Privacy notice

Alter Domus Participations S.à r.l., Société à responsabilité limitée, 5, rue Guillaume Kroll, L-1882 Luxembourg and each of its affiliates (“Alter Domus”) respects your privacy and is committed to protecting your personal data. This privacy notice (the “Privacy Notice”) relates to all personal data that you provide to Alter Domus in the context of your use of the Alter Domus Web site (regardless of where you visit the site from).

This Privacy Notice provides you with information on how Alter Domus collects and processes your personal data.

By using the Alter Domus website and services provided by Alter Domus, you consent to the data practices described in this Privacy Notice.


Collection of your Personal data

Personal data, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Alter Domus collects, uses, stores and transfers different kinds of personally identifiable information which can be grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes home or work address, email address and telephone numbers.
  • Financial Data includes bank account details.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, your interests, preferences and favorites.
  • Usage Data includes information about how you use our website, services.
  • Marketing and Communications Data includes your preferences in receiving marketing from Alter Domus and your communication preferences.

Alter Domus also collects anonymous information, which is not unique to you and does not directly or indirectly reveal your identity.

Alter Domus may collect or obtain personal data directly from you (for example by completing a form on Alter Domus Web site or attending one of our events or by going through our recruitment process) or indirectly because other people give that data to us (for example your employer or adviser or third party service providers that we use to help operate our business) or because it is publicly available.

Alter Domus may also collect personal data from you because Alter Domus combines personal data with other data made available to Alter Domus. Alter Domus may also infer personal data about you from the way you make use of the Alter Domus Web site, for example, to improve your experience when you use the Alter Domus Web site and ensure that it is functioning effectively, Alter Domus (or its service providers) may use cookies (small text files stored in a user’s browser) which may collect personal data. Additional information on how Alter Domus uses cookies and how you can control these can be found below.

Alter Domus does not intentionally collect any particularly sensitive categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and, if collected, Alter Domus does not use or disclose those sensitive personal data without your explicit consent.

Alter Domus encourages you to review the privacy statements of Web sites you use to link to Alter Domus so that you can understand how those Web sites collect, use and share your information. Alter Domus is not responsible for the privacy statements or other content on Web sites outside of the Alter Domus and Alter Domus family of Web sites.


Use of your Personal data

Purpose for which Alter Domus will use your personal data

Alter Domus collects and uses your personal data for legitimate interests, such as to operate the Alter Domus Web site. Alter Domus also uses your personal data to inform you of products or services available from Alter Domus and its affiliates. Alter Domus may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Your personal data may also be processed for compliance with statutory and regulatory obligations of Alter Domus or internal policy requirements and the order of a competent court, as well as (but not limited to) accounting, commercial communications, know-your-customer and anti-money laundering requirements, general management of the services or customer relationship purposes. Alter Domus may also process your personal data for the purposes of Alter Domus’ legitimate interest to defend Alter Domus offices, IT infrastructure and also in connection with services Alter Domus receive from professional advisors, such as lawyers and consultants or other service providers either to execute Alter Domus’ contractual obligations toward you or Alter Domus’ clients or more generally for legitimate business interest personal data.

Change of purpose

Alter Domus will only use your personal data for the purposes for which Alter Domus collected it, unless Alter Domus reasonably consider that it needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact your Alter Domus’ contact point.

If Alter Domus need to use your personal data for an unrelated purpose, Alter Domus will notify you and will explain the legal basis which allows Alter Domus to do so.

Please note that, in exceptional circumstances, Alter Domus may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law and for the purposes or in connection with the purposes set out above.

Transfer and disclosure of personal data

Alter Domus does not sell, rent or lease personal data collected from the Website to third parties. External business partners may, from time to time, contact you on behalf of Alter Domus about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is transferred to the third party. In addition, Alter Domus where necessary, may share data with trusted partners to help Alter Domus perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal data except to provide these services to Alter Domus, and they are contractually required to maintain the confidentiality of your information.

Alter Domus Web sites will disclose your personal data, without notice, only if required to do so by law or if such action is reasonably necessary to: (a) defend claims; (b) protect and defend the rights or property of Alter Domus; and, (c) act under emergency circumstances to protect the personal safety of users of Alter Domus, or the public.

