Data protection
Tareno (Luxembourg) S.A. processes personal data from 25 May 2018 in accordance with Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
‘Personal data’ defines any information relating to an identified or identifiable natural person. A natural person is deemed identifiable when he can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, genetic, mental, cultural, social or economic identity.
‘Processing of personal data’ means any use of such data, such as collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
Personal data likely to be collected and processed
- Identification data (e.g. name, address, telephone numbers, date of birth, gender, identity card number, e-mail address, IP address)
- Financial data (e.g. bank account numbers, income, property, financial transactions)
- Data on education, training, profession, employer, hobbies, marital status
Personal data that is not processed
- Sensitive data (racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual orientation, genetic data), except with the consent of the persons concerned.
Legitimacy / purpose of processing personal data
- The data processing is necessary for the performance of a contract that you have entered into or intend to enter into with us
- You have given us your consent (e.g. direct marketing)
- The processing of data is necessary to comply with a legal obligation to which we are subject (Know Your Customer, MIFID, the fight against money laundering, terrorist financing and tax fraud)
- The processing of data is necessary for a legitimate interest of Tareno (Luxembourg) S.A. (defence of the interests of Tareno (Luxembourg) S.A. in legal proceedings, provided that our interests prevail over your interests, rights and fundamental freedoms).
Processing of personal data
Processing is limited to your data that is directly related to the initial purpose of processing. The information processed is that which is necessary for the fulfilment of the purpose and therefore data for which there is a direct link. Every effort is made to ensure that the data processed is correct and up-to-date. In addition, it is treated confidentially and stored in secure locations and equipment. We have taken appropriate organisational, technical and physical measures to ensure data protection and to prevent accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorised access of data.
Access to your data is limited to our employees and external service providers, as part of the performance of their services for the same purposes (e.g. IT). Your personal data may also be transferred by us to other financial institutions (e.g. your custodian bank). Finally, your personal data may be transferred to a public authority by virtue of a legal or regulatory obligation.
Tareno (Luxembourg) S.A. retains your personal data for the period necessary to fulfil the purpose and in accordance with its legal obligations.
Your rights
- Right of access and copy
- Right of rectification
- Right to erasure (under the conditions and within the limits set out in the Data Protection Regulation)
- Right to portability: you may request that your personal data be recovered in a structured, commonly used and machine-readable format so that it can be transmitted to a third party.
- Right to object: you may, for example, withdraw your consent to the processing of your personal data at any time If you wish to request the exercise of any of these rights or if you are dissatisfied with the way in which we process your personal data, you may contact us by post:
Tareno (Luxembourg) S.A.
Chief Compliance Officer
3, rue de la Poste
L-2346 Luxembourg
or by e-mail to: complaints@tareno.lu.
If you are not satisfied with the response given by Tareno (Luxembourg) S.A., you may submit your complaint to:
Commission National pour la Protection des Données
1, avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette
www.cnpd.lu