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Privacy Policy
 
Introduction
This is the privacy policy of Alessia SICAV, an undertaking for collective investment in transferable securities (UCITS) established as an investment company with variable capital (société d'investissement à capital variable; SICAV)  (Alessia). 
 
Alessia respects your privacy and is committed to ensuring that your personal information is used in accordance with current data protection legislation. 
 
This policy is structured in the following manner to aid your understanding:
• What information do we hold on you?
• How is your data collected?
• How do we use your information?
• Who do we share your information with?
• Information on transfers outside the EEA
• How long do we retain your information?
• What are your rights in relation to your information?
• Contact point in relation to this policy 
 
For the purposes of Personal Data processing Alessia identifies the following Data Subject categories:
• Investors (existing and potential) and their representatives (Investors).
• Operational contacts (Contacts) – representatives of our services providers, counterparties and suppliers
• Persons who have contacted us to file a complaint (Complainants)
• Persons who have accessed our website (Browsers) 
 
We have therefore split this privacy notice into those three categories for clarity and readability. 
You may belong to more than one category. 
 
Investors
 
What information do we hold on you? 
We collect your name, role, firm name, email address, telephone number, business address, your MiFID classification and investments in Alessia shares. 
 
How is your data collected? 
We register your details whenever you express interest in our products and/or our company. 
 
How do we use your information?
Processing for the purpose of providing services: 
 
We process your data, relying on the "legitimate interest ground". Alessia’s legitimate business interest, and purpose of our processing of your data, is providing you with the necessary information to analyse actual or potential investments in one or more of the Alessia sub-funds. 
 
When you receive newsletters or promotional email from Alessia, we may use personalized unique links or similar technologies to determine whether the email has been opened and which links you click. This enables us to provide you with email communications or other information that are more targeted to your needs. We will rely on our legitimate interests to do this, meaning the provision of electronic direct marketing of our data, services and products, unless legislation requires us to obtain your consent, in which case we will request this from you. 
 
Who do we share your information with? 
We process your data using cloud hosting providers in the EU.  We may share your data with any government, regulatory authority or court if deem this necessary or appropriate. 
 
Contacts
What information do we hold on you? 
We collect your name, role, firm name, email address, telephone number and business address. 
 
How is your data collected? 
If your firm has entered into a business relationship with us, whether as service provider, counterparty or supplier, we will collect your name, firm name, business address and other contact details. 
 
How do we use your information?
Processing for the purpose of providing services: 
We process your data, relying on the "legitimate interest ground". Alessia’s legitimate business interest, and purpose of our processing of your data, is maintaining the business relationship, contact you on behalf of your organization in order to query, develop or otherwise in connection with the actual or possible services provided by your organization, discuss possible transactions with your organization and contact you in connection with the same and account any transaction or business relationship. 
 
Who do we share your information with? 
We process your data using cloud hosting providers in the EU. We will share your contact details with our service providers, if we deem this necessary or appropriate in order to settle or account any transaction or relationship, and/or any government, regulatory authority or court if deem this necessary or appropriate. 
 
Complainants
What information do we hold on you? 
We collect your name, date and place of birth, Tax ID, investments in Alessia, role, firm name, email address, telephone number and business address, bank account details, and any information relating to your complaint and the resolution thereof. 
 
How is your data collected? 
If you, your firm or your client has filed a complaint, we will collect the necessary information to contact you, investigate and resolve the complaint 
 
How do we use your information?
Processing for the purpose of providing services: 
We process your data, relying on the "legitimate interest ground". Alessia’s legitimate business interest, and purpose of our processing of your data, is investigating your complaint and contacting you or your representative in order to discuss a mutually acceptable solution if Alessia deems the complaint valid.  
 
Who do we share your information with? 
We process your data using cloud hosting providers in the EU. We will share your contact details with our service providers, if we deem this necessary or appropriate in order to settle or account any transaction and/or any government, regulatory authority or court if deem this necessary or appropriate. 
 
Browsers
What information do we hold on you? 
We log your IP address and the pages you have viewed. 
 
How is your data collected? 
If you accessed our website, our systems will collect your IP address for services you have used and pages you have visited. We will also collect details on the device you used to connect, such as operating system, geographic location, browser type and language, access times and referring website addresses. 
 
How do we use your information?
Processing for the purpose of providing services: 
We process your data, relying on the "legitimate interest ground". Logs of page views and interaction with our web product are maintained to help us to provide you with a more personalized user experience in relation to the provision of services to you, and develop our website and product offering to you. 
Who do we share your information with? 
We process your data using cloud hosting providers in the EU and the US (see below).  
 
Transfers outside the EEA Browsers 
We partner with companies who analyse how our Browsers navigate and use our website. These companies operate in the US and appropriate data protection is covered by their EU Privacy Shield certification. 
 
What are your rights in relation to our use of your information? 
You have rights under data protection law in relation to our use of your information, including to: 
 
a. request access to your information, which you can do by emailing compliance@alessia.lu stating you are submitting a Data Access Request;
 
b. update or amend your information if it is inaccurate or incomplete by emailing compliance@alessia.lu requesting an update;
 
c. object to certain uses of your personal data (which includes direct marketing and processing based on legitimate interests and processing for purposes of scientific or historical research and statistics) on grounds relating to your particular situation by emailing compliance@alessia.lu stating that you are submitting a Data Objection Notice;
 
d. request the deletion of your information, or restrict its use, in certain circumstances (for example you can request that we erase your information where the information is no longer necessary for the purpose for which it was collected, unless certain exceptions apply) by emailing compliance@alessia.lu stating that you are submitting a Data Deletion Request;
 
e. withdraw any consents you have provided in respect of our use of your information either by  emailing compliance@alessia.lu stating that you are submitting a Data Consent Withdrawal;
 
f. request the return of information you have provided to us, to use for your own purposes (often called your right to data portability) where the processing is based on your consent or  a contract, and the processing is, by emailing compliance@alessia.lu;
 
g. lodge a complaint with the Information Commissioner's Office (https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html) or other authority that has jurisdiction.
 
We may need to ask you for further information and identification to help us to comply with this request. More information about these rights can be found at www.cnpd.lu. If you have any questions about these rights, or you would like to exercise any of them, please contact us at compliance@alessia.lu
 
How long do we retain your data? Contact details of Investors, Contact and Browsers are stored for varying lengths depending on the nature and purpose for which it was collected. Alessia will review your personal data periodically to ensure it is still necessary to be retained for the purpose for which it was collected. 
 
Do we use cookies? 
Yes (cookies are small files that a site or its service provider transfers to your computers hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. 
 
We use cookies to help us understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. 
 
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. We use third party vendors, including Google, to show our ads on other websites on the internet. Some of these third party vendors, including Google, use anonymous cookies to serve ads based on a user’s prior visits to our website. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page. 
 
How to contact us
If you have any questions regarding this policy, please email compliance@alessia.lu. 
 
Changes to this policy 
We keep this privacy notice under regular review and we will place any updates on this webpage. We will inform you of any material changes to the privacy notice. This privacy notice was last updated on May 28th, 2018. 
Alessia SICAV - The Absolute Return Company - VAT LU22621162 - R.C.S. Luxembourg N.B137597 - Legal notices - Regulatory Information - Privacy and cookies
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