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Disclaimer and legal information

Data protection information for users of the homepage and newsletter

1. An overview of data protection

General

The following gives a simple overview of what happens to your personal information when you visit our website. Personal information is any data with which you could be personally identified. Detailed information on the subject of data protection can be found in our privacy policy found below.

Data collection on our website

Who is responsible for the data collection on this website?
The data collected on this website are processed by the website operator. The operator’s contact details can be found in the website’s required legal notice.

How do we collect your data?
Some data are collected when you provide it to us. This could, for example, be data you enter on a contact form. Other data are collected automatically by our IT systems when you visit the website. These data are primarily technical data such as the browser and operating system you are using or when you accessed the page. These data are collected automatically as soon as you enter our website.

What do we use your data for?
Part of the data is collected to ensure the proper functioning of the website. Other data can be used to analyze how visitors use the site.

What rights do you have regarding your data?
You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.

2. General information and mandatory information

Data protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with the statutory data protection regulations and this privacy policy. If you use this website, various pieces of personal data will be collected. Personal information is any data with which you could be personally identified. This privacy policy explains what information we collect and what we use it for. It also explains how and for what purpose this happens. Please note that data transmitted via the internet (e.g. via email communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.

Notice concerning the party responsible for this website

The party responsible for processing data on this website is:

Nordlux Vermögensmanagement S.A.
7, rue Lou Hemmer
L-1748 Luxembourg – Findel

Telephone: +352 26198-1
Email: kontakt@nordlux-vm.lu

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).

Revocation of your consent to the processing of your data

Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

Right to file complaints with regulatory authorities

If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for matters related to data protection legislation is the National Commmission for Data Protection of the Grand-Duchy of Luxembourg in which our company is headquartered. The complaint form to file your complaint can be found at the following link https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html

Right to data portability

You have the right to have data which we process based on your consent or in fulfillment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar. If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.

Other privacy rights

You have the right of free information on your stored personal data, e.g. correction, blocking, deletion and limitation of processing within the scope of the applicable legal provisions. You also have the right not to be subject to any decision based solely on automated processing, including profiling, that will have legal effect or similarly affect you in a similar manner. For further information on personal data, please contact us at any time at the address given in the imprint.

Opposition to promotional emails

We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements with regard to sending promotional and informational materials not expressly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as email spam, is received.

3. Data collection on our website

Cookies

To design our website according to the needs of the users, we need certain information. Among other things, we use cookies in order to collect this information. The purpose of these cookies is to facilitate the use of the Internet and the communication. Cookies are stored on your PC or other devices for the anonymous tagging of the device and to support the application when you return to our website. Cookies do not contain any personal data.

If you wish, you can block the storage of cookies via your web browser entirely or be notified prior to the storage. However, please note that if you do not accept cookies, some pages might no longer be displayed correctly.
This website uses the following cookies:

  • Transient cookies
  • Persistent cookies

Transient cookies are deleted automatically when you close the browser. This especially includes session cookies. These cookies store a so-called session ID with which various requests of your browsers can be allocated to the joint session. In this way, your computer can be recognised when you return to the website. Session cookies are deleted when you log out or close the browser.

Persistent cookies are deleted automatically after a predefined period that may vary depending on the cookie. You can delete the cookies in your browser’s security settings whenever you wish.

You can configure your browser settings according to your preferences and e.g. refuse to accept some or all cookies.

More information on how cookies work is available here : http://www.allaboutcookies.org

The data of the cookies are not linked to your other data.

Server log files

The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are:
•Browser type and browser version
•Operating system used
•Referrer URL
•Host name of the accessing computer
•Time of the server request
•IP address

These data will not be combined with data from other sources. The basis for data processing is Art. 6 (1) (b) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.

Registration on this website 

You can register on our website in order to access additional functions offered here. The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration. To inform you about important changes such as those within the scope of our site or technical changes, we will use the email address specified during registration.

We will process the data provided during registration only based on your consent per Art. 6 (1)(a) DSGVO. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed. We will continue to store the data collected during registration for as long as you remain registered on our website. Statutory retention periods remain unaffected.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).

reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.

Data processing is based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam.

For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html.

4. Newsletter

Newsletter data

If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.

We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) DSGVO. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.

5. Plugins and tools

YouTube

Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

When you call up a page of our website that contains a social plugin, your browser makes a direct connection with Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. If your browser does not support web fonts, a standard font is used by your computer. Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

Google Maps

This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.
The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.

Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.com/policies/privacy/.The only

FURTHER INFORMATION

Privacy policy for customers

Who is responsible for data processing and whom can I contact in this regard?

The responsible party is:

Nordlux Vermögensmanagement S.A.
7, rue Lou Hemmer
1748 Luxembourg – Findel
Luxembourg
Tel.: +352 26198-1
e-mail: kontakt@nordlux-vm.lu
Website: www.nordlux-vm.lu

You can reach our Corporate Data Protection Officer at:

Nordlux Vermögensmanagement S.A.
Data protection officer
7, rue Lou Hemmer
1748 Luxembourg – Findel
Luxembourg
Tel.: +352 26198-1
e-mail: datenschutz@nordlux-vm.lu

Investor Protection Summary

The Luxembourg investor compensation scheme (SIIL) covers investors, physical persons and legal entities within the limits and according to the terms and conditions provided for by the law of 18 December 2015 relating to the resolution, recovery and liquidation measures of credit institutions and some investment firms, including deposit guarantee and investor compensation schemes.

