1. Data Controller
This Policy applies to by Zadig Asset Management SA, a Luxemburg corporation with its registered address: 70C, route d’Arlon L-8008 Strassen Luxembourg, hereinafter referred to as Zadig or “we”, “us” or “our”. In accordance with Article 24 GDPR, we function as the Data Controller, meaning we are responsible.
If you are a citizen in the US, our privacy and data protection policies comply with the California Consumer Privacy Act 2020 (“CCPA“). For citizens in Canada the Canadian Personal Information Protection and Electronic Documents Act S.C. 2000, c. 5 (“Pipeda”) shall apply. If you are a User in the United Kingdom and Wales, because of Brexit, the GDPR remains applicable during a so-called transitional period. Please review this page regularly for applicable changes.
4. Getting in touch with us
When Users are contacting us or when creating an account with us, we collect personal data. You understand and acknowledge that leaving your information with us is at your own risk. Your personal data is kept private and confidential and is processed in a secure manner. We guarantee a safe and secure way of data transmission, but each User remains responsible for providing their data to us.
When you contact us through our website, social media, phone, or by any other means, we may collect data and personal information, which we will store and process based on our legitimate business interests, and in accordance with Article 6 GDPR. Moreover, your data will be kept by us as long it is legally required.
5. Use of (personal) data
Besides the purposes mentioned in this Policy, your personal information may be used for other purposes, as long as they are appropriate, such as our legitimate business interests. However, the way we use your information shall always remain suitable for your interests.
We control and process your personal data and the purposes by which we do so are by no means exhaustive. Your personal information may be used in other ways as long as we have received your explicit consent or when we have a legal obligation to do so.
We may use your (personal) data for the following purposes:
- Give the services to you which you have requested;
- Track your use of our website and services and monitoring activity;
- Collect log data and device information to improve our services.
6. Children and privacy
If you are the parent or legal guardian of a child who is under the age of eighteen (18) and you notice that he or she is visiting our website without your permission, please contact us at immediately at: email@example.com. We shall never collect or process any personal data from children under the age of thirteen (13).
7. Data Processors
Zadig makes use of third-party service providers to operate our services and conduct our business. These parties have no or limited access to your data. Under the GDPR, those third-parties are considered Data Processors. We make use of the following Data Processors. Please check their respective privacy and data protection policies.
Each Data Processor mentioned may make use of their respective Data Processors. We undertake that they – at all times – maintain the same level of privacy and data protection as we do. However, we will never take any responsibility or be liable for data leaks or breaches for which the Data Processors listed above are responsible.
In case your personal information is transferred outside the European Economic Area (EEA), the jurisdiction it is transferred to must have the same level of data protection laws and regulations as laid down in the GDPR.
8. Individual’s Rights
Under the GDPR, you are considered a Data Subject with certain fundamental rights regarding your personal data.
a. Access Rights
You have the right to access and receive a copy of the personal information we have stored and upon your request, we will provide information about the way we have collected and processed your data.
b. Rights of Rectification
If your data is incorrect or incomplete, you can send us an email, and we will correct it without delay. Please contact us at firstname.lastname@example.org.
c. Right to be Forgotten
When there is no lawful purpose any longer or for any other reason whatsoever, you can request us to delete your data and personal information. We shall immediately honor such a request unless there is a legal obligation to keep your personal data for a longer period of time
d. Transfer Rights
On your request, we shall always provide you with a copy of your personal data we have stored in a machine-readable format, or transfer it directly to a new Data Controller on your request.
e. Right to Object
You can always object to the processing of your data when we do so based on your consent. Please contact us at email@example.com.
We want to resolve any complaint directly with you regarding our processing of your personal data. Please contact us at firstname.lastname@example.org. In any event, you also have the right to complain to your national Data Protection Authority, which is in this case: Commission Nationale pour la Protection des Données; please visit their website for more information: https://www.cnpd.lu.
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