PRIVACY POLICY

CompaM Fund (hereafter “Compam”) is a company with many years of experience in international finance (asset management, investment funds, trading and bond broking, estate and succession planning, risk management).

The processing of personal data, to which Compam may become privy, is carried out in compliance with Article 13 of the RGPD 679/2016 “General Data Protection Regulation”, as well as taking into account the principles of correctness, lawfulness, transparency and all limitations aimed at the preservation, minimization and accuracy of data, i.e. in compliance with the protection of personal integrity and confidentiality of all sensitive information attributable to the person.

This Privacy Policy is intended to be for the website www.compamfund.com (hereinafter the “Website”).

The Data Controller is CompaM Fund. 

To request further information about the processing of your personal data or to exercise your rights, you can contact us:

by writing to:CompaM Fund
49, Avenue J.F. KennedyL – 1855 Luxembourg
by writing to the email address:compamfund@compass-am.com
  1. What is personal data and what is processed

Personal data is information that directly or indirectly identifies or can identify an individual and can provide information about his or her characteristics, habits, personal relationships, etc. The following is considered personal data, including but not limited to: first name, last name, address or other contact details, an identification number or an online identifier.

Processing is any operation performed with or without the aid of automated processes and applied to personal data. Processing includes, but is not limited to: the collection, recording, organisation, storage, modification, consultation, erasure or destruction of data.

  1. What personal data is being processed
  1. Browsing data

During their normal operation, the computer systems and software procedures responsible for the operation of the Website acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects, but may by its very nature enable the User to be identified through processing and association with data held by third parties. This data includes: the IP addresses or domain names of the computers used by the User who connects to the Website; the URI addresses of the resources requested (Uniform Resource Identifier); the time of the request; and finally, other parameters relating to the User’s operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Platform to control its correct functioning, to identify anomalies and/or abuses and is deleted immediately after processing. The data could be used to ascertain liability in the event of cyber attacks against Compam or third parties.

  1. Data provided by the User through the “Info” Form

The User’s data is collected by the Data Controller when completing a form (hereinafter referred to as the “form”), in order to comply with the request for information.

  1. Data provided voluntarily by the User

The optional, explicit and voluntary sending of email to the addresses indicated on this website involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data entered in the letter.

  1. Purpose of processing

Your personal data will be processed for the following purposes:

  1. Respond to the request submitted to Compam by the User;
  2. Fulfil the pre-contractual, contractual, administrative and tax obligations arising from the relationship that may be established between the User and Compam;
  3. Send the User service-related communications/notifications;
  4. Fulfil the obligations established by law, current regulations, practice and requirements of the competent authority;
  5. To exercise their rights (both in and out of court) by Compam;
  1. Legal basis for the processing of User’s data

Each processing is justified by one of the following legal assumptions:

  1. Such processing is necessary for the execution of the contract between the parties. The provision of personal data is optional in this case but failure to provide it means that it is impossible to conclude the contract and perform the service requested;
  2. Processing is necessary for compliance with a legal obligation. In this case, the provision of data is mandatory and failure to provide it will result in it being impossible to conclude the contract and to perform the requested service;
  3. Processing is necessary for the pursuit of the legitimate interests of the Controller, provided that the interests or fundamental rights and freedoms of the User that require the protection of personal data do not prevail. In this case, the provision of data is optional.
  4. Processing is only possible where the User has consented to certain specific purposes. In such cases the provision of data is optional, and the User may revoke the consent previously given at any time.
  5. To whom might the data be disclosed

In the context of Compam’s activities and for the purposes specified above, your personal data may be shared with:

  • Duly appointed data processors providing specific processing services or accessories on behalf of Compam; the User may at any time request an up-to-date list of Data Processors;
  • Autonomous Data Controllers to whom the data may be communicated pursuant to legal provisions or orders of the Authorities;
  • Individuals authorised by Compam to process personal data necessary for carrying out activities strictly connected with the provision of services and who have an appropriate legal and contractual obligation of confidentiality (e.g. Compam’s employees and/or contractors).

Compam does not intend to sell or otherwise disclose your personal data to third parties.

  1. Where the data is stored

All personal data is stored electronically on servers located in the EU.

  1. How long are the data stored?

Your personal data is kept in compliance with the confidentiality and regulations in force for a maximum period of 10 years from the end of the contractual relationship. Any CV submitted by the User as candidates will be retained for a maximum period of 2 years after submission.

  1. What are your rights?

At any time, you can request confirmation as to whether or not your personal data is being processed and you have the right to: 

  • request access to the data to obtain information on the purposes pursued with the processing, the recipients to whom the data may be disclosed, the duration of the processing (where possible) and any consequences of processing based on profiling;
  • request the correction of personal data if it is inaccurate or incomplete;
  • request the deletion of data, if it is no longer necessary for Compam for the intended purposes; 
  • request that data processing be restricted, in the cases provided for by law;
  • request the transfer of data to another Data Controller in a commonly used format that can be read by a computer device, in the cases provided for by law;
  • object to the processing of your data and, specifically, have the right to object to decisions concerning you, if based solely on automated processing of your data, including profiling;

To exercise your rights, you can use the contact details provided under paragraph 1 or access the website of the Luxembourg Data Protection Authority https://cnpd.public.lu/fr.html 

  1. Automated Decision Making

You are not subject to decisions based on automated processing.