The SIIL provides cover for claims resulting from a credit institution’s inability to:

1. reimburse its investors the funds due to them or belonging to them, held on their behalf and related to investment transactions, in accordance with applicable legal and contractual conditions;

or

2. return to investors the instruments belonging to them and held by them, administered or managed on their behalf and related to investment transactions, in accordance with applicable legal and contractual conditions.

Investment transactions made by the same investor are covered up to an amount equivalent to EUR 20.000, whatever their currency or location within the European Union and regardless of the number of accounts held.

In case of an investment transaction involving a joint account, the claims are distributed evenly among the investors, if no special provisions have been provided.

Investors must be compensated as soon as possible by the SIIL, and this within three months at the latest.

Disclaimer

  • The information contained on our website is taken from sources that Nordlux Vermögensmanagement S.A. considers reliable. It is continuously updated. Nevertheless, we accept no responsibility and give no guarantee as to the accuracy, completeness and timeliness of such information or its use. The same goes for any website to which a hyperlink leads and to any website of another provider connected to our website by a hyperlink. Nordlux Vermögensmanagement S.A. is not responsible for the contents of these websites.
  • The opinions and recommendations given are those of the author and do not necessarily express the opinion of Nordlux Vermögensmanagement S.A. or its associated companies. They may change at any time without prior notice.
  • The information contained on our website, as well as access to it and its use, are governed by Luxembourg law and is intended solely for interested parties who have their registered office in Luxembourg or are resident in said country. By visiting our website and using the application’s functions, persons residing abroad shall also be subject to Luxembourg law.
  • The information should not be construed as an offer or recommendation of particular investment products. It does not comprise an offer of sale to investors subject to different legal systems, especially those of the United States of America or United Kingdom. This also applies where individual issuers or securities are mentioned. It is no substitute for investor- and subject-oriented advice geared towards the individual needs of investors. Please contact your customer adviser.
  • We will do our utmost to avoid any technical disruptions. Nevertheless, Nordlux Vermögensmanagement S.A. accepts no responsibility for any irregularities, such as temporary inaccessibility, delays, interruptions, errors or harmful programs.
  • In the processing of personal data, the protection of your privacy is of utmost importance to us and, in our operating processes; we take care to respect privacy at all times. Only personal data you have specifically disclosed to us will be recorded. We treat personal data in strict confidence and will use it only in providing services on your behalf and in accordance with legal requirements in Luxembourg on data protection and banking secrecy.
  • Personal data are processed during the transfer of money. The data is processed partly by your bank, as well as by specialised companies such as SWIFT (Society for Worldwide Interbank Financial Telecommunication). Data can also be processed and transmitted by data processing centres in other European countries and in the USA. It is then subject to local law. As a result, US authorities may request access to data stored in such data centres for purposes of counter-terrorism. Each customer who instructs his bank to execute payment orders or any other operations gives implicit consent that all data elements necessary for the correct completion of transactions may be processed outside Luxembourg.
  • Please refrain from conveying legally binding notices (e.g. credit transfer orders, securities orders or other message which may be of importance to our business relationship) by e-mail. You should make such instructions uniquely by telephone, fax or in writing, as the confidential nature of data sent by e-mail cannot be guaranteed and we are not currently able to ascertain unequivocally the authenticity and origin of information transmitted in this manner.
  • All users of our website shall be personally responsible for taking all the appropriate measures to protect their data and/or software against viruses.
  • The structure and contents of our website are copyright-protected. The information contained therein may not be in any way amended, duplicated or transferred to third parties without the prior written consent of Nordlux Vermögensmanagement S.A.

Customer information on complaint management

Nordlux Vermögensmanagement S.A. assumes its responsibility vis-à-vis it customers in all seriousness as regards the provision of investment and lending services. We aim to be a reliable and sustainable business partner for our customers. Nevertheless, it cannot be excluded that errors may occur. In such cases, please do not hesitate to contact us. To ensure due diligence, transparency and objectivity when processing complaints, we have defined fixed rules. Please address all complaints in writing to:

Nordlux Vermögensmanagement S.A.
Compliance / Complaints Management
7, rue Lou Hemmer
L-1748 Luxembourg – Findel

You will either receive within ten days confirmation of receipt of your complaint, in which you can find information about who is responsible for processing it and the estimated processing time, or we will provide you with an immediate solution. If you disagree with the proposed solution or if the processing of your complaint does not meet your expectations, you have the option of contacting our Chairman of the Board directly or initiating a non-judicial procedure for the handling of complaints with the CSSF (Commission de Surveillance du Secteur Financier) – Luxembourg’s financial sector supervisory body.

For more information, please consult the home page of CSSF or the CSSF regulation below.

Regulation CSSF No. 16-07

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