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Privacy Notice

“LS International Finance”, “we”, “us” and “our” means LS International Finance SA and we are committed to respecting your privacy in accordance with the requirements of the General Data Protection Regulation (GDPR).


Key definitions


GDPR

The General Data Protection Regulation (EU) 2016/679 is an EU regulation on personal data protection and privacy. GDPR achieves the uniformity in the data protection rules applicable to all individuals within the European Union and the United Kingdom.


Personal Data

Any information related to an identified individual or that may allow to directly or indirectly identify an individual (e.g. name, phone number, job title). Personal Data does not include any information or data related to legal entities (e.g. investment funds, securities issuers…).


Processing

Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means (e.g. collection, recording, organization, storage, consultation).


Data controller

The person or entity that determines the purpose and means of the processing of the Personal Data.


For the purposes of GDPR (the data protection law), we are a data controller in respect of your personal data. LS International Finance is responsible for ensuring that it uses your personal data in compliance with data protection law.


This privacy notice applies if you are a client, a prospective client, an intermediary or a client of an intermediary. The privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.


Personal data that we collect about you


We will collect and process the following personal data about you if you communicate with us by phone, e-mail or otherwise: name, address, e-mail address and telephone number, financial information, nationality.



Uses of your personal data


Your personal data may be stored and processed by LS International Finance to enable us to:

  • perform our contractual obligations to you

  • answer your enquiry

  • comply with our legal requirements or internal policies and procedures

  • establish, exercise or defend our legal rights or for the purpose of legal proceedings.


The use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates).


Disclosure of your information to third parties


We will take steps to ensure that the personal data is accessed only by the personnel of such affiliates that have a need to do so for the purposes described in this notice.


We may also share your personal data outside of LS International Finance and our affiliates:

  • with our business partners. For example, this could include our partners who provide you or your company or your organisation with services alongside or related to, those provided by LS International Finance. Personal data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;

  • with third party agents and contractors for the purposes of providing services to us (for example, our accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your personal data as described in this Privacy Policy;

  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;

  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;

  • to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and

  • to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.


Transfers of personal data outside the European Economic Area


The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for our affiliates or for one of our suppliers.


Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

  • the country that we send the data to might be approved by the European Commission;

  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or

  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.


In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.


You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.


Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and

  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.


Your rights

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;

  • the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;

  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;

  • the right to request that we rectify your personal data if it is inaccurate or incomplete;

  • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;

  • the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request; and

  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.


You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.


Contacting us


If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to our Data Protection Officer at data@lsif.lu

Privacy: Welcome
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