Privacy Policy

Disclaimer

Information and content – in particular, price, market, stock exchange or other business information – which re:cap global investors ag, Zug, Switzerland (“re:cap”) obtains from third parties (news agencies, fund companies or other commercial information providers) and/or which re:cap makes available to the user via links to such third-party providers (third-party content), are not the responsibility of re:cap; re:cap accepts no liability for such content. In particular, re:cap accepts no responsibility for the currency of price information, which possibly may only be relayed with a time delay. Furthermore, re:cap does not adopt the third-party content as its own, even if it is accessible via links on its website or there are links on the website referring to the third-party content.

The offering and distribution of shares/units in existing sub-funds of FP Lux Investments SCSpSICAV-RAIF, 1c, rue Gabriel Lippmann, L-5365 Munsbach, Luxembourg, is exclusively the responsibility of this company itself/the distribution partners appointed by same in the countries in which they are registered for distribution.

Therefore, the information contained in these pages should not be construed as an invitation to purchase shares/units in the existing sub-funds for persons not legally permitted to do so.

Valid versions of these documents may be obtained solely from FP Lux Investments SCSpSICAV-RAIF at the registered office of the company – 1c, rue Gabriel Lippmann, L-5365 Munsbach, Luxembourg – from the mandated AIFM of the company – BKN Capital S.A., Campus Contern – Building BOUVREUIL, 17, rue Edmond Reuter, L-5326 Contern, Luxembourg – or from the registrar of the fund.

All web pages, layouts, sources, as well as all proprietary and third-party content and information are protected by copyright, licences or other intellectual property rights and may not be distributed, processed or altered in any manner, or used for commercial purposes. The information and content on the re:cap web pages (proprietary content) have been carefully edited and researched. The content is regularly reviewed and, if necessary, updated and modified. However, re:cap cannot guarantee the accuracy, completeness and, in particular, the currency of the information and content, unless re:cap is guilty of intent or gross negligence in a specific case.

Privacy policy and information to be provided pursuant to Art. 13 and 14 of the GDPR

1. General

The responsible and legally compliant handling of your data is a primary concern for us.

We would like to inform you how we collect and otherwise process personal data. Personal data is all information relating to an identified or identifiable natural or legal person (such as name, contact details or consumption data).

Please note that this Privacy Policy does not contain a final description of our data processing, and specific data protection provisions or General Terms and Conditions of Business and Terms of Use may govern some aspects in whole or in part.

If you provide us with personal data on third parties (e.g. of family members or colleagues), please ensure that these persons are also familiar with the Privacy Policy.

Only share personal data on third parties if you are permitted to do so and the personal data are correct.

The Privacy Policy is based on the Swiss Data Protection Act (Bundesgesetz über den Datenschutz – DSG) applicable to re:cap.

In addition, we follow the guidelines of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG).

Controller within the meaning of the General Data Protection Regulation:

re:cap global investors ag, Baarerstrasse 8, CH-6300 Zug

2. What personal data do we process and for what purpose?

The following is a list of the personal data we process.

The term “processing” means any operation or set of operations performed on such data (such as collection, storage, use and disclosure):

– personal data that we receive in the course of our business from customers, business partners or other persons involved in the business relationship;

– personal data that we are legally or contractually obliged to collect;

– personal data that we take from public sources (media, Internet) or public registers (debt collection registers, land registries, registers of companies, etc.);

– personal data that we obtain from authorities and other third parties (list brokers, credit agencies).

Such personal data will only be processed to fulfil existing business relationships in the context of transactions and asset management for our company.

Furthermore, we process personal data to comply with statutory and regulatory obligations.

If you have given your consent to the processing of your personal data by us for certain purposes, we process your personal data in the context of and based on this consent, barring other legal grounds. Once given, consent may be withdrawn at any time. However, this does not have any effect on data processing that has already taken place. Consent must be withdrawn in writing or by sending an email to datenschutz@re-cap.ch.

3. Are personal data disclosed to third parties?

We only disclose personal data in the course of our business activities and for the purposes mentioned in point 2.

This involves, in particular, disclosure to service providers, including data processors (e.g. IT providers), suppliers, sub-contractors and other business partners, customers, authorities, official bodies and courts. We choose our contractors and suppliers carefully, evaluate them regularly and obligate them to comply with the GDPR within the mandatory set of agreements.

Some of the recipients are located in Switzerland, but some are located abroad.

Specifically, you must expect your data to be transmitted to other countries within Europe and to the USA, where some of the IT service providers we use are located.

If we transmit data to a country that does not have an adequate legal data protection standard, we ensure an adequate protection standard by making appropriate contracts or we work within the existing legal exemptions.

4. How long do we process personal data for?

We process personal data for as long as necessary for the fulfilment of our contractual and statutory obligations or for the purposes pursued with the processing; for example, for the entire duration of the business relationship (from initiation, execution until the end of a contract) as well as according to the statutory obligatory storage and documentation periods.

It is possible that personal data will be kept for the length of time for which claims may be made against our company and to the extent that we are otherwise legally obliged to do so or legitimate business interests require (e.g. for purposes of proof or documentation).

As soon as your personal data are no longer required for the above purposes, they are generally and to the extent possible deleted or anonymised.

5. What data protection rights can you exercise?

Within the framework of the data protection law applicable to you and to the extent provided for therein, you have the right to information, rectification, erasure, data portability, the right to lodge a complaint with a supervisory authority, the right to restriction of processing and also the right to object to data processing by us.

