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Privacy Notice - EU

Last updated on 03/12/2024

Liontrust Europe S.A. ("Liontrust", “we” or “our”) is committed to maintaining your trust and confidence by handling your personal data with respect and enabling you to self-manage the communications you receive from Liontrust. In addition, it is important that you know what personal data Liontrust holds about you and how it is used.

In this respect, Liontrust, acting as controller, has prepared this privacy notice (the “Privacy Notice”) in compliance with (i) the EU Regulation n°2016/679 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 (the “GDPR”) and (ii) any applicable national data protection laws (including but not limited to the Luxembourg law of 1st August 2018 on the organisation of the National Data Protection Commission and the general data protection framework, as may be amended or replaced) (collectively hereinafter the “Data Protection Laws”).

The Privacy Notice applies to you if you are a visitor of our website (www.liontrust.eu the “Website”).

The below key terms used in the Privacy Notice have the following meaning:

  • controller: a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
  • processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  • personal data: any information relating to an identified or identifiable natural person;
  • data subject: the identified or identifiable natural person to whom personal data relates;
  • recipient: a natural or legal person, public authority, agency or another body, to which the personal data are disclosed.

Table of contents

  1. What are the categories of Data Subjects?
  2. What Personal Data does Liontrust collect?
  3.  From which sources will Personal Data be collected?
  4. For what purposes are Personal Data processed and upon which legal bases?
  5. With whom will Personal Data be shared?
  6. Where will Personal Data be transferred?
  7. How long will Personal Data be retained?
  8. The Data Subjects’ rights
  9. Changes to this Privacy Notice
  10. Legal disclaimer
  11. Intellectual property rights
  12. Contact information

1. What are the categories of Data Subjects?

We collect personal data related to the following identified or identifiable natural person (the “Data Subject(s)”):

Website visitors:

Individuals who browse or interact with the Website.

2. What Personal Data does Liontrust collect?

We collect the following categories of personal data (the “Personal Data”):

Cookies (essential and non-essential)

Technical information collected from the essential cookies that we have in place to help make the Website usable by enabling basic functions like page navigation and access to secure areas of the Website.

Basic profile information, which is determined by your selections when you first arrive on our Website, e.g. your country of location and visitor type.

Information on how you use our Website, e.g. how many times you visit, the duration of your visit, the pages you view, videos you watch, files you download, links you click on.

Information on the device(s) you use to visit our Website, e.g. whether you are using a computer, a tablet or a smartphone, your screen resolution, your operating system, your browser, your IP address, server log file information.

Identification and contact data

Your name, profession, information on the company you work for, email address, telephone number, payment details (inc. account numbers, bank statements), identity verification documents, passport and/or driving license details, source of funds, electronic signatures, information relating to tax residency status, preferred language, IP addresses, job title, place of employment and your professional online presence.

Communication data

Communications via electronic or other means between you and Liontrust, including without limitation marketing communications, the preferences that you have communicated to Liontrust, information relating to events captured through event-related forms, such as dietary restrictions, hotel and flight information, registration/participation status, media interview attendance, previous event experience.

 

The only Personal Data that are automatically processed when you visit the Website are technical information collected from the essential cookies that we have in place to help make the Website usable by enabling basic functions like page navigation and access to secure areas of the Website. The Website cannot function properly without these cookies.

You are not required to disclose any other Personal Data to us as a condition of using the Website and no such Personal Data is automatically collected during your visit on the Website.

For more information on how we use cookies, please go to Cookie Policy.

3. From which sources will Personal Data be collected?

The Personal Data are collected from various sources, namely:

  • directly from you; or
  • from cookies and tracking technologies.

4. For what purposes are Personal Data processed and upon which legal bases?

For a data processing activity to take place lawfully, it needs to be legitimate and thus to be based on one of the grounds set out in article 6 of the GDPR, inter alia:

  • You have given your consent to the processing of your Personal Data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where you are a child.

