Information about Private Wealth Square

Private Wealth Square S.à r.l

R.C.S Luxembourg B 274310

Registered office: 6, place Winston Churchill, L-1340 Luxembourg, Luxembourg

Telephone number: +352 26 10 47 30

Contact: contact@pw-square.com

VAT Number: LU34594603

Authorisation: B 10149499/0

Disclaimer

The content of this website is set for information purpose only and may be changed, improved or updated without prior notice. Private Wealth Square is not responsible for errors or omissions in the content of this website or for damages arising from the use or performance of this website under any circumstances. Private Wealth Square cannot guarantee the full accuracy, reliability, currency or integrity of the information contained on this website, or the websites and webpages which links are provided. Your use of our website is at your own risk.

Intellectual Property

This website and its content are protected by intellectual property rights which belong to Private Wealth Square. Any reproduction or representation, in whole or in part, of any content of this website, without the express written consent of Private Wealth Square is strictly prohibited. All rights reserved.

Data Privacy Policy

Preliminary considerations

This data privacy policy (the “Data Privacy Policy” or “Policy) intends to provide you with a clear and comprehensive information, as per the requirements set out in the articles 13 and 14 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”).

Wherever this Policy refers to “you” or “your”, this means you, as individual being the “data subject” under GDPR, or any person connected to you namely any authorised person, anyone who deals with us for you (including but not limited to attorneys, external asset managers, trustees, representatives, recruitment agencies) and other associated people (including but not limited to partners, directors, beneficial owners of companies).

1. Who we are

Private Wealth Square S.à r.l., acting as data controller (hereinafter “Private Wealth Square”, “we”, “us”, or “our”) collects data to operate effectively and provide you with the best level of services. Therefore, at Private Wealth Square we are highly committed to safeguarding your privacy. We have developed this data privacy policy that covers how we may collect, process, share, protect and retain your personal data and your rights regarding it.

2. What data do we collect about you?

To provide its services, Private Wealth Square needs to collect and process personal data about you. The personal data we collect depends on the context of your interactions with Private Wealth Square and the choices you make including the services which are provided to you.

Note that you can choose what personal data you allow us to collect. When you are asked to provide personal data, you may decline. If you choose not to provide data necessary to provide the service, we may not be able to provide the service.

3. What categories of data we collect and process?

The personal data we collect, and process can include the following, but is not limited to:

• Identification data: we collect data about you such as your first and last name, email address, postal address, phone number, and other similar contact data, date and place of birth, gender, country, and preferred language;

• Electronic identification data: we use Cookies to collect data on how you use our website and view our marketing emails. More information is available when visiting our [Cookies policy];

• Business contact data: we collect data about you such as job function, job title, department, organisation name, size and location, and whether or not you are acting on behalf of a client;

• Financial data: we collect your financial data, such as banking details, if needed to take/make payments or fulfil contractual obligations or associated purposes;

• Contractual data: any information provided by the data subject allowing to Private Wealth Square to perform its contractual duties;

• Employment and recruitment data: In the context of an application for employment at Private Wealth Square, we collect data such as your name, your address, your phone number, your email address, experience, education, job skills and other information contained on your curriculum vitae and/or your cover letter or email.

Further to the categories of data mentioned above, Private Wealth Square guarantees that, except to the limited extent that may be necessary for the performance of its contractual duties toward the client, we neither request nor collect special categories of data (i.e., personal information specifying criminal offences/convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the data subject).

4. How do we collect your data?

This Data Privacy Policy applies to personal data, which is data that Private Wealth Square collects from you and other third parties that specifically identifies you as an individual. Private Wealth Square may collect your personal data in various manners, such as:

• Personal data that we collect when you consent to the use of different categories of cookies by visiting our website. For more information, please refer to our [Cookies Policy]. However, regardless of which cookies you have consented to use, all data transmitted are anonymised;

•  Personal data that we collect when you do business with Private Wealth Square or when you interact with us: we may collect and process your data when you conduct business with us. “Personal data” means information relating to an identified or identifiable natural person that Private Wealth Square receives on behalf of the individual or data subject himself/herself/itself. Examples of categories of such personal data can be found in the previous section;

• Personal data we obtain from other sources: we also may periodically obtain both personal and non-personal information about you from Private Wealth Square’s business partners or other third-party sources where they are legally authorised to share such information with us, and add it to the information we already hold about you, such as, but not limited to:

– Updated business address information;
– Identification data;
– Financial information;
– Contractual information.

