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Sustainable Investment Policy

In accordance with Article 6 of the SFDR (“Sustainable Finance Disclosure Regulation”), LOGIVER currently does not incorporate ESG (Environmental, Social, and Governance) criteria in its investment policies.

Data Protection Notice

LOGIVER places great importance on the protection of your personal data.

In the context of managing and monitoring the business relationship, LOGIVER acts as the data controller and processes the personal data of the Client, including its individual representatives. The processing is carried out by LOGIVER in accordance with Regulation (EU) 2016/679 of April 27, 2016, related to the protection of individuals with regard to the processing of personal data and the free movement of such data (“GDPR”), as well as all other applicable legal standards, including the Luxembourg law of August 1, 2018, implementing the GDPR.

As the data controller, LOGIVER can be contacted for any question related to data processing at the following coordinates:

LOGIVER – F.A.O. the Data Protection Officer

Adress : 12 rue Jean Engling, App 14A, L-1466 Luxembourg

Phone : +352 26 97 60 53

Email : dpo@logiver.com

The processing that LOGIVER carries out is necessary for the provision, successful completion, and improvement of services to the Client. In relation to the business relationship, the purposes are:

  • Discretionary management of the Client’s assets,

  • Compliance with legal and regulatory obligations, particularly in terms of anti-money laundering and counter-terrorism financing and tax matters,

  • Internal monitoring and the preparation of regulatory reports to authorities,

  • Detection and prevention of fraud, business development through direct marketing actions and client events,

  • Execution and preservation of evidence concerning the Client’s financial transactions,

  • Assessment of the suitability of financial instruments subscribed by the Client,

  • Defence of LOGIVER ‘s interests in court.

Processing for these purposes is based on LOGIVER‘s compliance with its legal or regulatory obligations, the execution of a contract to which the Client is a party, or the legitimate interest of LOGIVER, as defined in the GDPR 2016/679.

LOGIVER retains personal data either for the period necessary to meet applicable legal or regulatory obligations or – for evidential purposes – until the expiry of the period during which a judicial or extrajudicial action remains possible, the longest period being considered if multiple periods run concurrently for the same data.

LOGIVER will only transfer the Client’s personal data outside the European Economic Area (“EEA”) if a legal or regulatory provision requires it.

LOGIVER will collect and process certain information to determine the Client’s profile, preferences, and constraints in the context of the contractual relationship between LOGIVER and the Client. This data will be used to statistically analyse and assess the objectives, performances, and actions of the Client to best manage the Client’s assets and interests. The Client may choose to refuse to provide such information to LOGIVER , thus preventing LOGIVER from processing and collecting such data. However, such refusal may hinder the establishment or continuation of business relations between the Client and LOGIVER Such a refusal may, at the very least, limit LOGIVER ‘s ability to provide its services to the Client in the most effective manner possible.

LOGIVER will only request information necessary to fulfil its obligations and perfect its services for the Client. Unless expressly instructed otherwise by the Client or in the case of legal obligations, LOGIVER will not disclose this information to third parties. The Client’s personal data may also be processed by third parties when this is essential to properly meet the contractual obligations binding LOGIVER and the Client.

The categories of subcontractors that may potentially access Client data are as follows: external IT services; external trustees and accountants; lawyers; notaries and other legal advisers; companies providing software or other technical or mechanical support enabling LOGIVER to provide its services and on which the Client’s data might rely.

In addition to these categories, Luxembourg or foreign public authorities (police, court, etc.) might be recipients of the Client’s data, to the extent and only if these authorities require LOGIVER to produce such data, they are competent to make such a request, and LOGIVER cannot oppose it.

The Client has certain rights concerning only the personal data that concern him. These rights are:

i.     The right to request access to his personal data;

ii.    The right to request the rectification of his personal data;

iii.   The right to request the erasure of his personal data;

iv.    The right to request the limitation of processing of his personal data and to know the impact of such limitation;

v.     The right to object to the processing of his personal data and to know the impact of such opposition;

vi.    The right to data portability;

vii.   When the processing of his data is based on his consent, the right to withdraw his consent at any time without this withdrawal affecting the legality of the prior processing;

viii.  The right to file a complaint with the competent supervisory authority. In Luxembourg, the authority in question is the National Commission for Data Protection (“CNPD”) located at 15, Boulevard du Jazz in L-4370 Belvaux.

Complaints

In accordance with CSSF Regulation No. 16-07, a complaint is a claim submitted to LOGIVER to recognize a right or remedy harm. Simple requests for information or explanations cannot be considered complaints. Any complaint must be submitted in writing in French or English and must be accompanied by supporting documents. Complaints should be addressed to:

LOGIVER – F.A.O. the Chief Compliance Officer

Adress : 12 rue Jean Engling, App 14A, L-1466 Luxembourg

Phone : +352 26 97 60 53

Email : compliance@logiver.com

The Company will send an acknowledgment of receipt to the complainant within 10 working days following the receipt of the complaint and will inform the complainant of the name of the person handling the complaint. The Company will respond within a period not exceeding one month between the date of receipt of the complaint and the date of sending the response to the complainant. If a response cannot be provided within this timeframe, the Company will inform the complainant of the reasons for the delay and specify the date on which the review of the complaint is expected.

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