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 : 30 Boulevard Joseph II, L-1840 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 or the explicit consent of the Client as defined in the GDPR. LOGIVER does not engage in processing activities involving sensitive data within the meaning of Article 9 GDPR, while personal data relating to criminal convictions, offences, or related security measures within the meaning of Article 10 GDPR are processed only for the purposes of anti-money laundering, counter-terrorist financing, and fraud prevention, with the safeguards provided by the applicable sector-specific legislation.

LOGIVER retains personal data either only 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.

Generally, LOGIVER processes your personal data within the European Economic Area (EEA) and does not transfer it outside the EEA on a regular basis in the context of the services provided to you. Where, exceptionally, personal data are transferred to a country outside the EEA, LOGIVER ensures that appropriate safeguards within the meaning of Chapter V GDPR are in place.

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.

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.

LOGIVER does not carry out any automated decision-making currently. Should this change in the future, our privacy notice will be systematically updated to reflect any new practices, and the safeguards implemented.         

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. Right not to be subject to a decision based solely on automated processing – to the extent such processing will be put in place.
ix.   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. The client also has the right to lodge a complaint to any other data protection competent supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

For further information, please refer to the Client Data Privacy Notice, which was updated in May 2026 and is available at www.logiver.com/data-protection

 

Complaints Handling

In accordance with CSSF Regulation No. 16-07 relating to the out-of-court resolution of complaints, a complaint is a claim lodged with LOGIVER S.A. with a view to having a right recognised or harm redressed. Requests for information, clarification or explanation are not treated as complaints. Submitting a complaint to LOGIVER S.A. is free of charge.

 

How to submit a complaint

You may submit a complaint by any means, although we recommend that you do so in writing, in either French or English, accompanied by any relevant supporting documentation. So that we can handle your complaint efficiently, please provide:

  • your identity and contact details, and, for legal persons, the details of the representative submitting the complaint;
  • the reference of the account, product or service concerned;
  • a chronological description of the facts giving rise to the complaint, with the relevant dates;
  • the outcome or redress you are seeking;
  • copies of any supporting documentation.
Complaints should be addressed to:

LOGIVER S.A

For the attention of the Chief Compliance Officer, responsible for the handling of complaints

Adress : 30 Boulevard Joseph II, L-1840 Luxembourg

Phone : +352 26 97 60 53

Email : reclamations@logiver.com

 

How your compliant will be handled

LOGIVER S.A. will acknowledge receipt of your complaint within ten (10) business days of receiving it, unless a substantive response is provided within that period. You will also be informed of the name and contact details of the person responsible for handling your complaint.

 

LOGIVER S.A. will examine your complaint fairly, diligently and without undue delay and will provide you with a response no later than one (1) month from the date of receipt of your complaint. Where a final response cannot be provided within this period, you will be informed of the reasons for the delay and of the date by which the examination of your complaint is expected to be completed.

 

Where our response does not meet your expectations, we will set out our position on your complaint in full, together with the reasons for it, and we will inform you in writing or on another durable medium of your right to refer the matter to the CSSF.

 

Referral to the CSSF

LOGIVER S.A. adheres to the out-of-court complaint resolution procedure operated by the Commission de Surveillance du Secteur Financier (CSSF).

 

A complaint may be submitted to the CSSF only after you have first attempted to resolve the matter directly with LOGIVER S.A.

 

If you have not received a response, or a satisfactory response, within one (1) month from the date on which you sent your complaint to the Chief Compliance Officer, responsible for the handling of complaints, you may file a request for the out-of-court resolution of your complaint with the CSSF.

 

The request should be filed in Luxembourgish, German, English or French. It must be filed with the CSSF within one (1) year from the date on which you filed your complaint with LOGIVER S.A., and is subject to the admissibility conditions laid down in CSSF Regulation No. 16-07. The procedure before the CSSF is free of charge and its conclusions are not binding on the parties. You retain at all times the right to bring the matter before the courts.

 

Requests may be filed with the CSSF:

 

 

Further information on the procedure, together with a copy of CSSF Regulation No. 16-07, is available on the CSSF website at https://www.cssf.lu/en/customer-complaints/.

 

Complaints management policy

LOGIVER S.A. maintains a written complaints management policy, endorsed by its management, which sets out the internal organisation and procedure for handling complaints. A summary of this policy is available free of charge on request from the contact details above.

 

Personal data

Any personal data processed in connection with your complaint will be handled in accordance with applicable data protection legislation and LOGIVER S.A.’s Privacy Notice.