For the avoidance of doubt, where you give your consent, such consent shall be construed distinctly from any consent given in the context of confidentiality and/or professional secrecy compliance obligations.

Nevertheless, where we have collected the Personal Data based on consent, no further processing is allowed beyond what is covered by the original consent or the provisions of the law. Where our purposes change over time or where we want to use Personal Data for new purposes, we will inform you of such new processing in accordance with the Data Protection Laws.

In the case at hand, the purposes for which the Personal Data are collected and the legal bases upon which we rely on are described below:

(i) The legitimate interests of Liontrust or of relevant third parties

Categories of Personal Data

Purposes

Essential cookies

To ensure comfortable use of the Website (including ensuring trouble-free connection establishment to the Website, to analyse the system security and stability).

Identification and contact data, as well as communication data.

To provide you with marketing communications not related to the marketing cookies, if applicable.

Identification and contact data as well as communication data.

To enable teams managing events to coordinate their e-mail campaigns and event notifications more effectively.

Identification and contact data, as well as communication data.

To allow for event and webinar sign-up.

Identification and contact data, as well as communication data.

To respond to your requests and enquiries when you contact us.

Identification and contact data, as well as communication data.

To conduct checks to identify you and verify your identity in order to comply with our legal and regulatory obligations. For our legitimate interests in to preventing or minimising fraud that could be damaging for you and/or us.

 

(ii) Necessity to execute the contract to which you are subject and take steps at your request prior to entering into the contract

Categories of Personal Data

Purposes

Identification and contact data, as well as communication data.

To take steps at your request prior to entering into a contract with you or where it is necessary for the performance of a contract to which you are subject.

 

(iii) You have given your consent

Categories of Personal Data

Purposes

Non-essential cookies

For historical, tracking, marketing and statistical purposes.

 

5. With whom will Personal Data be shared?

We may disclose Personal Data to other persons or entities (the “Recipients”) which, in the context of the above-mentioned purposes, refer to:

  • Liontrust’s affiliates;
  • IT service provider such as website administrator, website analytics service provider, communication agency;
  • our service providers, suppliers, sub-contractors and partners;
  • our professional advisors such as auditors, accountants and legal advisors;
  • Regulatory and law enforcement authorities where we are required to do so by applicable law or regulation;
  • Any other third party supporting the activities of Liontrust.

The Recipients may, under their own responsibility, disclose the Personal Data to their agents and/or delegates (the “Sub-Recipients”), which shall process the Personal Data for the sole purposes of assisting the Recipients in providing their services to Liontrust and/or assisting the Recipients in fulfilling their own legal obligations.

The Recipients and Sub-Recipients may, as the case may be, process the Personal Data as processors (when processing the Personal Data on behalf and upon instructions of Liontrust and/or the Recipients), or as distinct controllers (when processing the Personal Data for their own purposes, namely fulfilling their own legal obligations).

6. Where will Personal Data be transferred?

The Recipients and Sub-Recipients may be located either inside or outside the European Economic Area (the “EEA”)].

In any case, where the Recipients are located in a country outside the EEA which benefits from an adequacy decision of the European Commission, the Personal Data will be transferred to the Recipients upon such adequacy decision.

Where the Recipients are located outside the EEA in a country which does not ensure an adequate level of protection for Personal Data, we will enter, prior to such transfer, into legally binding transfer agreements with the relevant Recipients in the form of the European Commission approved standard contractual clauses or any other appropriate safeguards pursuant to the GDPR, as well as, if necessary, supplementary measures.

We currently transfer data to the following countries outside of the EEA:

  • the US;
  • India; and
  • Australia.

You can request further details of these safeguards by contacting us by writing to us at the address referred to in the Section 11 (“Contact Information”).

7. How long will Personal Data be retained?

We will retain the Personal Data for the duration of our relationship with you and thereafter for a period of ten (10) years, unless longer or shorter statutory limitation periods apply. Once we no longer require the Personal Data for the purposes for which it was collected, we will securely destroy the Personal Data in accordance with applicable laws and regulations.

