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Privacy Policy

Information regarding the collection, processing and use of your personal data.

Thank you for visiting the website of Active Ownership Capital S.à r.l. ("AOC"), where you can learn about our company and the range of services that we provide. In AOC we are committed in protecting your personal information; it is your information and we respect that.

This Privacy Policy explains how we collect your Personal Data through AOC’s website and through offline means, how we use, disclose and protect such data. This collection, processing and use of your personal data, is being done in compliance with the applicable data protection regulations, and AOC may amend from time to time this Privacy Policy in order to continuously comply with such regulations. In addition this Policy sets out your right to request that we delete, update or provide you with access to your personal information that we hold. Please note that this Privacy Policy only applies to personal information obtained by us – not information collected form your interactions with third parties.

Who we are and how to contact us

This website, the information and the services mentioned in it, are operated by AOC.

If you have any questions about this Privacy Policy, please contact us by sending an email to: gdpr@activeownershipcapital.com or through our online form. Henceforth we outline our principles for the collection, processing and use of your personal data:

1. Personal Data

Personal data is information that can be used to identify you or can be used to identify or contact you, e.g. your name, your personal identification, address, e-mail address or phone number (“Personal Data”).

2. Collection of Personal Data

AOC generally collects and uses the personal data only for operation of its website and to fulfil its legal or contractual obligations according to Art. 6 (1) f GDPR, as far as GDPR or any other legal regulation allows this collection or the user gave his consent for such processing. In occasion that such personal information is needed to be collected, you will be notified about this at the point of collection (e.g. contact form). Your data will be used exclusively for the purpose of processing the information that you already requested to receive from AOC, e.g. sending consumer information or newsletter subscription.

When collecting, processing and using your personal data, data protection regulations are observed and your data is treated confidentially.

Furthermore, AOC processes anonymous data when visiting this website as follows.

a) Server Access log With each access to our website, certain technical data are logged on the basis to our legitimate interest in this processing according to Art. 6 (1) f GDPR: operating system, internet service provider, IP address of accessing computer, browser type, name of the accessed file(s), date and time of access. These data are stored to optimise our website’s stability - for the duration of a user’s session - and for security to identify and pursue attacks on or misuse of our website. The data will be deleted as soon as they are no longer needed to attain the objective for which they were collected. An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

b) Cookies Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes. A cookie is a small text file that is sent from the web server to your browser to collect non-personal anonymous data. This file contains the URL visited, the date of the visit and an expiration date that determines the period of activity of the cookie. On the one hand, cookies are used by AOC to determine the more frequent visited pages of the AOC website and enhance the user experience and, on the other hand, to enable the user to save their personal settings in order to be available again the next time the website is accessed. AOC uses cookies on the basis of our legitimate interest according to Art. 6 (1) f GDPR. Every user actually has the choice to decide whether cookies are accepted or not. Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web site’s features. Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.

c) Contact form You may contact AOC directly via the online contact form. The personal data entered here (e.g. name, e-mail address) are processed in accordance with the statutory provisions for processing the request in accordance to Art. 6 (1) f GDPR. Personal data is only collected by using our contact form voluntarily and with your explicit consent (declaration of consent). You will then be informed of the collection and use of this personal data at the appropriate point (contact form).

Your data, will be used exclusively for processing the information that you already requested to receive from AOC, e.g. sending consumer information or newsletter subscription. Any Personal Data obtained by AOC, is generally not being shared with third parties.

3. Data storage

Unless expressly stated otherwise, AOC will retain personal data for as long as necessary for the purposes set out above. This is subject to statutory retention requirements. AOC employees are instructed to review the retention of personal data and to delete it, if necessary, periodically. Our website does not automatically collect your Personal Data without your knowledge.

4. Your rights

If AOC processes personal information about you, you have the following rights:

- Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will then provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in your personal information held by us.

- Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more.

- Other Rights: in addition, you may have right to have your information deleted if we are keeping it for a long period, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting AOC at gdpr@activeownershipcapital.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards. We will make sure that we will meet your request according to the applicable regulations.

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