1. Introduction
Light Blue Compass S.à r.l. (“Light Blue Compass”, “LBC”, “we”, “us” or “our”) respects your
privacy and is committed to protecting personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and applicable Luxembourg data-protection law.
This Privacy Policy explains how we collect, use, disclose, retain and protect personal data when you:
- visit our website at www.lightbluecompass.lu;
- contact or communicate with us;
- interact with us in a professional or business capacity; or
- otherwise provide personal data to us in connection with our activities.
This Privacy Policy should be read together with our Cookie Policy, Legal Notice & Website Terms and Website Disclaimer.
Where personal data is processed in connection with a particular investment vehicle, mandate, transaction or other arrangement for which separate privacy information is provided, that specific privacy information should also be read and will apply to the relevant processing.
2. Data Controller
The controller responsible for the processing of personal data described in this Privacy Policy is:
Light Blue Compass S.à r.l.
16 Avenue Pasteur
L-2310 Luxembourg
Grand Duchy of Luxembourg
Registered with the Luxembourg Trade and Companies Register (Registre de Commerce et des Sociétés) under number B300423.
Email: info@lightbluecompass.lu
For questions concerning this Privacy Policy, our processing of personal data or the exercise of your data-protection rights, please contact us using the details above.
3. Personal Data We May Collect
Depending on the nature of your interaction with us, we may process the following categories of personal data.
3.1 Contact and professional information This may include:
- your name;
- professional title or position;
- company, organisation or employer;
- professional or business address;
- email address;
- telephone number; and
- other contact information you choose to provide.
3.2 Correspondence and communications
Where you contact or communicate with us, we may process:
- the contents of emails, letters or other communications;
- documents or information you provide to us;
- records of communications with you; and
- information reasonably necessary to respond to or follow up on the relevant matter.
3.3 Professional and business relationship information
Where you interact with us in a professional or business capacity, we may process information relating to:
- your professional role or responsibilities;
- your organisation or business;
- your relationship with an investment vehicle, company, adviser, service provider, counterparty or other organisation;
- meetings and professional communications; and
- information relevant to the establishment, administration or management of our
professional relationship with you.
3.4 Technical website information
Our website is an informational corporate website and does not use analytics, advertising, behavioural tracking or profiling technologies.
Limited technical information may nevertheless be processed automatically where necessary for the secure hosting and operation of the website. This may include:
- IP address;
- browser and device information;
- date and time of access; and
- technical or security logs.
Such information is used solely for technical, operational and security purposes and is not
used to analyse individual browsing behaviour or create user profiles.
4. Information Obtained from Other Sources
We may occasionally receive professional or business contact information from sources other than directly from you, including:
- your employer, organisation or professional associates;
- investment vehicles or companies with which you are associated;
- professional advisers;
- service providers;
- counterparties;
- public registers; and
- publicly available professional or corporate sources.
Where we obtain personal data from such sources, we process it only where we have a lawful basis to do so.
5. How and Why We Use Personal Data
We process personal data only where we have a lawful basis under the GDPR.
5.1 Responding to enquiries and communications
We may process personal data in order to:
- respond to enquiries;
- provide information requested from us;
- arrange meetings or calls;
- consider potential engagements or business relationships; and
- communicate with you generally.
Legal basis: our legitimate interests in managing professional communications and business relationships and, where relevant, taking steps at your request prior to entering into a contract.
5.2 Managing professional and business relationships
We may process personal data in order to:
- establish and maintain professional relationships;
- administer engagements and mandates;
- coordinate with professional advisers and service providers;
- manage corporate and governance matters;
- organise meetings and communications; and
- maintain appropriate professional and business records.
Legal basis: performance of a contract or steps taken prior to entering into a contract, compliance with legal obligations, and our legitimate interests in properly administering our activities and professional relationships.
