Privacy Policy

Venture Corporate Group attaches importance to the protection of personal data. This policy describes how Venture Corporate Group, as a 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 natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “General Data Protection Regulation” or “GDPR” and any other national or supranational statutory law applicable to us), collects and processes personal data of natural persons who are or enter into a relationship with it.

DATA CONTROLLER

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

Definition: Personal data is information that relates to an identified or identifiable natural person. A natural person is considered identifiable when they can be identified directly or indirectly, particularly by assigning them to a characteristic. This includes, for example: name, email address or phone number. Similarly, information about personal preferences (such as hobbies or affiliations), as well as preferences regarding other websites, are part of this data. Anonymized or aggregated data that can no longer be used to identify a specific person is not considered personal data. Processing means any operation relating to your data, regardless of the means and procedures used, including collection, storage, exploitation, modification, communication, archiving or destruction.

PERSONAL DATA PROCESSED AND PURPOSES

1. Investment fund activities

As part 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 likely to be processed are identification data such as name, first name, address and telephone number, data relating to profession and employment, all data necessary and useful for Venture Corporate Group’s activity such as financial data, personal details and household composition.

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

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

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 can only process your personal data within the strict limits of their specific contractual or legal role.

In some cases, Venture Corporate Group may be legally required to communicate personal data to authorities such as the Financial Sector Supervisory Commission.

2. Recruitment

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

• Personal identification data;
• Personal characteristics;
• Data relating to studies;
• Training;
• Qualifications and professional experiences;
• Data relating to hobbies and interests;
• Any other personal data communicated by the candidate.

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.

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

Data relating to unsuccessful candidates is kept for a period of two (2) years, unless the candidate objects.

RIGHTS OF DATA SUBJECTS

To exercise their rights, the data subject can contact the following email address: contact@venture-re.eu, attaching a copy of both sides of their identity document (valid identity card or passport).

Any request to exercise rights will only be taken into account if it is accompanied by a copy of an identity document.

1. Right to information, rectification, erasure and restriction of processing

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

Each person has the right to obtain, at any time, within three months of receiving the request (right of access), without restriction and free of charge:

• Confirmation as to whether or not personal data concerning them is being processed;
• Information on the purposes of the processing operation, the categories of personal data concerned, and the recipients or categories of recipients to whom the data is disclosed;
• Communication in an intelligible form of the data being processed, and any available information concerning their source.

Each person can obtain, without undue delay, the rectification of any personal data concerning them that is inaccurate or incomplete (right of rectification).

Each person can request the limitation of processing (right to restrict processing) of their personal data:

• in case of contestation of the accuracy of said data;
• in case of illegal processing;
• in case of opposition to the processing of personal data.

In such a case, the personal data will be, with the exception of storage, only processed with the consent of the person or for the establishment (right to object), exercise or defense of legal rights, for the protection of the rights of other natural or legal persons or for reasons of important public interest of the European Union or of another Member State of the European Union. In the case where processing is limited, the person is informed before the limitation of processing is lifted.

Each person can request the erasure (right to be forgotten) as soon as possible of personal data concerning them when the use or other processing of this personal data is no longer necessary for the purposes described above, particularly when the consent relating to a specific processing has been withdrawn or when the processing is not or no longer legitimate for other reasons.

2. Right to object to processing

Each person can object to the processing of their personal data. In such a case, the personal data will no longer be processed unless our compelling legitimate interests prevail over your interests, rights and freedoms, or for the establishment, exercise or defense of a legal right.

3. Right to withdraw consent

Each person can withdraw their consent at any time without affecting the legality of the processing based on the consent before its withdrawal. The withdrawal of consent only affects future processing.

4. Right to data portability

When the 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 transmit it to another data controller.

5. Right to lodge a complaint

Each person can lodge a complaint about how Venture Corporate Group processes their personal data by using the following address: contact@venture-re.eu

This does not affect the right of each person to lodge a complaint with the Luxembourg data protection authority (the National Commission for Data Protection) or another European data protection authority.

RETENTION

Personal data may be retained for as long as necessary for the purposes for which it was collected and processed, or for the period imposed by law and regulatory provisions and without prejudice to a longer retention period in case of appeal, for the time necessary to exhaust all avenues of appeal.

POLICY MODIFICATION

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