1. General
This privacy policy provides information on how URBAN EQUITY GP S.à.r.l. processes personal data. “Personal data” means all information relating to an identified or identifiable natural or legal person. “Processing” means any handling of personal data, regardless of the means and procedures used, in particular the acquisition, storage, use, modification, disclosure, archiving, deletion or destruction of personal data.
For certain data processing, e.g. in the context of concluding contracts with URBAN EQUITY GP S.à.r.l. or in connection with URBAN EQUITY websites, there are further regulations (such as terms of use). These are available in the corresponding contracts or on the corresponding websites. In addition, the General Terms and Conditions (GTC) contain general information on data protection, in particular in connection with the performance of contracts in banking.
2. Data Protection
URBAN EQUITY GP S.à.r.l. is committed to protecting personal data and privacy in accordance with the applicable laws, in particular client confidentiality and data protection law. To this end, URBAN EQUITY GP S.à.r.l. takes various technical and organisational security measures (e.g. access restrictions, firewalls, personalised passwords as well as encryption and authentication technologies, training of employees, etc.).
3. Categories of Personal Data
URBAN EQUITY GP S.à.r.l. processes the following categories of personal data. We always process as little personal data as possible.
Data of the partners of URBAN EQUITY GP S.à.r.l., such as:
Master and inventory data (e.g. name, address, nationality, date of birth, professional background)
Technical data (e.g. business numbers, IP addresses, internal and external identifiers, records of access)
Marketing data (e.g. preferences, needs)
Client data, such as:
Master and inventory data (e.g. name, address, nationality, date of birth, tax number, information regarding account, custody account, concluded transactions and contracts, information on third parties affected by data processing, such as spouses, authorised representatives and advisors)
Transaction or order and risk management data (e.g. details of beneficiaries of transfers, beneficiary bank, amount of transfers, risk and investment profile, details of investment products)
Technical data (e.g. business numbers, IP addresses, internal and external identifiers, records of access)
Marketing data (e.g. preferences, needs)
Visitor and prospect data (e.g. visitors to URBAN EQUITY GP S.à.r.l. or URBAN EQUITY websites), such as:
Master and inventory data (e.g. name, address, date of birth)
Technical data (e.g. IP addresses, internal and external identifiers, access records)
Marketing data (e.g. preferences, needs)
Supplier data, such as:
Master and inventory data (e.g. name, address, date of birth, information on concluded transactions and contracts)
Technical data (e.g. IP addresses, internal and external identifiers, access records)
4. Origin of Personal Data
URBAN EQUITY GP S.à.r.l. may collect personal data from the following sources in order to fulfil the purposes set out in section 5:
Personal data provided to URBAN EQUITY GP S.à.r.l., e.g. when opening a business relationship, in the context of the execution of contracts, the use of products and services or on websites.
Personal data that accrue in the context of the use of products or services and are transmitted to URBAN EQUITY GP S.à.r.l. through the technical infrastructure or through processes based on the division of labour, e.g. in payment transactions, securities trading, eBanking, websites or on the occasion of cooperation with other financial or IT service providers, marketplaces and stock exchanges.
Personal data from third-party sources, e.g. authorities or sanctions lists of the UN and the EU.
5. Purposes of Processing
URBAN EQUITY GP S.à.r.l. may process personal data for the provision of its own services and for its own purposes or those provided for by law. In particular, the following should be considered:
Conclusion and fulfilment of contracts, execution, processing and administration of products and services (e.g. accounting, tax returns, commercial register entries and mutations, invoices, account openings, payments, financing, financial planning, investments, pension provision, insurance, consolidation)
Monitoring and controlling risks (e.g. investment profiles, anti-money laundering, limits, utilisation figures, market, credit or operational risks)
Statistics, planning, business decisions (e.g. development of new or assessment of existing services, products, processes, technologies)
Marketing, communicating, informing about and reviewing the service offering (e.g. print and online advertising, customer, prospect or other occasions, identifying future customer needs, assessing a customer, market or product potential)
Fulfilment of statutory or regulatory obligations to provide information or to report to courts and authorities, fulfilment of official orders (e.g. reporting duties vis-à-vis supervisory authorities and foreign tax authorities, orders issued by public prosecutors in connection with money laundering and terrorist financing)
Safeguarding the interests and securing the claims of URBAN EQUITY GP S.à.r.l., e.g. in the event of claims against the firm or claims of the firm against third parties
6. Disclosure to Third Parties, Categories of Recipients
URBAN EQUITY GP S.à.r.l. discloses customer data to the following third parties in the following cases:
For outsourcing in accordance with Clause 7 and for the purpose of comprehensive customer care to other service providers
For order execution, i.e. when products or services are used, e.g. to service providers, stock exchanges or marketplaces, reports of stock exchange transactions to (international) trade repositories
Due to legal obligations, legal justification or official orders, e.g. to courts, supervisory authorities, tax authorities or other third parties
To the extent necessary to protect the legitimate interests of URBAN EQUITY GP S.à.r.l., e.g. in the event of legal action threatened or initiated by customers, in the event of public statements, to secure claims of URBAN EQUITY GP S.à.r.l. against customers or third parties, in the event of collection of claims
With the consent of the data subjects to other third parties
Particularly when using certain products or services of URBAN EQUITY GP S.à.r.l., personal data may also have to be disclosed to third parties in countries where there is no adequate level of data protection (e.g. USA). If a transfer to such a country is necessary, URBAN EQUITY GP S.à.r.l. will, if possible, take appropriate precautions to continue to protect personal data adequately.