5. What are the purposes for the collection and processing of your data?

We use or may use your personal data based on the following purposes (or as otherwise described at the point of collection) associated with a lawful basis under the GDPR as further detailed below:

• To provide you with the service you have requested. This processing is necessary for the performance of a contract with the data subject;

• To provide you with information, access to resources or other services that you have requested from us on behalf of your organisation. This processing is necessary for the performance of a contract with the data subject;

• To send you client service-related communications (marketing). This processing is necessary for the purposes of the legitimate interests pursued by the controller;

• To deal with communications that you send to Private Wealth Square and responding to your queries, requests and complaints. This processing is necessary for (i) the performance of a contract to which the data subject is party or (ii) in order to take steps at the request of the data subject prior to entering into a contract and (iii) to comply with a legal obligation;

• To fulfil our legal obligations namely in respect to AML/KYC. This processing is necessary to comply with a legal obligation;

• To promote our events via pictures and videos disclosed on our social medias. This processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party;

• To manage the infrastructure and business operations of Private Wealth Square and to comply with internal policies and procedures.
This processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party;

• To comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities. This processing is necessary for compliance with a legal obligation;

• To process and address your application for employment at Private Wealth Square. In such context, we use such personal data solely for recruitment purpose, for consideration of your candidacy for employment, to communicate with you and to generate related correspondence, including offer letters and employment contracts. Such personal data may also be used, subject to applicable laws, to conduct necessary background checks for compliance and other employment related purposes (including the assessment of your profile in view of the conclusion of a potential employment contract, to the extent permitted by applicable laws and regulations);

• We may contact you by mail, telephone, fax, video conference, email or other electronic messaging service to notify you about special events, new features or other information that may be of interest to you in accordance with your interaction with Private Wealth Square. Where required by applicable laws, your prior consent will be obtained before sending you direct marketing and you may object or opt out of receiving marketing messages from Private Wealth Square.
 
To be noted that Private Wealth Square does not in any way sell, lease or rent your information to third parties.

6. With which third parties do we share your personal data?

Your personal data are intended for Private Wealth Square but may be shared with third parties in certain circumstances, such as:

• AML/KYC (third parties such as lawyers, notaries, domiciliation agents and banks);

• Service providers: we may disclose/transfer your data with third parties that we refer as service providers solely to the extent necessary to enable such service providers to provide services to Private Wealth Square and to assist us in providing services to you. Private Wealth Square’s policy is to maintain contracts with all third parties with whom we disclose/transfer personal information that restrict their access, use and disclosure of personal data. Service providers must, in fact, abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose;

• Third parties: we may disclose/transfer your data with/to third parties such as administration and public authorities, banking institutions, notaries, domiciliation agents and to professional advisors, auditors, fiduciary, tax and accounting services providers of Private Wealth Square;

• Compliance with applicable laws and regulations: we will access, transfer, disclose and preserve personal data to comply with applicable laws or respond to subpoenas, court orders or other valid legal process, for reasons relating to national security, to defend against legal claims, to protect the rights and safety of Private Wealth Square, Private Wealth Square’s clients, employees or others. This may involve the sharing of your data with law enforcement, government agencies, courts and other organisations;

• Consent: we may share your data in other ways and for new purposes if you have asked us to do so and have consented to such sharing;

• Should these recipients are be located inside or outside the European Union, it is to be noted that your personal data will not be transferred to any country located outside the European Union that does not provide an equivalent level of protection in relation to data protection as the European Union, unless:

– You gave us prior authorisation to do so;

– If specific measures, such as the most up to date Standard Contractual Clauses (SCCs), have been signed, or if the relevant companies have adopted binding corporate rules, ensuring that the of the applicable data protection law have been fulfilled.

Should you wish more information on the latter, please let us know by contacting using the details provided in the section entitled “How can you contact us” of this Policy.

7. What are your rights?

Private Wealth Square seeks to ensure that you can exercise your rights at any time. Private Wealth Square will address any request within the limits of its technical and organisational means.

Your rights include:

Access: You have the right to access your personal data and to request a copy of the latter.

Rectification: You have the right to request the rectification of incomplete or inaccurate personal data that we may process about you.

Erasure: You have the right to request the erasure of the personal data that we process about you. If at any time you decide you do not want us to retain any personal data we collected from you, you may request we delete your data.

Restriction: You have the right to restrict our processing of your personal data in situation where, for example, you believe such data to be inaccurate, processing unlawful or that we no longer need to process such data for a particular purpose.

