Privacy Policy
How AEQ MANAGEMENT Sàrl, acting as management company of AEQUITAS SECURITISATION, collects, uses and protects your personal data in accordance with the GDPR and applicable Luxembourg law.
1. Data Controller
The data controller in respect of personal data collected through this website and in the context of the AEQUITAS Note Programme is AEQ MANAGEMENT Sàrl, a société à responsabilité limitée incorporated under Luxembourg law (Luxembourg Trade and Companies Register No. B302489), acting as management company of AEQUITAS SECURITISATION, Securitisation Fund (RCSL O137), with registered address at 2-4, Parc d'Activités, L-8308 Capellen, Grand Duchy of Luxembourg.
For all data protection enquiries please contact us at: info@aequitas.io
2. Legal Framework
This policy is issued in accordance with Regulation (EU) 2016/679 (the "GDPR") and the Luxembourg law of 1 August 2018 on the organisation of the National Data Protection Commission and the general data protection framework (the "DPL").
3. Data We Collect
Website visitors: IP address, device and browser information (collected automatically), pages visited, time on site, and cookie preferences.
Enquiries and expressions of interest: full name, email address, professional role, organisation, country of residence, and message content.
Investors and Noteholders: identity documents (passport, national ID), proof of address, source of funds and wealth documentation, tax identification numbers (for CRS and FATCA compliance), bank account details, beneficial ownership information (under the Luxembourg RBO Law of 13 January 2019), investment amounts, and communication records.
We do not intentionally collect special categories of personal data such as health data, racial or ethnic origin, political opinions or religious beliefs.
4. How We Use Your Data
Operating and improving this website — on the basis of our legitimate interests.
Responding to enquiries and expressions of interest — on the basis of legitimate interests and pre-contractual steps.
Managing investor subscriptions and redemptions — performance of contract.
Compliance with AML/KYC obligations under Luxembourg law (including AMLD 5 and AMLD 6) — legal obligation.
CRS and FATCA reporting to tax authorities — legal obligation.
RBO (Register of Beneficial Owners) registration — legal obligation.
Sending investor communications and reports — legitimate interests or consent.
Managing the tokenisation platform (DigiShares) — performance of contract.
Fraud prevention and cybersecurity — legitimate interests.
5. Data Sharing
Service providers: domiciliation agents, fund administrators, custodians, auditors, legal advisers, and other professional service providers engaged by AEQ MANAGEMENT Sàrl.
DigiShares A/S: as white-label tokenisation platform provider, acting as a data processor under a data processing agreement.
Luxembourg Stock Exchange: for Notes admitted to trading on the Euro MTF.
Euroclear and Clearstream: for global notes held in clearing systems.
Luxembourg tax and regulatory authorities: where required by CRS, FATCA, or AML/KYC law.
Law enforcement and courts: where required by a binding legal obligation.
We do not sell your personal data to third parties and do not use it for advertising purposes.
6. Data Retention
AML/KYC records: minimum 5 years following end of the business relationship, as required by Luxembourg AML/CFT law.
Tax reporting records (CRS/FATCA): as required by applicable tax laws.
Investor communications and subscription records: duration of the Notes plus applicable limitation period (up to 10 years under Luxembourg law).
Website enquiry data: up to 2 years from last contact.
Cookie data: as set out in the Cookie Policy.
7. Your Rights
Under the GDPR you have the right to: access your personal data; rectify inaccurate or incomplete data; request erasure (subject to legal retention obligations); restrict or object to processing; data portability; and withdraw consent where processing is based on consent.
To exercise any of these rights, please contact us at info@aequitas.io. We will respond within one month.
You have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD), the Luxembourg data protection supervisory authority, at www.cnpd.lu.
8. International Transfers
AEQ MANAGEMENT Sàrl is established in Luxembourg, a Member State of the European Union. Where data is transferred outside the EEA (for example, in the context of FATCA reporting to US authorities), we ensure appropriate safeguards are in place in accordance with Chapter V of the GDPR, such as Standard Contractual Clauses approved by the European Commission.
9. Changes to This Policy
We may update this Privacy Policy from time to time. The date at the top of this page indicates when the policy was last revised. Where changes are material, we will notify affected individuals by appropriate means. The current version is always available on this page.
This document is provided for information purposes only and does not constitute legal advice. AEQUITAS SECURITISATION is a securitisation fund established under the Luxembourg Law of 22 March 2004, managed by AEQ MANAGEMENT Sàrl (RCSL B302489). For legal or compliance queries, please contact info@aequitas.io.