7. Outsourcing of Business Areas or Services (outsourcing)
URBAN EQUITY GP S.à.r.l. outsources certain business areas and services in whole or in part to third parties (such as account management including payment transactions, custody account management, preparation of consolidation reports, fund limit checks, definition of fund limit rules, opening of securities, updating of restriction rules, IT systems, etc.). The service providers who process personal data on behalf of URBAN EQUITY GP S.à.r.l. for this purpose (so-called order processors) are carefully selected. Whenever possible, URBAN EQUITY GP S.à.r.l. uses order processors domiciled in Switzerland or the EEA. The order processors may be entitled to have certain services (e.g. electronic data processing, securities settlement, etc.) provided by third parties.
The commissioned processors may only process personal data received in the same way as URBAN EQUITY GP S.à.r.l. itself and are contractually obliged to guarantee confidentiality, client secrecy and the security of the data.
Outsourcing by URBAN EQUITY GP S.à.r.l. is carried out in accordance with applicable regulatory standards.
8. Automated Decisions in Individual Cases Including Profiling
URBAN EQUITY GP S.à.r.l. reserves the right to process customer data automatically in the future, if necessary, in particular in order to identify essential personal characteristics of the customer, to predict developments and to create customer profiles. This serves in particular to review and further develop offers and to optimise the provision of services.
Customer profiles may also lead to automated individual decisions (e.g. automated acceptance and execution of orders in digital services). URBAN EQUITY GP S.à.r.l. ensures that a contact person is available if a data subject wishes to comment on an automated individual decision and such a possibility to comment is provided for by law.
9. Use of Websites and Cookie Policy
When a person visits URBAN EQUITY GP S.à.r.l. websites, the web server automatically records details of their visit (e.g. the website from which the visit is made, the IP address of the person visiting the site, the date of the visit, the content of the website that is accessed, including the date and duration of the visit). Such tracking data serve to optimise the websites and provide information on how the visitor informs themselves about and uses the products, services and offers. As a rule, however, they do not allow any conclusions to be drawn about the identity of the visitor. In this respect, no personal data is processed.
However, if the visitor provides personal data, e.g. by filling in a registration form or message field for newsletters, URBAN EQUITY GP S.à.r.l. may use this data in addition to the purposes stated under point 5, in particular for the following:
– for customer and user administration
– to inform the visitor about services and products
– for marketing purposes (e.g. sending newsletters)
– for the technical "hosting" and further development of the URBAN EQUITY GP S.à.r.l. websites
By using the websites, visitors confirm their express consent to this privacy policy and the risks mentioned.
In addition, by using the URBAN EQUITY GP S.à.r.l. website, a visitor agrees to the use of cookies. Cookies are small files that are stored on the computer of the visitor to track the corresponding website visit and navigation between different pages and/or to save settings (e.g. selected language). Cookies are used to collect statistical data on the frequency and time of visits to individual website areas and help to design tailored, useful and user-friendly websites. The visitor can decide against the use of cookies at any time by deleting the cookies set by the URBAN EQUITY GP S.à.r.l. website. Deletion is possible via the settings in the visitor's internet browser.
URBAN EQUITY GP S.à.r.l. may use third-party components (such as plug-ins) to enhance the user experience and advertising campaigns. These components may also use cookies for similar purposes. Neither these third parties nor URBAN EQUITY GP S.à.r.l. have access to the data collected by the other via cookies. Finally, URBAN EQUITY GP S.à.r.l. may use cookies as part of advertising on third-party websites. Where third parties collect anonymised information about the use of URBAN EQUITY GP S.à.r.l. websites and other websites, URBAN EQUITY GP S.à.r.l. may use this anonymised data to improve the effectiveness of its advertising.
This privacy policy applies only to data that URBAN EQUITY GP S.à.r.l. receives as a result of the use of its own websites. It is not applicable to third-party websites, even if the visitor reaches them via links. URBAN EQUITY GP S.à.r.l. has no influence on the content and data protection practices of third-party websites and assumes no responsibility for them.
10. Duration of Storage
The duration of the storage of personal data depends on the purpose of the respective data processing and/or statutory retention obligations, which may amount to five, ten or more years depending on the applicable legal basis.
11. Rights of the Data Subjects
Anyone can request information from URBAN EQUITY GP S.à.r.l. as to whether personal data about them is processed. There is a right of objection, restriction of processing and, where applicable, the right to data portability. Incorrect data can be corrected. Furthermore, the deletion of personal data can be requested, unless legal or regulatory provisions (e.g. retention obligations) or technical hurdles prevent this. The deletion of data may result in URBAN EQUITY GP S.à.r.l. no longer being able to provide certain services. In addition, where applicable, there is a right of appeal to a competent authority. Where URBAN EQUITY GP S.à.r.l. processes personal data on the basis of consent, this consent may be revoked at any time.
In order to assist URBAN EQUITY GP S.à.r.l. in responding to your request, please provide an appropriate and understandable communication. We will review and respond to concerns within a reasonable period of time.
12. Contact
URBAN EQUITY GP S.à.r.l. is responsible for processing your personal data.
The contact details of URBAN EQUITY GP S.à.r.l. are as follows:
URBAN EQUITY GP S.à.r.l.
Avenue de la Liberté 62
L-1940
Luxembourg
+423 340 14 88
hello@URBANEQUITY.com