Privacy Policy

Venture Corporate Group values the protection of personal data. This policy describes how Venture Corporate Group, in its capacity as data controller within the meaning of EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals regarding the processing of personal data and on the free movement of such data (hereinafter the “General Data Protection Regulation” or the “GDPR“), collects and processes the personal data of natural persons who are or come into contact with it.

DATA CONTROLER

All personal data that is provided or collected will be treated in accordance with this Privacy Policy by Venture Corporate Group as data controller or by one of its subsidiaries or service providers as a subcontractor within the meaning of the GDPR.

PERSONAL DATA PROCESSED AND PURPOSES

  1. Activities of an investment fund

In the context of this activity, Venture Corporate Group may collect and process personal data when:

  • A person is interested in one of our products;
  • A person is interested in or uses one of our services;
  • A person is involved in the management of our products and/or services.

The categories of data that may be processed are identification data such as name, surname, address and telephone number, data relating to profession and employment, all data necessary and useful to the activity of Venture Corporate Group such as financial data, personal details, and household composition.

Venture Corporate Group processes these personal data for the following purposes:

  • To execute a contract to which you are a party and/or to carry out pre-contractual measures taken at your request;
  • To comply with legal or regulatory obligations;
  • For our legitimate interests or the legitimate interests of third parties;
  • For the protection of our interests and the possible exercise of our legal rights.

This personal data may be transferred and processed by the companies involved as subsidiaries, central administration, management company and custodian bank of the investment fund for the same purposes as those stated above.  These recipients are all located within the European Economic Area and are mentioned in the investment fund’s prospectus. These companies may only process your personal data within the strict limits of their specific contractual or legal role.

In certain cases, Venture Corporate Group may be legally required to disclose personal data to authorities such as the Commission de Surveillance du Secteur Financier.

  1. Recruitment

When you apply for one of our job openings or on a voluntary basis, Venture Corporate Group collects and processes the following personal data from applicants:

  • Personal identification data;
  • Personal characteristics;
  • Study data;
  • Training;
  • Professional qualifications and experience;
  • Data related to hobbies and interests.

This data may be transferred to our social secretariat, which is located within the European Economic Area, for the same purpose as described below.

Venture Corporate Group processes this personal data for the following purpose: selection and recruitment of candidates.

Such processing is necessary for the performance of a contract to which the data subject is a party or for the execution of pre-contractual measures taken at his request.

Data relating to unsuccessful candidates are kept for a period of two (2) years unless they agree to a longer retention period.

RIGHTS OF THE PEOPLE CONCERNED

To exercise his/her rights, the person concerned may contact the following email address: contact@vcpl.lu and attach a copy of both sides of his/her identity card.

  1. Right to information rectification, removal, and limitation of processing

Each person can obtain, free of charge and as soon as possible, the communication of their personal data that are processed as well as any information on the origin of these personal data.

Each person can also rectify any personal data concerning him or her that is inaccurate.

Each person can request the limitation of the processing of their personal data:

  • in the event of a dispute as to the accuracy of the said data;
  • in case of illegal processing;
  • in case of opposition to the processing of personal data.

In such a case, personal data will, with the exception of storage, only be processed with the consent of the person or for the establishment, exercise or defense of legal rights, for the protection of the rights of other natural or legal persons or for reasons of substantial public interest of the European Union or another Member State of the European Union. In the event that a processing is restricted, the person is informed before the restriction on processing is lifted.

Any person may request the removal of his or her personal data as soon as possible when the use or further processing of such personal data is no longer necessary for the purposes described above, especially when the consent for a specific processing operation has been withdrawn or when the processing is not or no longer legitimate for other reasons.

  1. Right to object to the processing

Anyone may object to the processing of his or her personal data. In such a case, personal data will no longer be processed unless our overriding legitimate interests take precedence over your interests, rights and freedoms, or for the establishment, exercise or defense of a right in court.

  1. Right to withdraw consent

Each person may withdraw consent at any time without affecting the legality of the treatment based on consent prior to withdrawal. Withdrawal of consent only affects future processing.

  1. Right to data portability

When data processing is based on consent or legitimate purposes and is carried out by automated means, each person has the right to data portability for the information they have provided. In such a case, you can obtain a copy of your personal data in a commonly used electronic format so that you can manage it and pass it on to another data controller.

  1. Right to lodge a complaint

Any person may lodge a complaint about the way in which Venture Corporate Group handles his or her personal data by using the following address: contact@venturecg.eu

This is without prejudice to the right of every person to lodge a complaint with the Luxembourg data protection authority (the Commission Nationale pour la Protection des Données) or another European data protection authority.

CONSERVATION

Personal data may be retained for the duration of the relationship, without prejudice to the laws and decrees relating to archiving and without prejudice to a longer retention period in the event of an appeal, for the time necessary to exhaust all avenues of appeal.

POLICY CHANGE

Venture Corporate Group reserves the right to amend this Privacy Policy to ensure that each individual is fully informed of all processing activities and compliance with applicable data protection legislation.