5.3 Legal, regulatory and compliance purposes
Where appropriate, we may process personal data in order to:
- comply with applicable legal and regulatory obligations;
- maintain corporate, accounting, tax or compliance records;
- conduct appropriate due-diligence or compliance procedures;
- respond to lawful requests from courts, regulators or public authorities;
- establish, exercise or defend legal claims; and
- protect our legal rights and interests.
Legal basis: compliance with legal obligations and our legitimate interests in managing risk, maintaining appropriate governance and protecting our legal rights.
5.4 Website operation and security
Limited technical information may be processed in order to:
- operate and maintain the website;
- protect the security and integrity of our website and systems;
- detect or prevent unauthorised access, cyber threats or abuse; and
- diagnose technical problems.
Legal basis: our legitimate interests in operating and maintaining a secure website and information systems.
5.5 Whether you are required to provide personal data
You are not required to provide personal data merely in order to browse our website.
Where you contact us, certain information, such as your contact details and the information necessary to understand your enquiry, may be required in order for us to respond.
In other circumstances, the provision of certain personal data may be necessary in order to enter into or perform a contractual or professional relationship or to comply with applicable legal or regulatory requirements. If such information is not provided, we may be unable to respond to a request, establish or continue the relevant relationship, or comply with the applicable requirement.
6. Our Legitimate Interests
Where we rely upon legitimate interests as a lawful basis, those interests may include:
- operating and administering Light Blue Compass;
- communicating with clients, prospective clients and professional contacts;
- maintaining professional and business relationships;
- protecting our website, systems and information;
- maintaining appropriate business and corporate records;
- managing legal, operational and reputational risks; and
- establishing, exercising or defending legal rights.
We rely on legitimate interests only where we consider that those interests are not overridden by your rights and freedoms requiring the protection of personal data.
7. Disclosure of Personal Data
We do not sell personal data.
Where reasonably necessary and appropriate, personal data may be disclosed to categories of recipients including:
- investment vehicles, companies or other entities with which Light Blue Compass is professionally involved;
- professional advisers, including lawyers, accountants, auditors, tax advisers and consultants;
- alternative investment fund managers, administrators, depositaries, banks and other financial or professional service providers;
- corporate and administrative service providers;
- IT, hosting, cybersecurity, email, communications and other technology service providers;
- counterparties and other persons involved in a relevant professional matter or transaction; and
- regulators, supervisory authorities, governmental bodies, tax authorities, courts or law-enforcement authorities where required or permitted by law.
Where a service provider processes personal data on our behalf, we require such processing to be carried out in accordance with applicable data-protection
requirements.
8. International Transfers
Because our professional activities may involve international clients, investors, counterparties, advisers, service providers and other business contacts, personal data
may in some circumstances be transferred to or accessed from countries outside the
European Economic Area (“EEA”).
However, because our professional activities may involve international counterparties, advisers or service providers, personal data may in some circumstances be transferred outside the EEA.
Where such a transfer occurs, we will ensure that it is made in accordance with applicable data-protection law, including, where appropriate, through:
- a European Commission adequacy decision;
- European Commission-approved Standard Contractual Clauses;
- another safeguard recognised under Article 46 GDPR; or
- another lawful transfer mechanism or applicable derogation permitted by the GDPR.
You may contact us at info@lightbluecompass.lu if you require further information regarding the safeguards applicable to a particular transfer.
9. Retention of Personal Data
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and thereafter for such period as may be required or appropriate to comply with legal, regulatory, accounting, contractual, professional or limitation requirements.
The appropriate retention period depends upon the nature of the information and the context in which it is processed.
In particular:
- general enquiries and correspondence may be retained for as long as reasonably
necessary to respond to and follow up the relevant matter;
- professional and business relationship information may be retained for the duration of the relevant relationship and for an appropriate period thereafter;
- corporate, governance and compliance records may be retained for the period required by applicable law or reasonably necessary to evidence decisions, appointments, transactions and compliance; and
- technical and security information will be retained only for the period reasonably necessary for operational, security or diagnostic purposes.
