Squircle Capital Advisory Sàrl (“SQAD”), 7, Rue Pierre d’Aspelt, L-1142 Luxembourg, acting as data controller, uses your personal data in order to provide you with a better experience and ensure that any material which could be sent to you reflects your personal preferences.
SQAD respects and values privacy so when it comes to you, we are committed to protecting and processing your personal data only in accordance with relevant data protection legislation and good data processing practices.
In this privacy policy (the “Privacy Notice”) we explain how we collect, use, share, protect and keep information about you as well as the rights to which you are entitled in this respect.
Please take a moment to familiarise yourself with our privacy practices.
What information does SQAD collect?
For the purposes mentioned in this Privacy Notice, we collect the following groups of data concerning you:
- Your basic identification and contact details only if such have been provided by you in any contact from or registration process: we may collect data about you such as your first and last name, email address, postal address, phone number, and other similar contact data, country, and preferred language;
- Your business contact information only if such have been provided by you in any contact from or registration process: we collect data about you such as job function, job title, department, organisation name, size and location;
- Information on how you use our website: we use cookies to collect data on how you use our websites and view our emails. This may include for example information on which SQAD’s website pages you have visited, how long you stayed on them, which items you clicked on and on your IP-address.
Further to the categories of data mentioned above, SQAD guarantees that we neither request, collect nor process special categories of personal data
How does SQAD collect data?
This Privacy Notice applies to personal data, which is information that SQAD collects from you and other third parties that specifically identifies you as individual. SQAD may collect data in various manners:
- Information that we automatically collect when you use our website and/or when you communicate with us: when you use our website, we automatically collect, through Cookies, the following information: navigation and click-stream data; HTTP protocol elements; search terms. When you communicate with us, we also automatically collect your identification and contact details to respond to your message .
Sharing your personal data
Your information will be shared internally for the purpose of managing our website . This includes all staff members of SQAD and its affiliates, as well as SQAD’s service providers.
SQAD shares your personal data externally. For instance:
- To service providers: we may need to share limited information with our service providers who assist us in managing the website, who help us to prepare and send you our communications and/or process your responses.
- To business partners: we may share your personal data with our business partners when it comes to the management and organisation of events and conferences.
- Safety, security and compliance with law: we will access, transfer, disclose and preserve personal data to comply with applicable law and for reasons relating to security. This may involve the sharing of your data with law enforcement, government agencies and other organisations where needed and/or required.
- Consent: we may share your data in other ways and for new purposes if you have asked us to do so and/ or have consented to such sharing.
Those recipients may be located both in and outside the European Union. Your personal data will not be transferred to any country outside the European Union which does not ensure an adequate level of protection unless you gave us prior authorisation to do so or specific measures (adequate security measures such as model clauses) have been taken by us in order to ensure that the requirements of the applicable data protection law have been fulfilled.
Your rights
SQAD seeks to ensure that you are able to exercise your rights at any time. SQAD will address any request within the limits of its technical and organisational means. These include:
- Right to access your personal information: should you want to review the data we hold, collect and process about you, please let us know by contacting us;
- Right to rectification: should the data we hold, collect and process about you be inaccurate or incomplete, you have the right to update such data at any time by contacting us;
- Right to erasure: if at any time you decide you do not want us to retain any personal data we collected from you, you may request we delete your data by contacting us. We will take reasonable measures to comply with your request in accordance with applicable laws;
- Right to restriction of processing: should you wish to exercise this right, please contact us. You have the right to restriction of processing only where in accordance with applicable laws;
- Right to object: should you wish to exercise this right, please contact us. We will consider your objection and we will comply with it unless we have a compelling legitimate ground not to, as permitted by applicable law;
- Right to data portability: you may have the right to have your personal data transmitted directly from us to another controller only when you have asked us to do so and have consented to such sharing, and when technically feasible. Should you wish to exercise this right, please contact us; and/or
- Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”), where you believe that your data is being processed in a way that does not comply with the GDPR.
Please be aware that these rights are not always absolute and there may be some situations in which SQAD may not be able to comply with your request.
Retention period of your data
SQAD will only retain your personal data:
- For as long as it is necessary for the purpose or purposes for which it was intended;
- For the purposes of rendering or fulfilling the service requested by you; or
- For as long as required or permitted by law.
How we protect your data
SQAD takes the security of your data seriously. SQAD acknowledges your trust and is committed to protecting the data you provide to us. We maintain appropriate organisational, physical and technical security measures to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of personal data.
Notification of personal data breach
SQAD is committed to notifying you of any personal data breach by SQAD, its processors, or any other third-parties acting on SQAD’s behalf without undue delay, only where the personal data breach is likely to result in a high risk of breeching your rights and freedoms.
Changes to this policy
We reserve the right to amend this Privacy Notice from time to time to reflect changes in the law, our data collection and used practices, and to ensure it is accurate, complete and up-to-date. You are advised to check this Privacy Notice from time to time.