1. Introduction
This Privacy Policy describes how we collect, use, store, and protect the personal data of users of this website. It applies to anyone accessing the website, in particular accredited investors as defined by Luxembourg regulations.
We are committed to processing your personal data with full transparency and in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679.
2. Data controller
The data controller is:
33 Rosalind Franklin Street
L-4074 Esch-sur-Alzette
Grand Duchy of Luxembourg
Contact: jmtoscane@infofinancesa.com
3. Data collected
We may collect the following types of data:
Personal information: last name, first name, email address, phone number, address.
Professional information: employment status, status as an accredited investor.
Connection data: IP address, browser type, pages viewed, duration of visit.
Financial data (in the context of an investment process): banking information, amounts invested, net worth.
Data collected from cookies: browsing behavior, preferences, interactions.
4. Purposes of processing
Your data is processed for the following purposes:
Verification of Accredited Investor Status
Disclosure of Information About Our Investment Products
Handling contact and subscription requests
Improving the user experience on the website
Compliance with legal and regulatory requirements (compliance, anti-money laundering, etc.)
5. Legal basis for processing
The treatments provided are based on:
Your consent (e.g., contact form, cookies)
The performance of a contract or pre-contractual measures
Compliance with legal obligations
Our legitimate interest, particularly with regard to site security and customer relations
6. Data sharing
Your data may be shared with:
Our technical service providers (web host, web developer, analytics tools)
Our regulatory partners (advisors, auditors, regulatory authorities)
Any competent authority, in accordance with legal obligations
We do not sell or rent your personal data to third parties.
7. Shelf life
The data is retained for:
The period necessary for the purpose of the processing
Then archived in accordance with applicable legal requirements (e.g., 5 or 10 years for financial documents)
8. Your rights
In accordance with the GDPR, you have the following rights:
Right of access to your data
Right to rectification
Right to erasure (within legal limits)
Right to restriction of processing
Right to object
Right to data portability
You can exercise your rights by contacting: jmtoscane@infofinancesa.com
You also have the right to file a complaint with the CNPD (National Commission for Data Protection – Luxembourg).
9. Cookies
Our website uses cookies to:
Measuring website traffic (anonymous statistics)
Save your user preferences
Improve your browsing experienceAméliorer votre navigation
You can adjust your preferences at any time using the cookie management banner.
10. Safety
We implement appropriate technical and organizational measures to ensure the security of your data, including protection against unauthorized access, loss, or destruction.
11. Policy Change
We reserve the right to modify this policy at any time. Changes will be posted on this page along with the update date.
Last updated: March 26, 2025