Portability: You have the right to have your personal data transmitted directly from us to another controller only when you have asked us to do so and have consented to such sharing, and when technically feasible.

Objection: Where the legal basis for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your situation.

Withdrawing consent: If you have provided your consent as a legal basis for our processing of your personal data, you have the right to withdraw your consent at any time, free of charge.

Complaint: You have the right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”), where you believe that your data is being processed in a way that does not comply with GDPR. The CNPD can be contacted as follows:

Address: 15, Boulevard du Jazz, L-4370 Belvaux
Telephone: (+352) 26 10 60 -1
Email: info@cnpd.lu
Website: https://www.cnpd.lu

Should you wish to exercise any of these rights, except for the last one for which the CNPD can be contacted directly, please contact us as per the details provided in the section entitled “How can you contact us” of the Policy.

Please be aware that these rights are not always absolute and there may be some situations in which, technically or legally, Private Wealth Square may not be able to comply with your request.

8. How do we protect your data?

Private Wealth Square acknowledges your trust and is committed to protecting the data you provide to us. We maintain appropriate organisational, physical and technical security measures (including with respect to personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of personal data) to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of personal data.

While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of Internet as an open global communications vehicle and other risks factors, we cannot guarantee that any information, during transmission or while sored on our system, will be absolutely safe from intrusion by others, such as hackers.

Private Wealth Square pays a particular attention to work from home ethics. We avoid any hard copy to be taken at home and require from our employees that any task requiring the use of hard copies to be done from the office.

9. How long do we keep your data?

Private Wealth Square will only retain your personal data:

• For as long as it is necessary for the purpose or purposes for which it was intended;

• For the purposes of performing or fulfilling a contractual obligation with you or the organisation that you represent and, therefore, legitimate business purposes;

• For as long as it is necessary for the purpose of addressing your employment application and any query that may be raised in relation to your application’s process;

• For as long as required or permitted by law.

10. How can you contact us?

If you have any questions about our use of your personal data or regarding this Data Privacy Policy, please contact us as follows:

By sending an email at: contact@pw-square.com

or, by writing to us at:

Private Wealth Square S.à r.l
6, Place Winston Churchill
L-1340 Luxembourg
Grand Duchy of Luxembourg

11. How do we amend this Data Privacy Policy?

We reserve the right to amend this Data Privacy Policy from time to time to reflect changes in the law, our data collection and used practices, and to ensure it is accurate, complete and up to date*. You are advised to check this Data Privacy Policy from time to time.

* Last update on 01/08/2023

Cookie Policy

This Cookie Policy provides you, as user of our website, useful information about cookies, what cookies we use and the purpose of using tem.

What are cookies?

Cookies are small text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers.

What categories of cookies do we use and why?

Essential cookies

Essential cookies are necessary for our website to function and cannot be switched off. These cookies are set by default and cannot be disabled.

Functional cookies

Functional cookies enable our website to provide enhanced personalisation and functionality in accordance with your choice. As illustration, these cookies may enable us to recognise you as returning visitor to our website.

What specific cookies do we use and why?

The below list provides you with useful details on the specific cookies we use. Cookies (not mentioned in this list) may be added to our website, from time to time, by our developers or when we install additional third-party software or add new functionalities to our website. In such context, we will keep this list up to date on a best effort basis.

Cookies we set:

COOKIECONSENT. This cookie is automatically created when you visit our website, our server uses this to identify your session on our website which is generally used for temporary data storage.

Third Party Cookies:

The following third party services are used on our website and you should access websites and cookies policies of these third parties to obtain information over the cookies they use when you navigate our website:
– Considering that social media share buttons and plugins are used in our website, some cookies associated with these social media, such as LinkedIn, may be used to enhance your profile on their website or contribute to the data they hold for the purposes described in their respective cookies or privacy policies.

How can you withdraw your consent or change your cookies settings?

You can withdraw your consent to the use of cookies in our website, at any time, by deleting the cookies using your internet browser settings. These settings are usually found in the “preferences” or “options” menu of your internet browser. However, please note that this action may not enable you to enjoy the best browsing experience in our website.

More information about cookies?

More useful information about cookies can be found at:

http://www.allaboutcookies.org

In this website, you will find additional useful information about cookies and details on how to delete cookies from your device.

Contact us

If you have any questions about our Cookie Policy or the use of cookies in our website, please contact us.

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