Please note, however, that we reserve the right to exercise the restrictions provided in the law, if we, for example, are obliged to retain or process certain data or the data are required to establish claims.

To exercise your rights, please contact us as indicated in the legal notice in writing or by sending an email to datenschutz@re-cap.ch.

6. Cookies

U To make it more attractive to visit our website and for certain functions to work, we use cookies on various pages. Cookies are small text files that are placed on your device. Some of the cookies we use are deleted at the end of the browser session; that is, after you close your browser (“session cookies”). Other cookies remain on your device and enable your browser to be recognised on your next visit (“persistent cookies”). If cookies are placed, they collect and process certain user information on an individual basis, such as browser and location data as well as IP address. Persistent cookies are automatically deleted after a set period of time, which can vary from cookie to cookie. The period for which an individual cookie is stored is given in the table in your web browser’s cookie settings. In some cases, the purpose of the cookies is to store settings to simplify the ordering process (e.g. remembering the content of a virtual basket for your next visit to the website). If any cookies we use process personal data, such processing is done pursuant to point (b) of Art. 6(1) of the GDPR for the performance of the contract, pursuant to point (a) of Art. 6(1) of the GDPR where consent has been given or pursuant to point (f) of Art. 6(1) of the GDPR for the purpose of our legitimate interests in optimal website functionality as well as making the site visit customer-friendly and effective. Please note that you may configure your browser to alert you when cookies are placed and you can decide individually whether to accept them or to disable cookies in certain cases or in general. Every browser is different in how it manages cookie settings. This is described in the help menu of every browser, which explains how to change your cookie settings. The following are the links for the different browsers:

Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies

Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen

Chrome: https://support.google.com/chrome/answer/95647 hl=de&hlrm=en Safari: https://support.apple.com/de-de/guide/safari/sfri11471/12.0/mac/10.14

Opera: https://help.opera.com/de/latest/web-preferences/#cookies

Please note that blocking cookies may limit the functionality of our website.

7. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, text files that are placed on your computer to help analyse how you use our website. As a rule, the information generated by the cookie about your use of this website is transmitted to and stored by Google on a server in the United States. If IP anonymisation is enabled on this website, however, your IP address will be truncated by Google in the Member States of the European Union or in other States party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there. IP anonymisation is enabled on this website. On behalf of the operator of this website, Google will use this information to evaluate your usage of the website, to compile reports on website activity and to provide the website operator with other services related to website activity and Internet usage. The IP address transmitted by your browser by Google Analytics is not merged with other Google data. You can prevent the storage of cookies by configuring your browser software accordingly; however, note that if you do, it is possible that some features of this website will not work properly. You can also prevent Google from collecting the data generated by the cookie and related to your usage of the website (including your IP address) as well as Google from processing these data by downloading and installing the browser add-on available at the following link:

tools.google.com/dlpage/gaoptout?hl=de

Further information on the terms of service and on data privacy can be found at:

http://www.google.com/analytics/terms/de.html bzw. unter

http://www.google.com/intl/de/analytics/privacyoverview.html.

8. Google Tag Manager

This website uses Google Tag Manager. This service manages website tags via an interface. The Google Tag Manager only deploys tags. This means that no cookies are set and no personal data are collected. Google Tag Manager triggers other tags that themselves may collect data. However, Google Tag Manager does not access these data. If you have disabled a setting at domain or cookie level, this remains in effect for all tracking tags, provided that these tags are deployed with Google Tag Manager.

9. Google Maps

This website uses Google Maps to display maps and to give directions. Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. By using this website, you consent to the collection, processing and use of data automatically collected, or data entered by you, by Google, one of its agents or third parties. The Terms of Service for Google Maps can be found at Nutzungsbedingungen für Google Maps.

10. Social Plug-ins

The social plugins on our website require two clicks to activate.

This means that data will not be transferred to the platform in question until you click into it.

If you have accounts on these media, information may be attributed to your profile.

We have no control over such subsequent processing. Information on data processing by the social media platforms can be found on their websites.
The same also goes for the Google Maps map embedded on our site. Data are not transferred to Google until you click into it.

11. Tools and other
Cookie consent tool with Usercentrics technology

To obtain effective user consent for cookies that require consent and cookie-based applications, this website uses a cookie consent tool with technology from Usercentrics GmbH, Rosental 4, 80331 Munich, Germany (“Usercentrics”). A JavaScript code is embedded and a banner appears when users open the page. In the banner, users can give consent for certain cookies and/or cookie-based applications by ticking a box. The tool blocks all cookies that require consent until the user gives consent by ticking the appropriate box. This ensures that such cookies are only placed on the user’s device if he/she has given consent. For the cookie consent tool to be able to individually record, log and store the user’s consent settings for the duration of the session, when our website is opened the cookie consent tool collects certain user information (including the IP address), and transmits it to and stores it on Usercentrics servers. Such data processing is done in accordance with point (f) of Art. 6(1) of the GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly cookie consent management and thus in the legally compliant design of our website. Further legal grounds for the data processing described is point (c) of Art. 6(1) of the GDPR. As controller, we have a legal obligation to make the use of technically unnecessary cookies contingent on user consent. We have a data processing agreement with Usercentrics, which obligates Usercentrics to protect the data of visitors to our website and not to disclose them to third parties. Further information on the use of data by Usercentrics can be found in the Usercentrics privacy policy at https://usercentrics.com/privacy-policy/.