Privacy Policy and Protection of Personal Data

This policy aims to describe the conditions under which CA Indosuez Fund Solutions, 12 rue Eugène Ruppert, L-2453 Luxembourg (hereinafter referred to as “CAIFS”) collects and processes, in the context of its activities, the personal data of any concerned person, particularly its clients and users of this website.

Personal Data

As part of its activities, CAIFS processes, either automatically or otherwise, the personal data of individuals: existing and potential clients, users of this website (when they fill out online forms provided), and any other individual (such as authorized representatives, executives), all of these individuals hereinafter individually referred to as the “Concerned Person.” The personal data concerning the Concerned Persons that CAIFS collects or processes, in its capacity as data controller, are necessary to meet its legal or regulatory obligations, to allow the execution of pre-contractual measures or contracts to which the Concerned Person is a party, and/or to pursue the legitimate interests of CAIFS, while respecting the rights of the Concerned Person. When collected for other purposes, CAIFS first obtains the consent of the Concerned Person. For Concerned Persons who are clients, CAIFS uses their personal data to offer personalized advice and offers, provide better quality service, and help them make the best decisions. If certain information necessary to provide a service is missing, CAIFS will not be able to provide that service.

Purposes of Personal Data Processing

The personal data of Concerned Persons may be processed mainly for the following purposes:

1. Relationship initiation and management of the relationship and account

  • Prospecting and relationship animation
  • Relationship initiation and commercial relationship management

2. Product and service offering and management

  • Structuring / Legal services
  • Domiciliation and General Secretariat
  • Central administration o Registration, supervision of the distribution network
  • UCITS & AIFM management company: risk management, compliance, and governance
  • Advisor model
  • Depositary and custodian services for investment funds

3. Logistic management

  • Safety and security of property and individuals
  • Mail and archives management

4. Compliance with legal and regulatory obligations

  • With external authorities
  • In response to internal control obligations

Retention of Personal Data

These data are processed and stored for the duration necessary to achieve the pursued purposes and, at most, for the duration of the contractual or business relationship, extended by the time required for liquidation and consolidation of rights, prescription periods, and exhaustion of remedies. CAIFS may archive these data to meet its legal obligations, requests from regulators and administrative authorities, as well as for historical, statistical, or scientific research purposes.

Rights of the Concerned Person

The Concerned Person has the following rights, in accordance with applicable regulations:

  • Right to access their personal data
  • Right to rectify inaccurate or incomplete data
  • Right to object to the processing of their data for legitimate reasons
  • Right to request the erasure of their data when they are no longer necessary for the purposes for which they were collected or processed, or when the Concerned Person withdraws their consent
  • Right to request the restriction of the processing of their data
  • Right to request the portability of data in digital format

The Concerned Person can object at any time and without justification to the use of their data for commercial prospecting purposes, including profiling, or withdraw their consent by writing to CAIFS. Postage costs will be reimbursed upon simple request.

Data Protection Officer (DPO)

CAIFS has designated a Data Protection Officer, whom the Concerned Person can contact at the following address: dpo@ca-indosuez.lu or at our postal address CA Indosuez Fund Solutions, 12 rue Eugène Ruppert, L-2453 Luxembourg. The DPO can provide detailed information on the rights of the Concerned Person and the use of their data.

Complaints to Authorities

In case of dispute, the Concerned Person can file a complaint with the CNPD. Contact details are available on the website accessible via the following link: www.cnpd.lu

Transfer of Personal Data

Data may be transferred to a member country or a non-member country of the European Union. In the context of a transfer to a non-member country of the European Union not benefiting from an adequacy decision, guarantees ensuring the protection and security of data are implemented.

Professional Secrecy

Operations and data of Concerned Persons are covered by professional secrecy. CAIFS may be required to communicate information to legally authorized judicial or administrative authorities. The Concerned Person authorizes CAIFS to share their data with certain third parties, such as mediators, legal auxiliaries, Crédit Agricole Group companies, and CAIFS subcontractors.