Version October 2019
The website “www.reinet.com” (hereafter referred to as the “Website”) is operated by Reinet S.à r.l., 35, boulevard Prince Henri, L-1724 Luxembourg.
When a user uses the Website, Reinet S.à r.l. may collect personal data or information about the user or related to the user (also referred to as “you” or “your”) provided by the user via the Website as explained below, and share it with Reinet Investment S.C.A. acting through its general partner, Reinet Investments Manager S.A., 35, boulevard Prince Henri, L - 1724 Luxembourg, Phone number: +352 22 42 10 (hereafter also referred to as “Reinet”, “we” or “our”).
We process personal data collected via our Website and data collected by us from other sources as data controller in accordance with Regulation (EU) 2016/697 of 27 April 2016 (the “GDPR”) as well as any complementing or other law or regulation relating to the protection of personal data applicable to us (together the “Data Protection Laws”).
“Personal data” is defined by the GDPR as any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, in particular by reference to an identifier such as name, identification number, location data, online identifier or to one or more factors specific to, for instance, the physical, economic, cultural or social identity of that natural person (the “personal data”).
The purpose of the present policy is to inform you in your capacity as user of the Website about the type of data we process, the legal basis for such processing and its purposes and the rights you have in that respect.
1. Identity and contact details of the Controller
Reinet Investment S.C.A. acting through its general partner, Reinet Investments Manager S.A., a société anonyme incorporated under the laws of Luxembourg, having its registered office at L-1724 Luxembourg, Boulevard Prince Henri 35, registered with the Registre de Commerce et des Sociétés de Luxembourg under the number B 141.352 is to be considered as data controller (the “Controller”) with respect to the personal data it processes in relation to you as described below.
2. Type of personal data collected by Reinet
For the purpose of providing the services accessible on or via the Website, we collect and process personal data of any user taking the following actions on the Website:
- subscribing for receiving email updates on the latest Reinet financial and company announcements and press releases (we then collect the email address you register);
We do not request any sensitive personal data from you; neither do we wish to process such data.
Sensitive personal data are data relating to your racial or ethnic origin, political opinion, religious or philosophical convictions, trade union membership, health and sexual life, and genetic data.
Therefore, if you deliberately include such sensitive personal data about yourself (or other persons) in the incoming communication and/or documents sent to us notably in connection with the holding of ordinary shares of Reinet or otherwise, we consider that we have received the consent to use it for the purpose of responding to your query. To the extent we consider the sensitive personal data not useful for the purpose of handling your request, we endeavor to delete such data.
Cookies are small data files that we and our service providers store on the device you use to browse our Website such as your computer, smartphone, tablet or smart TV.
We or our service providers use the following types of cookies:
- Essential process cookies: they are absolutely necessary for the good functioning of our Website and services;
- Functional cookies: they allow us to operate or customize certain features of our Website and services based on your choices or as requested by you;
- Performance cookies: they are used to collect information on your use of the Website and services, on electronic communications, to analyse how the Website and services work and report potential errors. Such information helps us operating, maintaining and continuously improving the Website and services;
- Targeting cookies: they allow collecting information about your browsing history and preferences.
At any time, you can delete, block or disable cookies through your browser settings but note that all or some features of our Website and the services we propose may then not work correctly (or simply require that you input information previously provided when visiting our Website again).
Depending on the internet browser you are using, you can delete selected cookies or all at once. Through your internet browser setting, you can block all or certain types of cookies, from certain or all websites.
To manage your internet browser settings, please go to the “Tools”/“Preference” and “Internet Option” menu/page or equivalent of your internet browser. Then look for the “Delete Internet History” “Privacy” or “Cookies” settings.
Due to the growing number of internet browsers available and the various versions supported, it is not easy to provide you with detailed information on how the above works for each of them. We invite you to visit the assistance or help available for the internet browser you are using for more information on how to manage your internet browser settings.
3. Purposes and legal grounds regarding the processing of personal data
We will only process your personal data collected via the Website for purposes related to the sending of the latest Reinet financial and company announcements and press releases and to the management of your incoming correspondence and the legal ground for such processing of your personal data is the satisfaction of our legitimate interests such as responding to your queries and providing you with legal and/or financial information on Reinet.
4. Hosting of the Website and recipients of the personal data
The Website is operated internally by Reinet S.à r.l. and is hosted in Luxembourg.
There is a back-up of the Luxembourg server on servers of our IT service provider located in the United Kingdom. Whilst this IT service provider has no access to any personal data in the ordinary performance of its duties, it may under exceptional circumstances and on a temporary basis access personal data, notably when this is required to ensure business continuity and data recovery.
Personal data provided via the Website will not be accessible to third parties other than those described here.
Your Personal Data is or may be transferred by us to the extent that such disclosure or transmission is necessary for satisfying the aforementioned purposes to a service provider in charge of the maintenance of the Website and to service providers operating in the IT and Communication fields and being in charge of the administration of the distribution lists and the communication, publication, distribution and regulatory filing (as may be required) of legal and/or financial information (whether periodic or ad hoc) from Reinet, all of which are located in Switzerland, and to an IT service provider located in the United Kingdom providing IT support services.
In circumstances where your Personal Data is or should be transferred to an entity not located within the European Economic Area (“EEA”), such transfer shall be based either (i) on an adequacy decision of the European Commission with respect to the protection of personal data in the country of domicile of the processor, (ii) on standard data protection clauses approved by the European Commission (in compliance with Article 46.2 of the General Data Protection Regulation), (iii) on your explicit consent to the proposed transfer, or (iv) in the event it is required by any judgment of a court or tribunal or any decision of an administrative authority, the Personal Data will be transferred on the basis of an international agreement entered into between the European Union or a concerned member state and other jurisdictions worldwide or, in compliance with Article 49.1 of the General Data Protection Regulation.
5. Retention of your personal data
We will only retain your personal data for the period necessary to fulfill the purposes for which it was collected and to comply with our legal obligations subject to the legal periods of limitations and to the situations where the applicable laws require or allow that such personal data be retained for a certain period of time after the purposes pursued by such processing have been fulfilled.
6. Your rights
You are hereby informed that you benefit from the following rights, subject to the conditions of the Data Protection Laws:
|(a)||right to access your personal data (i.e the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and relevant information in that regard);|
|(b)||rectification of your personal data (i.e the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you and taking into account the purposes of the processing, the right to have incomplete personal data completed);|
|(c)||erasure of your personal data;|
|(d)||restriction of the processing of your personal data (i.e the marking of stored personal data with the aim of limiting their processing in the future);|
|(e)||right to object to the processing of your personal data (i.e the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on satisfying the legitimate interests pursued by us. Should this right be exercised, we shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims);|
|(f)||where relevant, right to request the portability of your personal data (i.e you are allowed to receive personal data concerning you which you have provided to us on the basis of the aforementioned purposes in a structured, commonly used, machine-readable format, and to transmit it to another controller);|
|(g)||right to obtain from us a copy of, or access to, any balancing test that has been conducted in relation to the processing of personal data based on our legitimate interests].|
You have also the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, or of an alleged infringement of the GDPR (the supervisory authority is the “Commission Nationale pour la Protection des Données” in Luxembourg).