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Data Protection

Innpact S.A. is a public liability company incorporated under the laws of the Grand Duchy of Luxembourg, having its registered address at 5, rue Jean Bertels, L-1230 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg trade and companies register (registre de commerce et des sociétés) under number B 134935 (“Innpact S.A”), with VAT number LU 32529185.

Innpact Fund Management S.A., a public limited liability company incorporated under the laws of the Grand Duchy of Luxembourg, having its registered address at 5, rue Jean Bertels, L-1230 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg trade and companies register (registre de commerce et des sociétés) under number B 238136, with VAT number LU 3165 4359 (“Innpact AIFM”).

The website www.innpact.com is operated and controlled by Innpact S.A.

The website www.innpactfundmanagement.com (the “Website”) is jointly controlled by Innpact S.A. and Innpact AIFM.

Innpact S.A. and Innpact AIFM are jointly referred to as “Innpact”, and each individually as “the relevant Innpact entity”.

www.innpact.com and www.innpactfundmanagement.com are jointly referred to as the “Websites” and each individually referred to as the Relevant Website.

Agreement to Terms and Conditions of Use of this Website

By accessing these Websites, you agree to use the Websites only for lawful purposes and to be bound by the terms and conditions for use of these Websites as set out hereunder, which may be amended from time to time by the relevant Innpact entity without notice. The terms and conditions hereunder are subject to the laws of the Grand Duchy of Luxembourg and the exclusive jurisdiction of the Tribunal d’Arrondissement of Luxembourg city.

No Reliance and Limitations of Liability

The information on these Websites are provided by the relevant Innpact entity their affiliates (hereinafter referred to us  “we” or “us”) for informational purposes only and on an “as is” and “as available” basis, without any express or implied warranties as to the accuracy or completeness of the information provided and which may be changed by the relevant Innpact entity without notice. The information contained on these Websites should not be considered as an offer or solicitation, to deal in any of the investments or funds mentioned herein. Nothing contained in the information on these Websites constitutes legal, tax, investment or other advice, nor to be relied upon in making any decision.

You are encouraged to confirm the information contained herein, and you should not construe any information herein as a warranty or guarantee of the quality or availability of services or financial products. Any reliance on information provided on these Websites is at your own risk and in no event will Innpact or its service providers be liable for any loss or damage of any kind arising out of or in connection with your access, use, or browsing of these Website.

Any links to other websites or to materials provided by other parties are provided by us for your convenience only and do not imply endorsement of such websites or materials by us. These sites and materials are not owned by or under the control of Innpact, and Innpact disclaims all liability with regard to your access to and use of such linked websites or materials from other parties.

Copyright

The contents of these Websites are protected by copyright and may not be downloaded, extracted, reproduced, distributed, transmitted, or published, in whole or in part, for public or commercial purposes without Innpact’s prior written consent, or in case of third-party materials, the owner of that content. You may not alter or remove any logo, trademark, copyright or other notice from copies of content on these Websites.

You may review, download, save, and/or print out a hard copy of individual pages and/or sections of these Websites for your personal, non-commercial, non-political use.

You agree not to license, distribute, create derivative works from, transfer, sell or re-sell any content obtained from these Websites, nor to modify, deface content on these Websites, or reproduce content on these Websites separate and out of context from the original accompanying materials. You are not permitted to use the materials on these Websites except as expressly set forth herein.

Cookies

Please be informed that these Websites use cookies and third-party cookies from Google Analytics, which are small data files that are downloaded onto your computer, to help us understand how these Websites are used and how we can improve these Websites. For instance, these cookies may track and provide us with statistics regarding which pages are visited, which articles are downloaded, the length of time spent per user on these Websites etc.

If you do not wish to accept these cookies onto your computer, you can disable cookies via the setting on your browser.

Privacy Policy

Innpact understands the importance of keeping your personal data safe. The privacy policy of each Innpact entity (each a “Policy“) sets out what data we collect from clients and any further data collected in the course of the business relationship and why, how it is stored, processed and what your rights are in relation to this data. In case of any questions about this Policy or your data rights, please contact us by using the contact form, or alternatively:

Postal and visitor’s address:

Innpact S.A.