In some circumstances the Personal Data may be anonymised so that it can no longer be associated with the Data Subjects, in which case documents having been anonymised can be kept for an unlimited period of time.

The principal retention periods applied by Liontrust are described below:

Type of records

Retention periods

Cookies

6 months to 2 years unless longer or shorter statutory limitation periods apply.

Business correspondence

10 years from the end of the accounting year in which the document was sent or received.


8. The Data Subjects’ rights

In accordance with the conditions and limitations laid down by the Data Protection Laws, the Data Subjects acknowledge their right to:

Access their Personal Data:

To obtain from Liontrust confirmation as to whether or not Personal Data concerning them are being processed, and, where that is the case, access to the Personal Data.

Rectify their Personal Data:

To obtain from Liontrust without undue delay the rectification of inaccurate Personal Data concerning them. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.

Object to the processing of their Personal Data (including for commercial prospection purposes):

To object, on grounds relating to his or her particular situation, at any time to processing of Personal Data concerning them which is based on the performance of a task carried out in the public interest or the legitimate interests pursued by the Controller or by a third party. Liontrust shall no longer process the Personal Data unless Liontrust demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.

Where Personal Data are processed for commercial prospection purposes, the Data Subject shall have the right to object at any time to processing of Personal Data concerning them for such commercial prospection, which includes profiling to the extent that it is related to such direct commercial prospection.

Restrict the use of their Personal Data:

To obtain from Liontrust restriction of processing, in some circumstances.

Where processing has been restricted under the above paragraph, such Personal Data shall, with the exception of storage, only be processed with the Data Subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

Have their Personal Data erased:

To obtain from Liontrust the erasure of Personal Data concerning them without undue delay and Liontrust shall have the obligation to erase Personal Data without undue delay, except in certain limited scenarios set out in the GDPR.

Withdraw their consent:

To withdraw their consent easily and at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Ask for Personal Data portability:

To receive the Personal Data concerning them, which they have provided to Liontrust, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Liontrust to which the Personal Data have been provided, where (i) the processing is based on consent pursuant or on a contract and (ii) the processing is carried out by automated means.

 

The Data Subjects may exercise their above rights by writing to Liontrust at the address referred to in Section 11 (“Contact Information”).

The Data Subjects also acknowledge the existence of their right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”) at the following address: 15, Boulevard du Jazz, L-4370 Belvaux, Grand Duchy of Luxembourg; or with any competent data protection supervisory authority of their EU Member State of residence.

9. Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time.

An up-to-date version will be made available to you on the Website. We therefore encourage you to periodically check this Privacy Policy to understand how Liontrust protects and uses your information. In case of substantial updates to the present Privacy Notice, you will be notified through the Website or other means of communication.

10. Legal disclaimer

The information contained on this website is provided for informational purposes only.

Third-party resources that can be accessed with hypertext links from the Website are not under our control, and we are not responsible for the contents of any of these third-party resources. The third-party hypertext links presented on the Website are provided for your convenience only. The inclusion of any link on the Website does not imply any recommendation, approval or endorsement of that site by us.

Your use of the Website is at your own risk. The materials presented on the Website may be changed, improved, or updated without notice. We are not liable for any errors or omissions in the content of this Website or for damages arising from the use or performance of the Website under any circumstances.

Please be informed that any proceedings arising out of or relating to your use of the Website, its content and services will be subject to the laws of Luxembourg and the courts in Luxembourg shall have exclusive jurisdiction.

11. Intellectual property rights

Any intellectual property rights of the Website belong to us. Reproduction, copying, distribution or inclusion in other works, of part or all of the protected material available on the Website, is prohibited in any form except for printing or downloading the material for the sole purpose of private use in good faith.

12. Contact information

You may exercise your above rights by writing to us at the following address:

By email:

dataprotection@liontrust.com

 

Or:

 

Compliance

Liontrust Europe S.A.

18 Val Sainte Croix

L-1370

Grand Duchy of Luxembourg