Where information is relevant to an actual or reasonably anticipated dispute, investigation or legal claim, it may be retained until the matter is finally resolved and any applicable limitation periods have expired.
10. Security of Personal Data
We take appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or other unlawful processing.
Such measures may include, where appropriate:
- access controls;
- authentication and password protections;
- secure IT and communications systems;
- appropriate data-storage arrangements;
-confidentiality obligations;
- cybersecurity protections; and
- appropriate controls over service providers with access to personal data.
No method of transmission over the internet or electronic storage system can, however, be guaranteed to be completely secure.
11. Your Data-Protection Rights
Subject to the conditions and limitations contained in applicable data-protection law, you may have the following rights in relation to personal data concerning you.
Right of access
You may request confirmation as to whether we process personal data concerning you and, where applicable, obtain access to that data and information concerning its processing.
Right to rectification
You may request the correction of inaccurate personal data or the completion of incomplete data.
Right to erasure
In certain circumstances, you may request the deletion of personal data concerning you.
This right is subject to exceptions, including where continued processing is necessary to comply with legal obligations or to establish, exercise or defend legal claims.
Right to restriction
In certain circumstances, you may request restriction of the processing of your personal data.
Right to object
Where processing is based upon our legitimate interests, you may object to such processing on grounds relating to your particular situation.
Where personal data is processed for direct-marketing purposes, you may object to such processing at any time.
Right to data portability
Where the applicable legal requirements are satisfied, you may have the right to receive
personal data you have provided to us in a structured, commonly used and machine-
readable format and, where technically feasible, to request that it be transmitted to
another controller.
Right to withdraw consent
Where we rely upon your consent as the lawful basis for processing, you may withdraw that consent at any time.
Withdrawal of consent does not affect the lawfulness of processing undertaken before the
withdrawal.
Exercising your rights
To exercise any applicable data-protection right, please contact:
info@lightbluecompass.lu
We may request appropriate information to verify your identity before acting upon a
request.
12. Automated Decision-Making and Profiling
Light Blue Compass does not use personal data collected through this website for automated decision-making or profiling which produces legal effects concerning an
individual or similarly significantly affects an individual within the meaning of Article 22 GDPR.
13. Cookies
The Light Blue Compass website is an informational corporate website.
We do not use cookies or similar technologies for:
- website analytics;
-advertising or marketing;
- behavioural tracking;
- profiling; or
- monitoring users across websites or services.
The website may use only strictly necessary technical cookies where required for the secure and proper operation of the website.
Further information is available in our Cookie Policy.
14. Third-Party Websites
Our website may contain links to websites operated by third parties.
Light Blue Compass is not responsible for the privacy, security or data-processing practices of third-party websites.
Users should review the privacy information applicable to any third-party website before
providing personal data to that third party.
15. Children
Our website and the services described on it are intended for professional and business
users and are not directed at children.
We do not knowingly seek to collect personal data from children through this website.
16. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our activities, website, service providers, legal requirements or data-processing practices.
The current version will be published on this page together with the date of the most
recent update.
17. Contact Us
For questions concerning this Privacy Policy, the processing of personal data by Light Blue Compass or the exercise of your data-protection rights, please contact:
Light Blue Compass S.à r.l.
16 Avenue Pasteur
L-2310 Luxembourg
Grand Duchy of Luxembourg
Email: info@lightbluecompass.lu
18. Complaints to the CNPD
If you have concerns regarding the manner in which Light Blue Compass processes your personal data, we encourage you to contact us first so that we can consider and, where appropriate, address the matter.
You also have the right to lodge a complaint with the Luxembourg data-protection supervisory authority:
Commission nationale pour la protection des données (CNPD)
15 Boulevard du Jazz
L-4370 Belvaux
Grand Duchy of Luxembourg
Email: info@cnpd.lu
Further information concerning data-protection rights and the CNPD's complaints
procedure is available on the CNPD's official website.
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