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Privacy policy

Prime Properties SCA SICAV-SIF (hereinafter: “we”, “our”, “us” or “Prime Properties”), undertakes to protect and respect your privacy.
This privacy policy (the “Privacy Policy”) outlines the personal data (“information”) we collect or you provide to us and how we process personal data. By using this website, you accept the practices outlined in this Privacy Policy.

Table of contents:
1. Information collected;
2. Cookies;
3. Use of your information
4. Disclosure of your information
5. Transfer of your information
6. Your rights
7. Security of the information collected
8. Storage of your information
9. External websites
10. Consent to the collection and use of your information
11. Changes to our Privacy Policy;
12. Contact details.


1.The information collected

We collect and process the following data:

  • Information you provide to us: This is information that you provide to us by filling in forms on this website (such as an online contact form or registration to receive the newsletter) or due to corresponding with us, or having contacted us (by phone, post, email or other method). The information you provide to us may include your name, email address, postal address, your telephone number.
  • Other information you provide to us: such as through subscription documents and other onboarding documents (that may include tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you send us in connection with an investment or potential investment in Prime Properties.
  • The information we collect about you when you visit this website, namely technical information (IP address used to connect your computer to the internet, type of browser and version, time setting, type and versions of browser plug-ins, operating system and platform), information about your visit, including uniform resource locators (URLs), the clickstream to, through and from our website (including date and time); the products/services viewed or searched; page response time, errors in downloading, length of visits to certain pages, information on interactions with the page (such as scrolling, clicks, mouse movements), and the methods used to exit the page.

 


2.Cookies
Our website uses cookies. They allow us to provide a good experience when you browse our website and to make changes thereto.

 

3. Use of your information
We use the information you supply to us to provide you with the information and services you have requested, to answer any questions you have posed, to analyse your application, to send you communications (when you are eligible to receive it and registered for this purpose on our website).
Information may be provided in order to carry out our obligations arising from any contracts entered into with us, to comply with applicable laws and regulation, verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for our products or services. If you choose not to provide us with certain information, we may not be able to offer you certain of our products and services or may be required to cease offering you certain products or services. We will also use your information for legitimate interest reasons such as to manage our website and to carry out internal operations such as troubleshooting, data analysis, research, statistics, to optimize the content and layout of our website, especially in accordance with the medium you use to view it, to allow you to participate in interactive features of our service, if any and when you choose to do so, and to ensure the security and stability of our website. Additionally, to provide you with information on the services we offer and which are similar to those you have already purchased or requested.

 

4. Disclosure of your information
For the above purposes, we may share your information with our affiliates, our professional advisers, service providers, IT service providers, entities involved directly or indirectly in the management of Prime Properties (such as its general partner Prime Properties Management S.A., its alternative investment fund manager, Funds Avenue S.A., shares register holder), and providers of analyses and search engines that help us to improve and optimize our site.
We will also disclose information to third parties when necessary or useful for achieving one of the purposes set out in Section 3 of this Privacy Policy. Information will also be disclosed if we are under a legal obligation to do so or to protect the rights, property or security of Prime Properties or any other person. This includes sharing information with public authorities (such as judicial or law enforcement bodies).

 

5. Transfer of your information
We may transfer your information outside the European Economic Area (“EEA”), if necessary: (i) to achieve one of the purposes set out in Section 3 and/or (ii) to disclose your information to third parties in accordance with Section 4 of this policy.
If your information is transferred outside the EEA, we will ensure that it is protected such as by means of one of the following guarantees:

  • the laws of the country to which your information is transferred provide a suitable degree of data protection as approved by the European Commission by way of adequacy decision; or
  • transfer is governed by the provisions on data protection approved by the European Commission, such as standard contractual clauses.


