


3. LEGAL BASIS
For purposes explained in point (2):
a) Legitimate interest (responding to a request) or consent (newsletter);
b) Legitimate interest (log-based anonymized navigation data);
c) Consent
d) Contractual obligation
e) No processing
f) No processing


4. LOG FILES AND COOKIES
We collect certain information through log files and cookies. These are mainly the following information:
• IP address
• Operating system
• Pages visited
• Day and time of connection
The use of such files allows us to offer you a more consistent experience on the website.


5. LINKS TO THIRD-PARTY SITES
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates or to a number of websites that may provide useful information to our visitors. We provide you with these links only for convenience and the inclusion of a link does not involve the approval of the website concerned by ENGELWOOD. If you follow a link to one of these websites, please note that they have their own privacy policies and we do not accept any responsibility for these related policies or websites. Please check these policies before submitting personal information to these websites.

6. THIRD PARTIES
Your personal data will be sent to third parties.
The web server, POINTCOMM SARL, is a subcontractor located in Luxembourg. 
Your data can be stored, but encrypted, on their servers. Your IP address can be found in the logs on the server.

7. STORAGE TIME
Your personal data is stored by ENGELWOOD only for time in relation to the purpose of our communication exchanges.

8. RIGHT OF OBJECTION, WITHDRAWAL AND TRANSFER
You have the right to object, delete your personal data and withdraw your consent. You can also request the transfer of your personal data.

The right of objection is the possibility offered to Internet users to refuse to have their personal information used for certain purposes mentioned in the collection. You may express your opposition to the handling of your personal information if we have a legitimate (or third-party) interest in doing so and there is a valid reason to object to the processing of the data. You also have the right to object if we process your personal information for direct marketing purposes.

The right of withdrawal is the ability for users to request the removal of their personal information. You can also request the removal of your personal information when you have expressed your right to object to the processing of your data (see above). When you give your explicit consent to authorize the collection, processing and transfer of your personal information for a particular purpose, you have the right to withdraw your consent for this data processing at any time. Once we have received the notice of withdrawal of your consent, we will no longer process your information for the purposes for which you have given your consent, unless we have a legitimate reason to do so.

You can request the transfer of your personal information on your behalf or on behalf of another processing manager in an electronic and structured format (right to data portability). This allows you to retrieve and transfer your data in a usable electronic format.

9. RIGHT OF ACCESS AND RECTIFICATION
You can request access to your personal information (commonly referred to as "request for access to personal data"). This request allows you to receive a copy of your personal information and verify that we are legally processing that data. You can also request information to find out if we have personal information about you and, if so, what information is available and why we keep/use it. In addition, you can request the correction of the personal information we have about you. This allows you to correct any incomplete or inaccurate information we have about you.

10. RIGHT TO RESTRICTION OF PROCESSING
You can request a limitation of the processing of your personal information. This allows you to suspend processing your personal information, for example if you want to establish the accuracy or reason for processing the data.

11. RIGHTS REQUESTS EXECUTION
To request the execution of your rights, you can contact us at the following email address dpo@luxgap.com.

Your application will be processed within one month of confirming your identity. You will not have to pay a fee to access your personal information (or perform any other of your rights). However, we may charge you a reasonable fee if your access request is manifestly unfounded or inappropriate. We may also refuse to process your application for the same reason.

We may ask for this information to help us confirm your identity and to ensure that we respect your right to access this information (or for the performance of any other of your rights). This is a security measure to ensure that your personal information is not disclosed to an unauthorized person. You are allowed to file a complaint with the National Data Protection Commission ("CNDP") if you feel that your rights are not being respected.

12. SECURITY
The personal information we collect is stored in a secure environment. Our employees are required to respect the confidentiality of your information. To ensure the security of your personal information, we use the following measures:
• SSL Protocol (Secure Sockets Layer)
• Access management — authorized person
• Backups
• Firewall
We are committed to maintaining a high level of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your data. However, as there is no mechanism for maximum security, there is always a risk of using the Internet to transfer personal information.

 

 

 

 

COOKIE POLICY

Our cookie policy allows you to better understand the provisions we implement in terms of browsing our website. It informs you about the cookies on our website, their purpose (1) and gives you the procedure to set them up (2).

1. GENERAL INFORMATION ABOUT COOKIES
ENGELWOOD, as publisher of this site, can implement a cookie on the hard drive of your device (computer, tablet, mobile, etc.) to ensure smooth and optimal navigation on our website. This page describes the information they collect, how we use it and why we sometimes need to store these cookies.

"Cookies" are small, small text files that are downloaded to your computer and allow us to recognize your computer, tablet or mobile to customize the services we offer and enhance your experience.

The information collected through cookies does not identify you in any way. Cookies are used exclusively for our own needs to improve the interactivity and performance of our site and send you content tailored to your interests. None of this information is disclosed to third parties. To better inform yourself about the information cookies identify, you will find below the different types of cookies that can be used on engelwood.lu, their name, purpose and shelf life.

2. YOUR COOKIE SETTINGS PREFERENCES
When you log onto Engelwood.lu's website, some of your browsing information may be stored in cookies.

During your visit, a banner appears at the bottom of the screen informing you of the use of cookies when browsing the site. It is up to you to make a choice between accepting or refusing the cookies depending on the purpose pursued by each cookie.
Some cookies do not collect any personal data but simply allow a better browsing experience.
From time to time, we test new features and make subtle changes to the way the site is structured. When we test new features, some cookies can be used to ensure that you receive a consistent experience on the website while making sure we understand which optimizations our users like the most.


PERSISTENT COOKIES

• Google.com

CONSENT: used to remember that consent was given by the user.

Remarque: cookie à remplacer/supprimer. Durée de conservation trop longue (17 ans). 13 mois max.

NID: used to store information about the user’s navigation preferences.
iP_JAR: used to store information and preferences about maps or other associated Google services on pages where Google maps are embedded.

• Fonts.gstatic.com

CONSENT: used to remember that consent was given by the user.

Remarque: cookie à remplacer/supprimer. Durée de conservation trop longue (17 ans). 13 mois max.


SESSION
No session cookie is used.
No statistics or treatment are carried out.

DEFINITIONS
Session cookies: these are temporary cookie files that are deleted every time you close your browser. When you restart your browser and return to the site that created the cookie, the website will not be able to recognize you. You will need to log in again (if a login is required) or re-select your preferences/themes if the site uses these features. A new session cookie will be generated to store your browsing information and it will be active until you leave the site and close your browser.
Persistent cookies: these files remain in one of the subfolders of your browser until you manually delete them or your browser deletes them according to the duration specified in the persistent cookie file.