As provided for under the applicable data protection laws and regulations, you are entitled to request access, correct or erase your personal data or restrict the processing of your personal data, as well as the right to data portability. To exercise these rights, please contact Alter Domus () or your Alter Domus Contact point.

You also have the right to lodge a complaint with the competent data protection authority, being in Luxembourg the Commission nationale pour la protection des données.

Data retention

Alter Domus will only retain your personal data for as long as necessary to fulfil the purposes Alter Domus collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


Security of your Personal data

Alter Domus undertakes to process your personal data only for the defined purposes and to implement appropriate technical measures to protect and to keep it confidential. Your personal data will not be disclosed to any third party within or outside the European Union (including in countries that do not offer an adequate level of protection), other than other Alter Domus entities and/or third parties directly concerned by the defined purposes.

Alter Domus secures your personal data from unauthorized access, use or disclosure. Alter Domus secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

In addition, Alter Domus limit access to your personal data to those employees, agents, contractors and other third parties who require such information in order to fulfil a purpose. They will only process your personal data on Alter Domus’ instructions and they are subject to a duty of confidentiality.

Alter Domus has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach or suspected breach where Alter Domus is legally required to do so.


Use of Cookies

The Alter Domus Web site use "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Alter Domus pages, or register with Alter Domus site or services, a cookie helps Alter Domus to recall your specific information on subsequent visits. When you return to the same Alter Domus Web site, the information you previously provided can be retrieved, so you can easily use the Alter Domus features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Alter Domus services or Web sites you visit.


Changes to this PRIVACY notice

Alter Domus will occasionally update this Privacy Notice to reflect company and users’ feedback. Alter Domus encourages you to periodically review this Privacy Notice to keep up to date in relation to how Alter Domus is protecting your information.


Contact Information

Alter Domus welcomes your comments regarding this Privacy Notice. If you believe that Alter Domus has not adhered to this Privacy Notice, please contact Marc Vatrey, the Alter Domus E-Business Manager: . We will use commercially reasonable efforts to promptly determine and remedy the problem.


Official Registration

  • Alter Domus Luxembourg S.à r.l. is member of the Luxembourg Ordre des Experts-Comptables.
  • Alter Domus Liquidation Services S.à r.l. is member of the Luxembourg Ordre des Experts-Comptables.
  • Alter Domus Alternative Asset Fund Administration S.à r.l. is regulated by the Commission de Surveillance du Secteur Financier.
  • Alter Domus Depositary Services S.à r.l. is regulated by the Commission de Surveillance du Secteur Financier.
  • Alter Domus Management Company S.A. is regulated by the Commission de Surveillance du Secteur Financier.
  • Alter Domus Netherland BV is regulated by the Dutch Central Bank.
  • Alter Domus (Jersey) Limited, Sumod (Jersey) Limited is regulated by the Jersey Financial Services Commission.
  • Alter Domus Secretarial Services Limited is regulated by the Jersey Financial Services Commission.
  • Alter Domus (Guernsey) Limited is regulated by the Guernsey Financial Services Commission.
  • Alter Domus Depositary Services (UK) Limited is regulated by the Financial Conduct Authority.
  • Alter Domus  Fund Services (UK) Limited is regulated by the Financial Conduct Authority.
  • Cortland Capital Market Services Limited is regulated by the Financial Conduct Authority.
  • Alter Domus Fund Services (Ireland) Limited is regulated by the Central Bank of Ireland.
  • Alter Domus France is a member of the French Ordre des Experts-Comptables.
  • Alter Domus (Mauritius) Limited is regulated by the local Financial Services Commission.
  • AD-BEL Services SPRL is a member of the Institut des Professionnels Comptables et Fiscalistes.
  • Alter Domus (Services) Malta Limited, is regulated by the Malta Financial Services Authority.
  • Alter Domus Fund Services (Malta) Limited is regulated by the Malta Financial Services Authority.
  • Alter Domus Trustee Services (Malta) Limited is regulated by the Malta Financial Services Authority.
  • Virtue Resources Limited is regulated by the Malta Financial Services Authority.
  • Alter Domus (Cyprus) Ltd is regulated by the Cyprus Securities and Exchange Commission.
  • Alter Domus Cayman Limited is regulated by the Cayman Islands Monetary Authority
  • Alter Domus Hong Kong Limited is regulated by the Registry for Trust and Company Service Providers of the Companies Registry of Hong Kong

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