Alter Domus

Privacy Notice

AD PN Version 02 for January 2020 (17 Jan 2020)

Introduction

Alter Domus respects your right to privacy.  This Privacy Notice explains, where we act as the data controller, who we are, how we collect, share and use personal information about you, and how you can exercise your data protection rights.   It also describes where we act as a data processor.  It applies to all individuals who access our website at www.alterdomus.com, engage our services, provide services to us, and who participate in our recruitment activities or are current or past employees. We recommend that you read this Privacy Notice in full to ensure you are fully informed.


For more information about Alter Domus and the services which we provide, please see the Alter Domus website at www.alterdomus.com.


This privacy notice addresses both private individuals and organizations whose employees may have their personal data processed by Alter Domus. Individuals or organizations referred above include clients, prospective clients or their representatives, agents or appointees, or a representative of an organization Alter Domus have a business relationship with.

Who are Alter Domus?

Alter Domus Participations S.à r.l., Société à responsabilité limitée and its affiliates (hereafter referred to as ‘Alter Domus’), with our main establishment situated on 15 Boulevard F. W. Raiffeisen, in Luxembourg, is the data controller where Alter Domus acts as a controller, and is committed to protect your personal data and to comply with the data protection legal framework in Europe and in every country in which we have an affiliate.


With many offices and desks around the world, Alter Domus has a global reach. Our teams combine cross-border transaction experience with local accounting knowledge to assist our clients in implementing complex international investment structures while servicing their local administrative needs.

Contact Details of the Data Protection Officer (DPO)

The Alter Domus Global Data Protection Officer can be contacted at the address above or via e-mail .

How does Alter Domus collect your personal data?

There are several ways in which Alter Domus collects information about you:
 

  • When you provide personal data directly to Alter Domus
  • When your personal data is provided by your company to Alter Domus
  • When you communicate with Alter Domus through mail, email, phone, fax, or any other form of electronic or non-electronic communication method
  • When your personal data is provided by trusted third parties, including recruitment agencies, independent financial advisors, publicly accessible directories, industry databases, other business intelligence tools Alter Domus subscribes to or a referral.
  • When you provide your personal data during the on boarding process as a client of Alter Domus
  • When your personal data is obtained through third party service providers during the on boarding process as a client of Alter Domus, namely anti money laundering service providers, credit reference agencies, fraud prevention agencies, registers and records, sanctions checking and background screening service providers
  • When we obtain your personal data through publicly available sources
  • When your personal data is shared between Alter Domus affiliates
  • When you attend our events or seminars
  • When you request our papers or answer our surveys

What personal data does Alter Domus collect?

Alter Domus collects the following categories of personal data about you:
 

  • Contact Details; including name, home or business address, home or business phone number, mobile phone number, email address and other means of contacting you.
  • Identity Data; personal data that unambiguously identifies you, such as date of birth, place of birth, nationality, national identity card number, passport number, country of residence or work.
  • Marketing and Communications Data; includes your preferences in receiving marketing from Alter Domus and your communication preferences.
  • Sensitive Personal Data; which may include health related information, disability status and records of criminal offenses or pending court proceedings.
  • Financial Data; such as bank account details, revenue, expenditures, assets, liabilities, tax reports and other relevant personal data that may be required by regulation or to fulfil the contract.
  • Client and Investor Classification Data; personal data that helps define your client profile, such as experience as a client of financial sector services, assessing politically exposed person status, assessing money laundering risk, assessing sources of wealth and other personal data.
  • Relationship Contractual Data; personal data collected during the contractual relationship, including contact history and personal data provided by you or observed and derived by the normal progression of the contract.
  • Website Usage Data; collected via cookies and similar technologies (see Cookie Notice).

How long does Alter Domus store your personal data?

The length of time for which Alter Domus holds your personal data varies. Following the principles of the GDPR and other data protection legislation across the globe, Alter Domus will not keep your data for longer than is necessary for the purposes for which the personal data is being processed.

 

As different purposes have different necessities, the retention period will vary from processing activity to processing activity and country to country. Some minimum retention periods are set by local or international laws and regulations, and Alter Domus is obliged to abide by these requirements. These are known as statutory retention periods.

Who does Alter Domus share your personal data with?

Sharing your personal data with our affiliates
To better provide our services, Alter Domus may need to share your information with our affiliates around the World.

 

Transfers of personal data between entities within the Alter Domus group of companies is supported by data processing agreements between these entities which comply with the requirements of the GDPR and other national and international regulations.  


Sharing your personal data with third parties
In no circumstances does Alter Domus ever sell personal data to external organisations.


