Alter Domus

Privacy Notice

Version 5

29 September 2020

Introduction

Alter Domus offers a comprehensive range of services spanning fund administration, corporate services, agency services, CLO collateral administration, credit and structured product services, depositary services, transfer pricing, wealth administration, domiciliation, and management company services.

 

Alter Domus is a fully integrated Fund and Corporate services provider dedicated to clients internationally, and are committed to respecting your privacy - wherever you may be in the world.

 

This Privacy Notice explains who we are, how we collect, share, safeguard and use your personal data, and how you can exercise your privacy rights.

 

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

 

If you are an Alter Domus employee please refer to your Employee Privacy Notice for more information about how we process your personal data as an employee.

Who is 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 collects and processes personal data for our own purposes.

 

“Alter Domus”, “we”, “us” and “our” means Alter Domus Participations S.à r.l. and its affiliates.

Contact Us

If you have any questions regarding this Privacy Notice, enquiries regarding data protection, or wish to exercise your rights please contact our Data Protection Officer as shown:

 

By email:

Updates to this Privacy Notice

This Privacy Notice is updated from time to time, all versions are dated and numbered at the top of the notice.

Third Party Websites

Links to and from other websites, which are independent of Alter Domus, are maintained by third parties. Alter Domus is not responsible for the content or privacy practices of any third-party websites and shall not be liable for any damages or harm arising from the content and use of such websites.

 

Any links to other websites are provided as a convenience to you as a user, and do not imply our endorsement of the linked websites or association with their operators.

Privacy Laws

Alter Domus is compliant with data protection legislation within all of the jurisdictions in which it operates.  The jurisdictions in which we operate are listed on the Alter Domus website at www.alterdomus.com.  

Cookies

As a website visitor, Alter Domus collects personal data from you to administer the site, to improve your browsing experience, and to enable visitors to be better informed of the services available through Alter Domus. Such data is obtained through the use of cookies and similar technologies.

 

For further information on our use of cookies please see the Alter Domus Cookie Notice.

How Alter Domus Collects Personal Data from You

Alter Domus collects your personal data when you:

  • Complete an online contact form or survey

  • Visit our website (see Cookie Notice)

  • Register to receive our email newsletter(s) or other communications

  • Enter a competition or promotion

  • Request, contract and use a service from us

  • Communicate with us via phone calls, chat, email, web forms, social media and other methods of communication

  • Attend our events

  • Provide services to us

Personal Data Alter Domus Collects from Others

Alter Domus works with a number of third parties and may receive your personal data from them. The third parties include, but are not limited to:

  • Business partners

  • Clients and prospective clients

  • Suppliers

  • Sub-contractors

  • Advertisers

  • Referrers

Where another party (such as a company or a partnership or any third parties acting on you or your behalf) provides your personal information to us, they must also comply with their obligations under the relevant privacy laws and regulations. If you believe that the entity for whom you work or a third party has not provided you with details of the personal information that it holds about you and/or has not obtained your authority to provide us with that personal information for processing as described in this Privacy Notice, then please contact such entity directly.

Types of Data Alter Domus Collects

  • Identity Data; this includes but is not limited to first name, last name, date of birth, place of birth, nationality, passport details, national identity card number or social security number
  • Contact Data; this includes email address, telephone number(s) and postal address
  • Financial Data; this includes banking details, income details, tax information, source of wealth
  • Employment Details; this includes job titles, employment history
  • Technical Data; subject to your cookie settings this may include internet protocol (IP) address, browser type and version, operating system
  • Any personal data about you included in free text boxes; including in relation to enquiries or comments submitted to us
  • Other User Profile Data such as feedback and survey response

Sharing Your Personal Data

When necessary, Alter Domus shares your personal data with:

  • Vendors and administrative support, infrastructure, and other service providers handling your information on our behalf, such as AML/KYC providers; in each case, such vendors and service providers will be contractually bound by confidentiality and privacy obligations consistent with the obligations in this Privacy Statement
  • Tax, government and any relevant regulatory authorities
  • Prosecuting authorities and courts, and/or other relevant third parties connected with legal proceedings or claims
  • Fraud prevention and/or law enforcement agencies
  • Third parties where Alter Domus is required to do so by law
  • Third parties to whom we disclose information in the course of providing services to you or to the entity that has engaged us to provide the services

Security of Personal Data

Security of all personal data is extremely important to Alter Domus. We have implemented technical, administrative and physical security measures to help protect your personal data from unauthorised access and improper use.  Alter Domus uses a number of safeguards to protect your personal data. 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

How We Use Personal Data

Please note where we collect personal data for a statutory or contractual requirement, or a requirement necessary to enter into a contract you are obliged to provide the personal data. Failure to do so may mean that we are unable to provide our services to you.

