Nolen, Winkler, and Partners (NoW Partners)

GENERALITIES

At NoW Partners, we care about your privacy and the personal data you trustfully share with us.

We want you to clearly know how we deal with your personal information (as Data Subject) that we may gather or be given access to by you or a third party.

This Notice explains what kind of personal information we gather on you, as well as why and how we (as Data Controller) process it.

This Notice sets out your rights with regard to the EU GDPR (General Data Protection Regulation).

This notice might be subject to changes. Any updates will be posted on our website. We recommend you regularly review it to ensure that you are always aware of our privacy practices. Our privacy commitments to you:

We will keep your data safe and private
We will ensure that you can exercise your rights
We will train our employees to properly manage your personal information

WHO IS CONCERNED?

This Notice describes our practices when using:

The personal information of natural persons which are clients based in the EEA1 or outside the EEA;
The personal information of any other data subject which operates as an employee, a legal representative, a supplier, a partner, a proxy, an administrator, a guarantor or a contact person. The personal information of natural person based in the EEA who may visit our Website.

WHAT PERSONAL INFORMATION ARE WE COLLECTING AND WHY?

In general, we may collect the following types of personal information you give us or which are given to us by third parties:

Identification data, e.g., names, addresses, telephone numbers, email addresses, business contact information;
Personal characteristics, e.g., date of birth, country of birth;
Professional information, e.g., employment and job history, title, representation authorities;
Identifiers issued by public bodies, e.g., passport, identification card, tax identification number, national insurance number, social security number;

Financial information, e.g., financial and credit history information, bank details;
Transaction/investment data, e.g., current and past investments, investment profile, investment preferences and invested amount, number and value of shares held, role in a transaction (seller/acquirer of shares), transaction details;
Cookie information, e.g., cookies and similar technologies on websites and in emails (please see  also our Cookie Policy).

General Data Protection Regulation requires that we undertake to process only the data necessary for the purpose pursued by the processing.

More specifically, we use your personal data for the following purposes:

to fulfil the contract to which you are party, or as part of the pre-contractual measures of such contract ;
to comply with legal and regulatory requirements;
to pursue our legitimate interest as far as it is not overridden by your fundamental rights and freedoms;
to develop our business relationship with you;

for any additional purpose for which you have explicitly consented to.

WHAT ARE YOUR RIGHTS?

Individuals have the following rights, under certain circumstances, in relation to their personal information:

Right to access personal information
Right to rectify personal information
Right to restrict the use of personal information
Right to request that personal information is erased
Right to object to processing of personal information

Right to data portability (in certain specific circumstances)
Right to withdraw for consent for data processing (if the consent was required for lawful processing)
Right to lodge a complaint with a supervisory authority.

If you - as an individual - wish to exercise these rights, you can contact us at the following address:

NoW Partners

33 Rue de Gasperich

L-5826 Hesperange

Email : welcome@nowpartners.lu

Please note that we may ask for additional information to verify your identity before carrying out a request.

DATA TRANSFER

Your data can be transmitted to public authorities, regulatory authorities, courts when required by law. We will only transmit your personal information for commercial use with your prior consent.

RETENTION PERIODS

We will retain your personal information covered by this Notice for as long as required to perform the purposes for which the data was collected, depending on the legal basis on which such data was obtained and/or whether additional legal/regulatory obligations mandate that we retain the personal information. In general terms, this will mean that personal information will be kept for the duration of our relationship and:

KYC; and
as long as it is necessary for individuals to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under applicable law.

CONFIDENTIALITY AND SECURITY

We have implemented reasonable technical and organizational measures designed to secure personal information from accidental loss and unauthorized access, use, alteration or disclosure.

HOW TO CONTACT US?

If you would like to raise any questions, concerns or complaints concerning this Notice, you can contact us at: