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SOCIETE PRIVEE D'INVESTISSEMENT SA privacy policy

To obtain information about your personal data collected, the purposes and subjects with which the data is shared, contact the controller.

Data controller

SOCIETE PRIVEE D'INVESTISSEMENT SA .

Owner contact email: spi@spi-sa.eu

Types of data collected

The controller does not provide a list of the types of personal data collected.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to data collection.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically while using this Application.
Unless otherwise specified, all data required by this application is mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating this Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about the required data are encouraged to contact the owner.

Any use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described. in this document and in the cookie policy, if available.

The user assumes responsibility for the personal data of third parties obtained, published or shared through this application and guarantees to have the right to communicate or disseminate them, freeing the owner from any liability towards third parties.

Method and place of processing of the data collected

Processing methods

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and / or telematic tools, with organizational methods and with a logic strictly related to the purposes indicated. In addition to the controller, in some cases other subjects involved in the organization of this application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal mail) may have access to the Data (hosting providers, IT companies, communication agencies) also designated, where applicable, as Subcontractors by the Data Controller. The updated list of managers can always be requested from the controller.

Legal basis for processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given his consent for one or more specific purposes; Note: in some jurisdictions, the controller may be authorized to process personal data without the user's consent or another of the legal bases specified below, as long as the user does not object ("opt- out ") to such processing. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;

the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;

the processing is necessary to fulfill a legal obligation to which the controller is subject;

the processing is necessary for the performance of a task of public interest or for the exercise of official authority vested in the controller;

processing is necessary for the pursuit of the legitimate interest of the controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on the law, provided for by a contract or necessary for the conclusion of a contract.

Place

The Data are processed in the operational offices of the Data Controller and in any other place where the parties involved in the processing are located. For more information, please contact the controller.
The User's Personal Data may be transferred to a country other than that in which the User is located. For more information on the place of processing, the User can refer to the section relating to the details of the processing of Personal Data.

The User has the right to obtain information on the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or composed of two or more countries, such as the United Nations, as well as on the security measures adopted by the controller to protect the data.
The User can check whether one of the transfers described above takes place by examining the section of this document relating to details on the processing of Personal Data or request information from the Data Controller by contacting him at the opening contact details.

The duration of the conversation

The Data are processed and stored for the time necessary for the purposes for which they were collected.

So:

Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be kept until the end of the execution of this contract.

Personal data collected for purposes related to the legitimate interest of the data controller will be kept until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the user's consent, the controller may keep the personal data longer until this consent is revoked. In addition, the controller may be obliged to keep personal data for a longer period in accordance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Consequently, at the end of this period, the right of access, deletion, rectification and the right to data portability can no longer be exercised.

User rights

Users can exercise certain rights with reference to the data processed by the controller.

In particular, the User has the right to:

withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed.

oppose the processing of their data The user can oppose the processing of their data when it intervenes on a legal basis other than consent. Further details on the right to object are given in the section below.

access their data.The user has the right to obtain information on the data processed by the controller, on certain aspects of the processing and to receive a copy of the processed data.

verify and request rectification. The User can check the accuracy of his Data and request its update or correction.

obtain restriction of processing. When certain conditions are met, the User may request the limitation of the processing of his Data. In this case, the Data Controller will only process the Data for purposes other than their storage.

obtain the cancellation or deletion of their Personal Data. When certain conditions are met, the User can request the cancellation of his Data by the Owner.

receive their data or have it transferred to another owner. The user has the right to receive their data in a structured format, commonly used and readable by an automatic device and, where technically possible, to obtain their unimpeded transfer to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures related to it.

propose a complaint. The User can lodge a complaint with the competent supervisory authority in matters of personal data protection or initiate legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public authority vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for related reasons. to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they can oppose the processing without having to justify reasons. To find out whether the Data Controller is processing data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the User's rights, Users can send a request to the Owner's contact details indicated in this document. Requests are filed free of charge and processed by the controller as soon as possible, in any case within one month.

Cookie policy

This app uses tracking tools. To find out more, the User can consult the Cookie Policy.

More information about the treatment

Defense in court

The user's personal data may be used by the owner in court or in the preparatory steps for its possible establishment for the defense against abuse in the use of this application or related services by the user.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of public authorities.

Specific information

At the request of the user, in addition to the information contained in this privacy policy, this application may provide the user with additional and contextual information regarding specific services, or the collection and processing of personal data.

System log and maintenance

For purposes related to operation and maintenance, this Application and any third-party services it uses may collect system logs, which are files that record interactions and which may also contain Personal Data, such as User's IP address.

Information not contained in this policy

Further information regarding the processing of personal data may be requested at any time from the controller using the contact details.

Response to "Do Not Track" requests

This app does not support "Do Not Track" requests.
To find out whether the third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The controller reserves the right to make changes to this privacy policy at any time by informing users on this page and, if possible, on this application as well as, if technically and legally possible, by sending a notifying users through one of the contact extremes it has. Please consult this page frequently, referring to the date of the last modification indicated at the bottom.
If the changes affect processing operations whose legal basis is consent, the controller will collect the user's consent again, if necessary.

SPI SA

Societe Privée d'Investissement SA

65, Boulevard de la Pétrusse

L-2320 Luxembourg

Phone: (+352) 28 55 32 24
Email: spi@spi-sa.eu

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