Privacy policy

The controller is Belem Capital Management S.à.r.l., 152 Boulevard de la Pétrusse, L-2330 Luxembourg, RCS Luxembourg B294643 ("Belem Capital", "we", "us").

For any question about this policy or about your personal data, please contact us at enquiries@belemcapital.com or by post at the address above.

We have not appointed a data protection officer, as we are not required to do so under Article 37 GDPR.

2.1 When you browse the website

Data: IP address, date and time of access, pages requested, browser type and version, operating system, referring website, and technical error data.

Purpose: to deliver the website, ensure its security and prevent misuse.

Legal basis: our legitimate interest in operating a secure website (Article 6(1)(f) GDPR).

Retention: server logs are kept by our hosting provider for a limited period, unless they are needed to investigate a security incident.

2.2 When you use the entry page

Data: the country of residence and investor category you select, the version of the declaration you accept and the date of acceptance.

Purpose: to restrict access to the website in accordance with the laws governing the distribution of financial products in the country you select, and to avoid asking you again on each visit.

Legal basis: compliance with our legal obligations (Article 6(1)(c) GDPR) and our legitimate interest in ensuring that the information on the website reaches only the investors for whom it is intended (Article 6(1)(f) GDPR).

Retention: this information is stored in your browser's local storage for 30 days and is not transmitted to us. You can delete it at any time from your browser settings.

To apply access restrictions, the country associated with your IP address may be determined at the time of your visit. Your IP address is not stored for this purpose.

2.3 Fonts and background video

The fonts and the background video used on this website are served from our own hosting infrastructure. Displaying them does not involve any connection to third-party servers.

2.4 When you contact us by email

Data: your name, email address, organisation, position, the content of your message and of any attachments, and any other information you choose to provide. Where your enquiry concerns a fund or another structure, we may also ask for your country of residence, your investor category and confirmation that you approached us on your own initiative, before sending you any information.

Purposes: to answer your enquiry; to manage our relationships with prospective investors, investors, partners, service providers and journalists; to verify, before providing information on a fund or structure, that you are eligible to receive it; and to keep records of our business correspondence.

Legal bases: steps taken at your request prior to entering into a contract (Article 6(1)(b) GDPR); compliance with our legal obligations, including record-keeping obligations and restrictions on the distribution of financial products (Article 6(1)(c) GDPR); and our legitimate interest in answering enquiries and developing our business relationships (Article 6(1)(f) GDPR).

Retention:

• correspondence with prospective investors, partners and other contacts that does not lead to a business relationship: up to 3 years after our last contact;
• correspondence relating to a business relationship: for the duration of the relationship and up to 10 years after the end of the financial year concerned, in accordance with Article 16 of the Luxembourg Commercial Code;
• correspondence with journalists: until you ask us to stop contacting you, and at the latest 3 years after our last contact.

2.5 Investor onboarding

The website does not allow you to invest or to subscribe to any fund or structure. Where you decide to invest, the identification and verification procedures required by anti-money laundering legislation are carried out outside the website, by the entities concerned, and are governed by the privacy notice provided with the relevant subscription or contractual documents. Data collected for these purposes is kept for 5 years after the end of the business relationship, in accordance with the Luxembourg Law of 12 November 2004 on the fight against money laundering and terrorist financing.

2.6 Persons presented on the website

The names, photographs, titles and biographies of the members of our team, governance bodies and partners are published with their agreement, in order to present the firm.

We do not use your personal data for automated decision-making, including profiling, within the meaning of Article 22 GDPR. We do not sell personal data.

Your personal data is accessible only to the members of our staff who need it. It may be disclosed to:

• our hosting provider, Lovable Labs Incorporated, and its sub-processors;
• our email and office software provider, Google (Google Workspace);
• the alternative investment fund manager, the administrators and the other service providers of a fund or structure, where your enquiry concerns that fund or structure;
• our professional advisers (lawyers, auditors), who are bound by confidentiality obligations;
• affiliated entities of Belem Capital Management S.à.r.l., where necessary to answer your enquiry;
• public authorities, courts and supervisory authorities, where required by law.

Our service providers act as processors on our instructions, under agreements that comply with Article 28 GDPR.

Some of our service providers, or their sub-processors, are located outside the European Economic Area, in particular in the United States. Transfers to the United States are made to recipients certified under the EU-U.S. Data Privacy Framework, on the basis of the European Commission's adequacy decision of 10 July 2023, or, failing that, on the basis of the standard contractual clauses adopted by the European Commission. Transfers to Switzerland and to the United Kingdom are covered by adequacy decisions of the European Commission.

You can obtain information on these safeguards by contacting us at the address in section 1.

Under the GDPR, you have the right to:

• access your personal data and obtain a copy of it;
• have inaccurate data rectified;
• have your data erased, where the conditions of Article 17 GDPR are met;
• restrict the processing of your data;
• receive your data in a structured, commonly used and machine-readable format, where the processing is based on a contract and carried out by automated means;
• object at any time, on grounds relating to your particular situation, to processing based on our legitimate interest, and object at any time to the use of your data for direct communications;
• withdraw your consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before the withdrawal.

To exercise these rights, contact us at enquiries@belemcapital.com. We will respond within one month, which may be extended by two months where necessary given the complexity or number of requests. We may ask you to confirm your identity.

You also have the right to lodge a complaint with the Commission nationale pour la protection des données (CNPD), 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg, cnpd.public.lu, or with the supervisory authority of your place of habitual residence or work.

We take appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Emails sent over the internet are not fully secure: please do not send us sensitive information by unencrypted email.

We may update this policy, in particular if the features of the website change. The date of the latest update is shown at the top of this page.