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Privacy policy

Dernière mise à jour : 19 octobre 2026

This privacy policy explains how Belem Capital Management S.à.r.l. processes personal data in connection with the website belemcapital.com and with the emails you send to us. It is provided in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR") and the Luxembourg Law of 1 August 2018 on the organisation of the National Commission for Data Protection.

Sommaire

  1. 1. Controller
  2. 2. Personal data we process, purposes, legal bases and retention periods
  3. 3. Recipients
  4. 4. Transfers outside the European Economic Area
  5. 5. Your rights
  6. 6. Security
  7. 7. Changes to this policy

1. Controller

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. Personal data we process, purposes, legal bases and retention periods

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.

3. Recipients

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.

4. Transfers outside the European Economic Area

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.

5. Your rights

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.

6. Security

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.

7. Changes to this policy

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.

152 Boulevard de la Pétrusse, L-2330 Luxembourg

investors@belemcapital.com

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This website is intended for professional, institutional and well-informed investors only. It does not constitute an offer, a solicitation or investment advice. Investments in on-chain strategies involve risks, including the loss of capital. See the legal notice and the disclaimer.

Avertissement

Intended audience. This website is published by Belem Capital Management S.à.r.l. ("Belem Capital"). It is intended exclusively for professional, institutional and well-informed investors, as defined for each country on the entry page, and is not directed at retail investors. Information in relation to Belem Capital is made available through this website to such investors only.

No offer, no advice. Under no circumstances should any material on this website be used or considered as an offer to sell, a solicitation of an offer to buy or a recommendation to subscribe to any security, fund unit or other financial instrument, or to enter into any service agreement, whether or not sponsored, managed or advised by Belem Capital. Nothing on this website constitutes investment, legal, tax or accounting advice.

Any such offer or solicitation can and will be made only by means of the offering documents of the relevant fund or structure, only in jurisdictions in which such an offer is lawful, and only to investors who meet the eligibility, suitability and sophistication requirements set out in those documents. Prospective investors should obtain independent professional advice before making any investment decision.

European Economic Area. This website is not intended as marketing of any fund in any member state of the European Economic Area within the meaning of Directive 2011/61/EU on alternative investment fund managers (AIFMD). No marketing passport under that Directive is available for the fund presented on this website.

United States. This website is not directed at any person located in the United States or any U.S. person. Persons who access it do so on their own initiative and at their sole responsibility. No fund or interest presented on this website has been or will be registered under the U.S. Securities Act of 1933, as amended, under the securities laws of any state of the United States or under the U.S. Investment Company Act of 1940, as amended.

Other jurisdictions. Access to this website and to the structures it presents is restricted by law in certain jurisdictions. Specific conditions apply to visitors from Switzerland, the United Kingdom, Singapore, Hong Kong and Australia, as set out on the entry page, and access is not available from certain countries. Each visitor is responsible for ensuring that accessing this website, and any investment in a structure it presents, complies with the laws and regulations of their country of residence.

Risks. Investments in on-chain strategies, digital assets and alternative investment funds involve significant risks, including technological, smart contract, custody, counterparty, liquidity, regulatory and market risks, and may result in the loss of all of the capital invested. Past performance is not a reliable indicator of future results. There is no assurance that any investment objective will be achieved.

Information. The information on this website is provided as at its date of publication, may be summarised or incomplete, and may change without notice. Belem Capital does not undertake to update it. In case of inconsistency between this website and the offering or contractual documents of a fund or structure, those documents prevail. Use of this website is governed by the legal notice.

© 2026 Belem Capital Management S.à.r.l. · 152 Boulevard de la Pétrusse, L-2330 Luxembourg · RCS Luxembourg B294643 · contact@belemcapital.com