Privacy Notice

This privacy policy (the Privacy Notice) sets out the rules and procedures as to the processing of personal data (i.e. data by which you may be directly or indirectly identified, hereafter the Personal Data) in accordance with the Data Protection Legislation when accessing and browsing the website (the Website).

Data Protection Legislation means the General Data Protection Regulation (EU) 2017/69 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.

1. Who is the data controller and who to contact?

Any Personal Data provided to or collected by us will be processed (i.e. used, stored, transmitted, etc.) in accordance with this Privacy Notice by us, Active Ownership Capital S.à r.l. registered at 17, rue de Flaxweiler L - 6776 Grevenmacher (hereafter “AOC” “we” or “us”), in our capacity as controller or by our subcontractors and service providers as further described in this Privacy Notice in their capacity as processors.

If you have any questions or comments or want to exercise your rights, you may contact or write to us at the address above.

AOC has appointed a data protection officer who may be contacted at

2. What personal data IS PROCESSED?

AOC 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 AOC processes about you include:

· personal data that you provide by filling in forms on our Website or using our 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, telephone number; and information related to your personal situation (employment and occupation)),

· if you contact us by email or by phone, any records of these exchanges;

· data technically transmitted when you access or browse our Website, such as your IP address or data obtained through the use of cookies. Please refer to Clause 4 “Cookies” and to the cookie policy for further information on if AOC uses cookies.

3. For which purposes does AOC process personal data and on which legal basis?

3.1 Based on AOC’s or a third party’s legitimate interest

We process your Personal Data in our interests or to pursue third party’s legitimate interests. These interests cover processing to:

· helping us to administer, evaluate and improve our business, our products and the services we offer;

· identify you and to enable us to properly answer your query;

· keep a record of your relationship with us;

· send updates and announcements about AOC products and services;

· assure the safety and continuity of AOC’s IT services and systems;

· prevent and detect fraud;

· establish, exercise and defend legal claims; and

· in connection with any business reorganisation, transfer, disposal, merger or acquisition on the level of AOC or any of its affiliated companies (AOC Group).

3.2 With your consent

Insofar as you have given AOC 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.

4. Cookies

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

We currently do not use any cookies, including essential and/or non-essential cookies (such as advertisement cookies) on the Website.

In case AOC starts to use cookies, you will have the choice of deciding whether to accept cookies or not by setting your browser to block all cookies except strictly technical cookies that are necessary to the functioning of the Website.

5. 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 and archiving storage providers, financial, tax or legal advisors, that process your Personal Data on AOC’s instructions;

· government, courts, law enforcement authorities, regulators or attorneys and supervisory authorities;

· parties involved in the context of a company restructuring, transfer, divestiture, merger or acquisition impacting AOC;

· shareholders, agents, employees, consultants, representatives, auditors and business partners; and

· other companies belonging to AOC Group (and if necessary, their respective shareholders, agents, employees, consultants, representatives, auditors, service providers and business providers).

6. Where is your personal data transferred to?

Your Personal Data will not be transferred outside of the European Economic Area.

7. How long does AOC retain your personal data?

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

Active Ownership may notably retain the Personal Data you have submitted to AOC 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

AOC may also retain your Personal Data for up to two (2) years for statistics, business analysis and marketing purposes.

8. Do you have the obligation to provide Personal Data?

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

9. To what extent DOES AOC use automated decisions making or profiling?

In general, AOC does not use automated individual decision-making or profiling in the course of the relationship with you. Should AOC rely on such processing, AOC would inform you separately.

10. What are the rights of the users?

The exercise of the below rights is free of charge and not bound to any formalities. You may exercise these rights by contacting us through the contact information included in clause 1 above.

To protect your privacy and security, AOC may takes steps to verify your identify before complying with any of your requests.

10.1 Right to information, rectification, erasure and restriction of processing

You may request to obtain, within reasonable intervals, and in a timely manner, the communication of your Personal Data that is being processed by AOC, as well as all information on the origin of those Personal Data.

You also have the right to rectify 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 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 in clause 3 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.

10.2 Right to object

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

10.3 Right to withdraw consent

You have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal. The withdrawal only affects future processing.

10.4 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 AOC – this means that you can obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and potentially transmit it to another controller.

10.5 Right to lodge a complaint

In the event that you wish to complain about how AOC 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 AOC in the first instance using the contact details provided in clause 1 and AOC 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.

11. Links to third party websites

The Website might contain link to third party websites (e.g. Facebook, Linkedin, Twitter, etc.).

This Privacy Notice solely concerns the Website, and AOC’s processing of personal data.

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

12. Amendments of this privacy Notice

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

Updated on December 2022