6. Your rights
You have certain rights with respect to the information we hold about you. To the extent permitted by law, you may have the following rights in relation to the processing of your information:

  • Access. To request a copy of the information we process in relation to you as well as transfer your information and to be informed about how we use and share your personal information.
  • Object. To object to the processing of your information if (i) we are processing your information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your information for direct marketing purposes.
  • Correction. To request that we update the information we process in relation to you, or to correct information that you think is incorrect or incomplete.
  • Erasure. To ask that we delete information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
  • Restriction. To request that we restrict the way in which we process your information, for example, if you dispute the accuracy of your information or have raised an objection which is under consideration.
  • Portability. To request a copy of your information that you have provided to us in a commonly used electronic format.
  • Automated decision making. To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar significant effect to you.
  • Complain: The right to lodge a complaint about the way in which we process your information with the National Commission for Data Protection (1, avenue du Rock’n Roll, L-4361 Esch-sur Alzette, www.cnpd.public.lu).

For all requests relating to the exercise of your rights regarding personal data protection, please send an email indicating in the subject “Request concerning data protection”. We may need to request specific information from you to help us confirm your identity and ensure your right to access to the information requested, or to exercise any of your other rights. This is to ensure that information is not disclosed to any person who does not have authority to receive it. We may also request further details and information in relation to your request to help us to locate the information processed in relation to you, including, for example, the nature and location of your relationship with us. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
Should we require more than one month (from the receipt of your request) to respond to your request, we will duly inform you.


7. Security of the information collected
We have implemented a number of security measures to prevent the disclosure of or unauthorized access to the information collected and/or received on our website.
We maintain administrative, technical, organisational and physical safeguards which are designed to protect the information we obtain against unauthorized or unlawful use, disclosure, access, loss, destruction or damage. These measures include storage of all information on our secure servers with limitation of access to those who require access to information.
When considering the safeguards which we utilise a risk-based assessment considering the following factors is undertaken:

  • the state of the art of commercial available technology;
  • the cost of implementation;
  • the nature, scope, context and purpose of processing; and
  • the severity and likelihood of the risks.

However, the confidentiality of any communication or other material that is conveyed to us or that we convey to third parties via our website or by email cannot be guaranteed. We shall not be held liable for the security of information conveyed via these means.

 

8. Storage of your information
The information received or collected via our website is retained in accordance with the applicable legal requirements with respect to data protection, your information will not be kept for longer than necessary to achieve the purposes set out in this Privacy Policy or otherwise disclosed to you unless the processing of such data is required as part of a pre-litigation, litigation or dispute, in which case we will keep your data until the situation is finally resolved or if storage is required for our compliance with any legal or regulatory duty, the information will be kept for as long as necessary in in order to comply with such duty.
To determine the appropriate retention period for information, we consider the amount, nature, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

9. External websites
Our website may occasionally contain links to or from other websites. Links to such third party websites are provided for information purposes only. If you follow one of these links, they have their own policies on data protection. They are, therefore, not subject to this Policy and we shall not be held liable for such policies. If you decide to visit one of these sites, you do so at your own risk and Prime Properties cannot be held liable therefor.
Any reference to a website, products or services of third parties is provided solely for information purposes and does not constitute an endorsement or recommendation by Prime Properties of such sites, products or services.
Prime Properties has no influence, has not approved or examined the content of any possible third party website referring to this website, and hence Prime Properties shall not be held liable for such third party website.


10. Consent to the collection and use of your information
By using this website, you acknowledge that you have read the terms and conditions applicable to this online Privacy Policy and agree to the collection and use of your information as stipulated above. You may withdraw any consent you previously provided to us or object at any time to the processing of your information.


11. Changes to our Privacy Policy
We may amend this Privacy Policy. Any changes to this online Privacy Policy will be published on this website. The continued use of this website, following the publication of changes to this Privacy Policy, implies your acceptance of such changes. This online Privacy Policy was last updated on 08-08-2025.


12.Contact details
For all enquiries regarding this personal data protection policy, please contact the controller, Prime Properties by email at info@primeproperties.lu or by post to the following address: Prime Properties SCA SICAV-SIF, 2 rue Eugène Ruppert à L-2453 Luxembourg. Officer: Arnaud Schreiber (a.schreiber@primeproperties.lu). Prime Properties is registered with the Luxembourg Business Register (registre du commerce et des sociétés) under the number B209465. The Fund is authorised by the Commission de Surveillance du Secteur Financier (the “CSSF”) as a specialised investment fund (Fonds d’Investissement Spécialisé).