The purpose of this data protection policy is to inform you how Sparinvest S.A., located at 28, Boulevard Royal, L-2449 Luxembourg processes your personal data, and what rights you have in relation to our collection, processing and storage of your personal data. Data protection is important for Sparinvest, which is why we have taken a series of measures to ensure this protection, and to be in full compliance with legislation regarding the protection of personal data.
Why we process your personal data
There are several important reasons why Sparinvest processes your data: To deliver more accurate and relevant consulting regarding investments via our services; to carry out transactions; and to administer your relationship with us as a customer in this context. Our processing of your personal data is therefore necessary in order for us to provide you with our services.
Personal data is also used for marketing purposes, including refining our communication with you based on your interests and focus areas, as well as sending you relevant marketing material in the form of newsletters, information about our products, invitations to events -and more.
Data collections and types of personal data
We gather and process the personal data you have submitted to us in relation to our investment consulting, execution of transactions and administration of your relationship with us as a customer. In general, your personal data is collected when you contact us (by telephone, via a website or via email) with a view to you receiving our consulting services, for carrying out transactions on your behalf etc.
For marketing purposes, in special circumstances we also collect data from publicly accessible websites and social media. These special circumstances would be that we want further information on companies, their employees and/or their board of directors.
Sparinvest processes standard personal data such as your name, contact information, information about your finances and any services you receive.
Sparinvest also handles your passport and CPR data if we are required to do so by law.
Sparinvest does not gather specific categories of personal data (sensitive personal data) about you.
Legal basis for processing your personal data
Data protection is an integral part of our business. We are responsible for protecting your personal data when you communicate with us in relation to our consulting, execution of transactions and our administration of your relationship with us as a customer. Our treatment of your personal data is in compliance with all relevant national and international legislation and standards regarding the protection of personal data.
The legal basis for our treatment of your personal data is based on:
- Your voluntarily given, specific and informed permission to process your data for specific purposes
- Fulfilment of a contract with you, particularly in relation to your relationship with us as a customer
- Compliance with a legal obligation, such as Sparinvest’s obligations with regard to the money laundering legislation, as well as documenting investments and accounting materials and/or:
- Our legitimate interests in processing personal data that are not superseded by your interests or fundamental rights. Examples of these interests are invoicing for services rendered, our communication with you if Sparinvest has any questions regarding specific services, storage of data for documentation purposes, data storage for documentation purposes, handling of a current or potential legal dispute, retention and improvement of customer relations with you, and the optimisation of our website
Who receives your personal data?
Sparinvest sometimes shares your personal data with others. This could be the public authorities in connection with money laundering legislation, for example. In addition, Sparinvest can also share your personal data with intra-group companies or third-party vendors. The third parties that Sparinvest shares personal data with act solely on behalf of Sparinvest and in accordance with Sparinvest’s instructions. The third parties are not entitled to process your personal data for their own purposes unless legislation and/or the relevant authorities require it.
Transferring your personal data to a country outside the EU/EEA
In certain circumstances, your personal data may be transferred to a third-party country outside the EU/EEA, for example if Sparinvest uses a third-party vendor located in such a country. Sparinvest ensures that any such transfers take place in accordance with the relevant data protection legislation. This means that any party outside the EU/EEA receiving your personal data must ensure an adequate level of protection, for example by committing to the EU/US Privacy Shield or accepting the EU commission’s standard contractual arrangements with Sparinvest. If you have any questions regarding this, you are welcome to email Sparinvest at GDPR@sparinvest.dk.
Storage of your personal data
Sparinvest stores your personal data for as long as it is necessary to fulfil the purposes mentioned above.
This means that your personal data will be stored as long as you have an active customer relationship with us and, as far as it is necessary, for a reasonable period of time after the customer relationship has ended. This is for documentation purposes. The length of this period is normally three years.
In addition, Sparinvest stores your personal data related to specific transactions in accordance with legal, financial and accounting purposes. For example, accounting records are kept for accounting purposes for five years from the end of the fiscal year to which the material relates, in accordance with the special regulations for storing accounting records specified in current accounting legislation. After this time, the personal data will be deleted.
If you are not a Sparinvest customer, we normally keep your personal data for up to three years from the date of your last inquiry.
When you are registered, you have the opportunity to exercise the following rights:
- The right to access your information
You have the right to request access to the personal data that Sparinvest processes about you. Sparinvest must provide a copy of the personal data that is processed (free of charge) or disclose the information in electronic form.
- The right to rectify your information
You have the right to rectify incorrect personal data, including completing incomplete personal data.
- The right to delete information (the right to be forgotten)
Under certain circumstances you have the right to have personal information about you deleted.
- The right to limit usage
Under certain circumstances you have the right to limit Sparinvest’s processing of your personal data.
- The right of data portability
When data processing is based on consent or a contract and the processing takes place automatically, you have the right to receive your personal data in a structured, commonly used and readable format. If it is technically possible, you have the right to have this personal data transferred to a third party without hindrance from Sparinvest.
- The right to object
Under certain circumstances you have the right to object at any time about Sparinvest’s processing of your personal data. In particular, you have the unconditional right to stop personal data being processed for use in direct marketing.
If the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Please note that this does not affect Sparinvest’s processing of your personal data prior to the withdrawal of your consent.
Submission of complaints
If you wish to submit a complaint regarding Sparinvest’s processing of your personal data, please contact Sparinvest at GDPR@sparinvest.dk.
You have also a right to file a complaint to your national supervisory authority or Luxembourg National Commission for Data protection:
Commission Nationale pour la Protection Donnees
1, Avenue du Rock’n Roll
Telephone number: (+352) 26 10 60 – 1
25th May 2018.