  1. Cookies

Cookies are text rows which act as computer markers sent from a server (in this case, the one on the Website) to a user’s device (usually to the Internet browser) when they access a given page of a website; cookies are automatically stored by the user’s browser and retransmitted to the server that generated them each time the user accesses the same Internet page. In this way, for example, cookies allow and/or facilitate access to certain Internet pages in order to improve the user’s browsing experience (i.e. they allow the storage of pages visited and other specific information, etc.), or in some cases they allow profiling activities. Therefore, for a facilitated and complete use of the Website, it is useful if, on your first time accessing the Website, you express your preferences regarding the placement of cookies. 

Characteristics and purposes of cookies

Our Site uses the following categories of cookies:

“Necessary Cookies” (known as Technical cookies): These are necessary to enable the User to browse the Website and use its functionalities. In particular, they enable functions without which it would not be possible to use the Website fully, since their presence enables basic functions such as page navigation and access to the protected areas of the Website.

“Session Cookies” are active cookies for the relevant session only, which allow you to temporarily store the information needed to navigate from page to page and avoid having to re-enter it.

The User’s consent is not required for the use of Necessary (“Technical”) cookies.

  1. Amendments

Compam reserves the right to amend or simply update the content of this Privacy Policy, in part or in full, including as a result of changes in applicable legislation. These changes will be binding as soon as they are published on the Site. If you continue to access or use the service after such posting you will be deemed to have expressly accepted these changes. Compam therefore invites the User to visit this section regularly to take cognizance of the latest and updated version of the Privacy Policy so that they can always be updated on the data collected and the use that Compam makes of it.

15 February 2023

Before accessing the navigation of this website, read carefully warnings below:

By accessing this web site and any pages thereof, you acknowledge your agreement with and understanding of the following terms of use and legal information pertaining to both this web site and any material in it. If you do not agree to the terms and conditions below, do not access this web site or any pages thereof.

Access to the information contained on this web site may be restricted by laws and regulations applicable to the user. Persons in respect of whom such prohibitions apply must not access this web site.

NO RELIANCE AND NO WARRANTY

Although COMPAM believes that the information on the web site is accurate at the date of publication, no warranty of accuracy is given. The information on this web site is provided for information only and should not form the basis of an investment decision. Opinions and any contents of this web site are subject to change without notice. COMPAM accepts no liability for any loss or damage arising from any use made of information contained in this web site.

LIMITATION OF LIABILITY

Under no circumstances, including, but not limited to, negligence, shall COMPAM be liable for any special or consequential damages that result from the access or use of, or the inability to access or use, the materials at the Site.

INVESTMENT PERFORMANCE

The value of investments and the income derived from them may fall as well as rise and investors may not get back the amount invested. Past performance is not necessarily a guide to the future performance of an investment. Changes in rates of foreign exchange may cause the value of investments to go up or down. No information or material on this web site is to be relied upon for the purpose of making or communicating investment decisions.

NO OFFER

Nothing on this web site should be construed as a solicitation or offer, or recommendation, to acquire or dispose of any investment or to engage in any other transaction. None of the investments referred to in this web site are available, and prospectuses in respect of them will not be distributed, to persons resident in any country, state or jurisdiction where such distribution would be contradictory to local law or regulation.

LOCAL LEGAL RESTRICTIONS

This web site is not directed to any person in any jurisdiction where, by reason of that person's nationality, residence or otherwise, the publication or availability of this web site is prohibited.

USA: The investments referred to on this web site have not been registered in the United States under applicable U.S. securities laws. The investment vehicles described on this site are not being offered in the United States or to US persons and the information contained on this site is neither an offer to sell nor a solicitation of an offer to buy interest in these investment vehicles.

SWITZERLAND:

The Fund has not been authorized to be sold to the public in and out of Switzerland and the information contained on the following pages do not constitute an offer or solicitation for the sale of the Fund.

The Fund may be sold in Switzerland within the terms and conditions of Swiss law and current practice of the Swiss Financial Supervisory Authority FINMA and in particular the offer is reverted to institutional investors in accordance with the Swiss Collective Investment Schemes Act,  art. 3 para. 1 and 10 para. 3 let. a. and b.

Therefore, if you access the following information and presentation of the Fund, you acknowledge that you understand and accept this disclaimer and comply with the restrictions given by the Swiss regulator. If you do not agree with this disclaimer and do not comply with the restrictions, do not access the following pages.

No information or any opinion expressed on this site shall be construed as a public offer, solicitation of an offer, or a recommendation to buy or sell investment funds, or provide any investment advice or service in relation thereto.

 

 HYPERTEXT LINKS, REFERENCED WEBSITES

COMPAM disclaims any liability, whether in contract, tort or criminal liability resulting from any damages arising out of or in any way connected to the referenced website or the use of the hypertext links. COMPAM does not control, nor support to any extent the contents of these websites which are not covered by this notice.

RESERVATION OF RIGHTS

COMPAM reserves the right at any time to revise, amend, alter or delete the content provided on this website.

JURISDICTION

The content of this website under the domain name www.compamfund.com resides in Luxembourg and shall be governed by the Laws of Luxembourg.
Any disputes arising from this website shall be dealt with exclusively by the Court of Luxembourg

COPYRIGHT

All material available on the Site, unless otherwise specifically indicated, is subject to copyright with all rights reserved. The material is freely usable for browsing purposes only and requires express mention of COMPAM in the event the material, or any part thereof is reproduced in any form, written or electronic. Additionally, any re-publication of this material requires the express consent of COMPAM. Links to the site or use for any public or commercial purpose are subject to COMPAM's prior written permission.