As part of our ongoing commitment to data protection and transparency, Lemanik Asset Management S.A. and all Lemanik European branches (together “Lemanik”) addressed the new standards introduced by the General Data Protection Regulation (GDPR) in this Privacy Policy.
In this Privacy Policy, we cover the nature of the personal data that is collected and stored by us, the purpose and the legal basis for processing your data, the data sharing, the data retention and your rights with regards to your data as data subject.
In the context of our service offering, Lemanik mainly acts as data processor for the personal data we process on behalf of our clients (e.g. investment funds).
Nevertheless, in line with this Privacy Policy, Lemanik acts as a data controller for the personal data we process for our own purposes such as described below.
PERSONAL DATA
In accordance with the GDPR definitions, when we refer to “personal data” we mean any data that could identify an individual, directly or indirectly, in particular, by reference to an identifier such as a name, ID number, location data, signature or online identifier.
Lemanik collects personal data and will act as the data controller of this data if you:
1. Collection of personal data
We collect your personal data during the course of your business relationship with us. For example, when you engage with us in respect of a new relationship/prospective relationship, you will communicate with your contacts within Lemanik.
We may also receive data about you from other sources, such as directly from your organization or via other publicly available sources.
We combine data about you from various sources, including the data that you have provided to us directly.
Lemanik only collects data that is necessary to fulfil the purpose behind our relationship with you. We won't collect data we don't need. Personal data we collect fall within one or more of the below categories:
2. How we use your personal data
We will only process your personal data on the basis allowed in the GDPR, for the purposes below, and we will limit the use of sensitive data which have special legal protection.
3. Legal basis for processing your data
We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do so.
Such legal basis may be one of the following:
DATA SHARING AND TRANSFERRING PERSONAL DATA GLOBALLY
Lemanik may share your data to manage our business and deliver services and/or to comply with applicable laws, regulations and rules.
Lemanik may transfer your personal data with:
Should your personal data be processed in countries outside the EU or in countries not providing an adequate level of data protection, Lemanik will take appropriate steps to ensure that such processing will be executed in accordance with the below:
DATA RETENTION
We will store your personal data for as long as it is necessary for the purposes for which it was collected, as explained in this Privacy Policy and in accordance with the GDPR.
DIRECT MARKETING
We may use personal data to let you know about Lemanik products and/or services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing communications with you.
YOUR RIGHTS AS A DATA SUBJECT
You have a number of legal rights in relation to the personal data that we hold about you and you can exercise your rights by contacting us using the details at the back of this document. These rights include:
Please note that these rights are subject to certain conditions like legal obligations, retention period requirements especially where you ask us to restrict the use of your personal data or the erasure of such data.
Any complaint can be logged with the applicable data protection regulator.
As regards to this Privacy Policy, there is no need for you to take any action.
Should you have any question on the aforementioned or should you want to exercise one of the above rights, please contact: [email protected].
To better enjoy this experience
please rotate your device