Privacy policy
Prime Properties (hereinafter: “we”, “our”, or “Prime Properties”), undertakes to protect and respect your privacy.
This Privacy Policy outlines the personal data we collect or you provide to us and how we process them. 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. Legal basis
13. 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 (online contact form, registration to receive the newsletter…) or due to corresponding with us, having contacted us (by phone, post, email or other). The information you provide to us may include your name, email address, postal address, your telephone number.
– 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, and phone numbers used to call us.
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 provide information on the services we offer and which are similar to those you have already purchased or requested, to analyse your application, to optimize the content and layout of our website, to send you communications (when you are registered for this purpose on our website).
We use the information we collect 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.
4. Disclosure of your information
For the above purposes, we may share your information with our affiliates, our professional advisers (legal, registrar…), service providers, our IT service providers, entities involved directly or indirectly in the management of Prime Properties (its general managing partner, the company managing alternative investment funds), 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, if we are forced to comply with a legal obligation or to protect the rights, property or security of Prime Properties or any other person. This includes sharing information with the public authorities (judicial, police…).
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 by means of the following guarantees:
-the laws of the country to which your information is transferred provide a suitable degree of data protection (Article 45 of the GDPR); or
-transfer is governed by the provisions on data protection approved by the European Commission (Article 46.2 of the GDPR) or is subject to the EU-US Privacy Shield;
-transfer is based on binding corporate rules (Article 47 of the GDPR); an approved a code of conduct (Article 40 of the GDPR); an approved certification scheme (Article 42 of the GDPR); a trusted data transfer agreement (Article 46.3 of the GDPR); data protection clauses adopted by the Belgian data control authority (Article 46.2 of the GDPR).
6. Your rights
You have certain rights with respect to the information we hold about you, namely:
-the right to access information we hold about you, to ensure that we process your information in accordance with this policy and the law in force;
-the right, in certain circumstances, to request that the processing of your information be restricted (storage of information without using it), cease, or that your information be deleted;
-the right to request the amendment of information about you if it is inaccurate or incomplete;
-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);
-the right, at any time, to withdraw your consent to process your personal data;
-the right to receive, in certain circumstances, the personal data in our possession in a structured, commonly used machine-readable and interoperable format;
-the right to object to certain types of processing (except when such results from a legal obligation sensu lato).
However, we may retain certain information for legal or administrative purposes.
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” and include a copy of your ID or other proof of your identity, for security reasons. We will get back to you as soon as possible. Should we require more than a 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. 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.
All information you provide to us is stored on our secure servers.
8. Storage of your information
The information received or collected via our website is retained in accordance with the applicable legislation on data protection, your information will not be kept for longer than necessary to achieve the purposes set out in this Privacy Policy 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 solved 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 relation to such duty.
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.
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.
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 09/01/2018.
12. Legal basis
Regulation 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation – “GDPR” or the “Regulation”) which came into force on 25 May 2018 seeks to strengthen and improve the protection of your personal data.
13.Contact details
For all enquiries regarding this personal data protection policy, please contact 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)
