Privacy policy

1. Who is responsible for your data

The controller of the personal data processed through this website and in the course of our business relationships is:

For any question about this policy or your data, contact our Data Protection Officer at dpo@atdomcoinvestorservices.com or by post at the address above, marked “Data Protection Officer”.

2. Personal data we collect

• Contact data you give us through the contact form or by email: name, company, professional email address, your profile and the content of your message.
• Business relationship data about representatives of our clients and prospects: identity, position, contact details, correspondence.
• Investor and client due-diligence data (for funds and companies we service): identity documents, address, tax residence, beneficial ownership, source of funds and screening results, as required by anti-money laundering law.
• Technical data when you browse the site: IP address, browser type, pages visited and date/time, kept in server logs by our hosting provider for security. We do not use audience-measurement or advertising cookies (see our cookie policy).

3. Why we use your data and on what legal basis

4. Who receives your data

Your data is accessed only by authorised staff who need it, subject to professional secrecy (article 41 of the Law of 5 April 1993). It may be shared with:

• other Atdomco Group entities, including IRE AIFM, where needed to deliver the services;
• service providers acting on our behalf (IT, hosting, document management), bound by a data processing agreement — for this website in particular: Netlify, Inc. (United States), which hosts the site; EmailJS Pte. Ltd. (Singapore, with servers in the United States), which transmits the messages sent through the contact form; and Microsoft (Microsoft 365), which hosts the mailbox that receives them;
• the funds and companies we service, their depositaries, auditors and banks, as part of the services;
• competent authorities (CSSF, tax authorities, Financial Intelligence Unit, courts) where the law requires it.

We never sell your personal data.

5. Transfers outside the European Economic Area

Atdomco Group has teams in Mauritius and the United Arab Emirates, and some of the service providers of this website process data in the United States: Netlify relies on the EU-U.S. Data Privacy Framework and the European Commission's Standard Contractual Clauses; EmailJS relies on the European Commission's Standard Contractual Clauses. Where personal data is transferred outside the EEA to a country without an adequacy decision of the European Commission, we put in place appropriate safeguards, in particular the European Commission's Standard Contractual Clauses, together with supplementary measures where needed. A copy of these safeguards can be requested from our Data Protection Officer.

6. How long we keep your data

• Enquiries that do not lead to a business relationship: up to 3 years after our last contact.
• Client and investor due-diligence records: 5 years after the end of the business relationship or the transaction, as required by the Law of 12 November 2004 on the fight against money laundering and terrorist financing (extendable where the law allows).
• Accounting records and supporting documents: 10 years, as required by the Luxembourg Commercial Code.
• Website server logs: kept by our hosting provider for a limited period, for security purposes.

7. Security

We apply technical and organisational measures appropriate to the risk — including access controls, encryption in transit, logging and staff training — to protect personal data against loss, misuse and unauthorised access.

8. Your rights

Under the General Data Protection Regulation (EU) 2016/679, you have the right to:

• access your data and receive a copy (art. 15);
• have inaccurate data corrected (art. 16);
• have your data erased, where no legal obligation requires us to keep it (art. 17);
• restrict processing (art. 18) and receive your data in a portable format (art. 20);
• object to processing based on our legitimate interest, and to direct marketing at any time (art. 21);
• withdraw your consent at any time, without affecting processing already carried out.

To exercise these rights, write to dpo@atdomcoinvestorservices.com. We answer within one month; we may ask for proof of identity.

9. Right to lodge a complaint

If you believe your data is not handled lawfully, you may lodge a complaint with the Luxembourg data protection authority:

10. Changes to this policy

We may update this policy to reflect changes in our services or in the law. The date at the top of the page shows the latest version.