 

The primary purpose categories for which Alter Domus may process your personal data are listed below, along with representative types of data. The key legal bases are also stated for jurisdictions within the EU, and Jersey, Guernsey, Mauritius and Cayman Islands. Other jurisdictions do not require the legal bases to be stated, and these may vary according to local law:

 

 

 

Purpose Categories

Type of data

Lawful basis for processing

To perform AML and KYC checks

Identity, Contact,
Financial, Employment

  • Necessary to comply with a legal obligation

  • Performance of a contract
     

To deliver our services

Identity, Contact,
Financial, Technical,

Employment

  • Performance of a contract

  • Necessary to comply with a legal obligation

  • Necessary for our legitimate interests
     

To comply with tax reporting requirements

 

Identity, Contact
Financial, Employment

  • Necessary to comply with a legal obligation

To manage our relationship with you

Identity, Contact,

Financial, Employment

  • Performance of a contract

  • Necessary to comply with a legal obligation

  • Necessary for our legitimate interests

To send you marketing information about our
services that we think may be of interest to you
 

Identity, Contact,

Technical

  • Consent

  • Necessary for our legitimate interests

To exercise or defend our legal rights

Identity, Contact,
Financial, Employment,

Technical

  • Necessary for our legitimate interests

 

International Data Transfers

Your personal data may be transferred internationally to trusted service providers and other third parties when necessary. When doing so Alter Domus transfers personal data pursuant to established safeguards such as the use of EU Standard Contractual Clauses, and the EU/US and US Swiss Privacy Shield (see below).

EU – US and US Swiss Privacy Shield

Alter Domus’ US operations participates in the EU-US and US Swiss Privacy Shield Program.

 

Adoption of the Privacy Shield Framework includes adherence to the Privacy Shield Principles, a set of requirements governing participating organisations’ use and treatment of personal data received from the EU.

 

To view our Privacy Shield Notice, please click here.  For more information and to check our certification status please visit www.privacyshield.gov.

Retaining Personal Data

Alter Domus retains your personal data only for as long as is necessary for our purposes.

 

Alter Domus retains a Data Retention Schedule as part of its Alter Domus’ Data Retention Policy.  This policy and schedule complies with the legal retention requirements of all of the jurisdictions in which we operate.

 

These documents are reviewed and updated regularly. We keep personal data for as long as it is required to meet legal or regulatory obligations and for the exercise and/or defence of any legal claims.

Automated Decision Making

Alter Domus does not use any automated processes to make decisions about you without human intervention. 

What are your Data Protection Rights?

Numerous national and international regulations include measures to safeguard and enforce data subject rights.  Alter Domus supports the rights described below except where doing so would contravene the requirements of local law or regulations.  Please see the table – Subject Rights by Jurisdiction – below, to clarify applicable variances.

 

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

 

Furthermore, you have the following rights (subject to your jurisdiction):

  • Right of Information and Access – The right to obtain from the controller confirmation of whether personal data is being processed, information in clear and transparent language on how it is used and by whom, 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 to a relevant supervisory authority and/or claim compensation for damages or distress
  • 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 decision making without human involvement

The following table outlines your valid legal rights for jurisdictions which do not follow EU regulations or adopt similar mechanisms (such as Jersey, Guernsey and Mauritius):

 

Subject Rights by Jurisdiction USA* Cayman Islands Australia Hong Kong Singapore China Japan
Right to be informed Statute specific Yes Yes Yes No Yes Yes
Right of access Statute specific Yes Yes Yes Yes Yes Yes
Right of rectification Statute specific Yes Yes Yes Yes Yes Yes
Right of portability Statute specific No No No No No No
Right to object Statute specific Yes No No No No Yes
Restriction of processing Statute specific Yes No No No Yes Yes
Erasure Statute specific No** No No No Yes Yes

Note:

*Determined by state specific legislation, and sector specific Federal Laws and Guidelines

**Except under order of the Commissioner

 

You can request to exercise your rights by getting in touch with us using the contact details found in the ‘Contact Us’ section of this notice.  This includes the withdrawal of consent where consent is used as the legal basis.

 

Please be advised that these rights are not absolute, and Alter Domus may have legally valid reasons for not complying with your request. We will inform you where this is the case.