To provide you with our services, wherever deemed essential, Alter Domus may share your personal data with third parties.  Alter Domus may share your personal data with the following where sharing your personal data is intended for the purpose of effecting, managing, reporting or establishing a relationship in regard to providing our services, or to provide employment:

 

  • Clearance and Settlement entities
  • Custodian bank or agency
  • Credit reference agencies
  • Professional services organisations such as Auditors and Law Firms
  • Transfer agent
  • Administrators
  • Government and regulatory bodies
  • Depositaries
  • Dealers
  • Employee benefit providers
  • Background screening organisations
  • Supplier Sub-processors

 

Any such sharing of your personal data is only undertaken under compliance with prevalent data protection legislation.


Alter Domus may also share your personal data if this is required by law or regulation. This may include sharing for the purposes of tax reporting, and legitimate disclosures to regulators, auditors or public authorities.  Furthermore, Alter Domus may be obliged to share your personal data with law enforcement authorities when such a demand is authorised by a Court order (if applicable).


Finally, Alter Domus will also share your personal data to establish, exercise or defend our legal rights.

How does Alter Domus protect your data?

Alter Domus uses a number of safeguards to protect your personal. Alter Domus has adopted data protection legislation compliant contracts and data sharing agreements with clients, between Alter Domus affiliates and with suppliers.


Furthermore, Alter Domus enforces security technical and procedural measures across its offices and operations, and is currently working towards consolidating many of these under an ISO27001 certification.
Examples of such measures include:

  • Physical security of access to our offices and floors
  • Restricted access control to your personal data on our systems, frequently reviewed and revised.
  • Your data is stored on servers in controlled, secure environments
  • A range of data flow detection and prevention methods
  • Restrictions on connecting non-approved devices to the Alter Domus network
  • Restrictions and safeguards related to the transmission of data externally
  • Regular training of our employees on data protection and privacy matters.

What are your data protection rights?

Numerous national and international regulations include measures to safeguard and enforce data subject rights.  Alter Domus support the rights described below, worldwide.  Not all rights are absolute:


You have the right to be informed about what, how and why we process your personal data, as outlined in other sections of this Privacy Notice.  

 

Furthermore, you have the following rights:

Right of Access – The right to obtain from the controller confirmation of whether personal data is being processed, how, why, and with what safeguards, and to receive a copy of this data.

Rectification - the right to have personal data corrected where it is inaccurate or incomplete.
Erasure (right to be forgotten) - the right to have personal data erased.

Data portability - the right to receive personally or have data sent to a third party in a common and machine-readable electronic format.

Object - the right to complain and to object to processing.

Restriction of processing (purpose limitation) - the right to limit the extent of the processing of personal data.

Automated decision-making and profiling - the right not to be subject to decisions making without human involvement.

 

These rights are best exercised by e-mailing the Alter Domus Information Governance Team at .

 

However, please be advised that these rights are not absolute, and Alter Domus may have legally valid reasons for not complying with your request. However, should this occur we will inform you of why we believe this to be the case.

 
Furthermore, you have the following right, if you disagree with our processing of your personal data or our decision to override your exercise of your rights:

Complain & Compensation - the right to complain to a relevant supervisory authority and/or claim compensation for damages or distress – See below:

What if you want to complain?

If you have a complaint in regard to the way in which Alter Domus processes your personal data please contact the Information Governance Team at


You also have the right to lodge a complaint with a supervisory authority.


Alter Domus operates over many jurisdictions.  Alter Domus main establishment is situated in Luxembourg. This means that the lead authority for the EU, under the GDPR, may be considered the Luxembourg CNPD.


The CNPD can be contacted through their online complaint form, which you can access by clicking here or by mailing the CNPD at:


Commission Nationale pour la Protection des Donnes (CNPD)
1, Avenue du Rock n’ Roll
L-4361 Esch-sur-Alzette

 

If you would like to complain to the Data Protection Authority in another jurisdiction please contact the relevant body.

What are our contact details?

Any questions you may have regarding this privacy notice, about our services, or how Alter Domus deal with your personal data while providing our services, should be addressed to the Information Governance Team at .

We can be reached via post at:


The Information Governance Team

Alter Domus Luxembourg S.à r.l.
15 Boulevard F. W. Raiffeisen,
L-2411 Luxembourg


Please mark the envelope with the word “Data Protection Team” so that Alter Domus know that it is a data protection related matter and to ensure that it is properly addressed.

Changes to the Privacy Notice

Any changes to this privacy notice in the future will be posted on this website. When major changes are made to the privacy notice, due to new regulatory demands or significant changes to processing activities, Alter Domus may notify you, depending upon our relationship with you and your contact preferences.

Nonetheless, Alter Domus recommend you check frequently to see if any updates or changes to our Privacy Notice have occurred. Privacy Notices are dated and numbered, so you can track when changes were made to the notice.

 

 

 

 

 

 

 

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