5, rue Jean Bertels

L-1230 Luxembourg

Grand Duchy of Luxembourg

E-mail: info@innpact.com

 

Innpact Fund Management S.A

5, rue Jean Bertels

L-1230 Luxembourg

Grand Duchy of Luxembourg

E-mail: info@innpactfundmanagement.com

 

1. Data categories and sources of data

The main categories of personal data processed by the relevant Innpact entity, are (inter alia):

•             Personal identification data, such as name, date of birth and contact details, bank account information, social security number, travel ID, CVs,

•             IP addresses or other visitor origin profiles maybe traceable from visiting our website or social media profiles

•             Profile pictures, pictures from events and videos

2. Lawful basis and purpose of the processing

Any personal data provided to us is processed based on the legal grounds enumerated in Art. 6, Par. 1 of the GDPR. Most of our data processing arises from regulatory or contractual requirements, without which we would not be able to provide the contracted services or be in compliance with applicable laws. Certain data, such as business cards and photographs we may have of you from events, is processed based on consent or legitimate interest. For the processing of data that are not central to our contractual or regulatory obligations, you have the right to withdraw your consent and request that we stop processing and to delete such data at any time.

3. Profiling and automated decision-making

Innpact does not use data profiling or automated decision-making as per Art. 22 and recital 71.

4. Third-party data processing

Innpact’s data systems are maintained and backed-up by an external IT service provider which is also located in Luxembourg and is complying with GDPR requirements.

In order to fulfil our obligations arising from contract or applicable laws, certain personal data may be transmitted to other service providers or regulatory authorities.

Due diligence is performed on such third parties to ensure that they are complying with GDPR.

Innpact shall be held liable for any kind of technical incidents that may occur during electronic transmission (including infection by virus, worm, etc.)

5. Transfer to third countries

To the extent practicable, Innpact avoids transferring your data to non-EU countries or to countries without EU equivalent data protection. To the extent required for the working relationships between service providers and between us and our clients, some data may be transferred outside of the EU, such as to affiliates of service providers or providers of IT cloud solutions. In such cases, prior due diligence is performed to ensure that service providers only transfer data to their affiliates which are compliant with GDPR and that the IT cloud solutions chosen have implemented GDPR compliant security measures.

The commitments relating to the protection of personal data herein shall apply mutadis mutandis to all data processors identified by Innpact.

6. Provision of data

Personal data relating to directors and officers must be provided in order to enable Innpact to perform its services.

Certain data relating to representatives of investors and contractual counterparties are also required to be provided to enable effective notification to the respective parties.

7. Storage of personal data

Any and all personal data will not be retained for longer than necessary in order to fulfil our obligations arising from contract or applicable laws.

For those data processes which are not strictly necessary for the fulfilment of our obligations arising from contract or applicable laws, you have the right to object to the processing and storage of your data and the right to request for your data to be securely deleted.

8. Your rights as a data subject

Please find below an outline of the most pertinent rights you have as data subjects vis-à-vis Innpact. The exhaustive list of your rights as data subject can be found in Art.15-22 and Art. 77 of the GDPR.

  • Right to access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17+19 GDPR)

You have the right to see what personal data we have of you in our files.

If you spot an error in your personal data in our files, or that it is no longer up to date, you have the right to request that it is rectified.

Any of your personal data we have in our files will be deleted upon request, unless Innpact has an overriding obligation to maintain the data such as arising from contract or applicable laws.

  • Right to restriction of processing (Art. 18+19 GDPR)

We will limit the ways and purposes your personal data is processed upon request, unless there are overriding obligations arising out of contract or applicable laws.

  • Right to data portability (Art. 20 GDPR)

You have the right to request that your personal data is transferred from Innpact to another recipient of your choosing.

  • Right to object (Art. 21+22 GDPR)

You have the right to object to the processing of your data by Innpact and to request Innpact to stop processing your data. In such case Innpact will stop processing your data unless there are overriding obligations such as those arising from contract or applicable laws.

Please note that Innpact does not send any newsletters and does not pass on your contact details to any third parties for their own marketing purposes without your explicit consent.

  • Right to complain (Art. 77 GDPR)

You have the right at all times to lodge a complaint with regarding the processing of your data, whether to Innpact or directly to a national data protection authority of a European Union Member State.