Your California Privacy Rights

Right Not to Sell Your Data:  California Civil Code permits California residents to request from companies conducting business in California a list of third parties to which the company has disclosed personally identifiable information during the preceding year for direct marketing purposes.

 

Alter Domus does not sell or otherwise share your personal data with third parties for their direct marketing purposes; accordingly, we do not maintain such a list of third parties.

 

If you are a resident of California and would like additional information you may contact the U.S. data protection contact using the contact details found in the ‘Contact us’ section of this notice.

How to Complain

If you have a complaint in regard to the way in which Alter Domus processes your personal data please get in touch using the details found in the ‘Contact Us’ section of this notice.

 

You also have the right to lodge a complaint with a supervisory authority. Alter Domus’ main establishment is based in Luxembourg. The Commission Nationale pour la Protection des Donnes (CNPD) is the supervisory authority in Luxembourg.

 

The CNPD can be contacted through their online complaint form available here, or by post:


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

 

Alter Domus operates over many jurisdictions. If you would like to complain to the Data Protection Authority in another jurisdiction please contact the relevant body. Contact details for other European Supervisory Authorities can be found here. For Cayman Islands please contact the Ombudsman.

Alter Domus Entities

Alter Domus Luxembourg S.à r.l.

Business Office Services S.à r.l.

Alter Domus Alternative Asset Fund Administration S.à r.l.

Alter Domus Liquidation Services S.à r.l.

Alter Domus International S.à r.l.

Alter Domus Transfer Pricing S.à r.l.

Alter Domus Group S.à r.l.

Alter Domus Co-sourcing Services S.à r.l.

Alter Domus Participations S.à r.l.

Alter Domus Depositary Services S.à r.l.

Paradocs Holding S.à r.l.

Castlelux Two S.à r.l.

Alter Domus Management Company S.A.

Alter Domus (Services) Malta Limited

Alter Domus Fund Services (Malta) Limited

Virtue Resources Limited

Alter Domus (Holding) Malta Limited

Alter Domus Trustee Services (Malta) Limited

Alter Domus (Treasury) Malta Limited

Business Office Services International (Malta) Limited

Alter Domus (Treasury) Malta USD Limited

Alter Domus (Cyprus) Limited

Alter Domus Services Limited

Alter Domus Nominees Limited

Alter Domus Management Limited

Leverie Limited

Manakinel Limited

Branile Limited

BOS BUSINESS OFFICE SERVICES (CYPRUS) LIMITED

Alter Domus Nederland B.V.

Business Office Services Netherlands B.V.

Corfas B.V.

Alter Domus Liquidation Services B.V.

Alter Domus (UK) Limited

Alter Domus Depositary Services (UK) Limited

Alter Domus Fund Services (UK) Limited

Alter Domus DCM (UK) Limited

Alter Domus Trustees (UK) Limited

Alter Domus Agency Services (UK) Limited

Alter Domus Financial Services (UK) Limited

Alter Domus (Jersey) Limited

Alter Domus (Services) Limited

Alter Domus Secretarial Services Limited

Sumod (Jersey) Limited

Alter Domus (Jersey) Listing Services Limited

Sumod (Guernsey) Limited

Alter Domus (Guernsey) Limited

Alter Domus (Ireland) Ltd

Acorn Investments Limited

Alter Domus Secretarial (Ireland) Limited

Alter Domus Fund Services (Ireland) Limited

Alter Domus Depositary Services (Ireland) Limited

Pragma Business Services SRL

AD-BEL Services SPRL

Pragma Accountancy SPRL

Alter Domus Fund Services France SAS

Alter Domus France SAS

Alter Domus Iberia S.L.

AD Iberia Management, S.L.

Alter Domus Deutschland GmbH

Alter Domus Inc.

AD Carta, LLC

Alter Domus (US) LLC

Cortland Capital Market Services LLC

Alter Domus Products Corp.

Alter Domus (CA) Inc.

Alter Domus Cayman Limited

Alter Domus Singapore Pte Ltd

Alter Domus Hong Kong Limited

Alter Domus Alternative Asset Fund Administration (Beijing) Limited

Alter Domus China Limited

南京凯达兰信息咨询有限公司

アルタードムス・ジャパン株式会社

Alter Domus Japan K.K.

Alter Domus Australia PTY Ltd

Alter Domus (Mauritius) Ltd

Alter Domus Mauritius (Nominees) Ltd