Privacy notice

1. INTRODUCTION

Green Tech is committed to protecting the privacy and security of the Personal Data that Green Tech holds. This notice is intended to explain how Green Tech collects, uses and protects your Personal Data.

2. WHO IS Green Tech

Green Tech is a Luxembourg based investment manager. Green Tech is committed to handling Personal Data fairly and lawfully and takes data protection obligations very seriously. Green Tech ensures that it processes Personal Data in compliance with applicable data protection laws, including without limitation, the General Data Protection Regulation 2016/679 (“GDPR”).

3. WHAT IS PERSONAL DATA AND WHAT DATA DOES Green Tech HOLD?

Green Tech define Personal Data as “data relating to living, identifiable individuals”. The information Green Tech collects and hold can be categorised as follows: Employees and Prospective Employees – includes, but is not limited to, contact details, identification information, bank account details, background checks, employment history, performance information, remuneration, healthcare and pension arrangements.

Clients and Prospective Clients – in relation to Green Tech’ individual clients, includes, but is not limited to, contact details, identification information, bank account details, background checks, transaction histories etc. For Green Tech’ corporate clients, includes but is not limited to the names, and contact details of the individuals Green Tech interact with together with background and identification information of Directors and Officers that Green Tech are required to collect for regulatory purposes. For Green Tech’ prospective clients, primarily includes names and contact details but if being on-boarded could also include other information as described above.

Service Providers, Suppliers and Contractors – the names and business contact details of the individuals Green Tech interact with at Green Tech service providers, suppliers and contractors together with background and identification information that Green Tech is required to collect.

Other Business Partners / Contacts (e.g. banks, brokers, registrars, lawyers, accountants, actuaries, regulators, investee companies, managing agents etc) – the names and business contact details of the individuals Green Tech interact with at these entities together with background and identification information that Green Tech is required to collect.

4. HOW IS PERSONAL DATA COLLECTED?

Green Tech uses different methods to collect Personal Data including the following: • personal details provided directly by employees, clients, suppliers & contractors and other business contacts; and

  • information from third parties and publicly available sources e.g. Companies House, Registrars and Background Check Providers.

It should be noted that the Green Tech website does not capture or record any Personal Data relating to website users/visitors.

5. HOW DOES Green Tech USE PERSONAL DATA?

The Personal Data Green Tech obtains and holds is used to enable Green Tech to:

  • provide investment, management and administration services to Green Tech’ clients;
  • fulfil Green Tech’ contractual and other obligations to employees, suppliers, contractors and other business partners; and
  • meet Green Tech’ legal and regulatory obligations.
    Under the GDPR a firm must have a legal basis / justification for processing data. In the vast majority of instances, Green Tech will have one of the following justifications:
  • Performance of a contract;
  •  Compliance with legal obligations; and
  • Legitimate business interests – in this instance the processing must be “necessary” and must balance the interests of the controller with the rights of the individual. Green Tech may combine the Personal Data that Green Tech collects from Data Subjects with information obtained from other sources to the extent permitted by law.

It is important that the Personal Data Green Tech holds is accurate and current and therefore the Data Subject should advise Green Tech as soon as possible in the event of any changes.

6. TO WHOM DOES Green Tech DISCLOSE PERSONAL DATA?

Green Tech will only use a Data Subject’s Personal Data for Green Tech’ internal business purposes. This includes the provision of marketing related correspondence to the Data Subject on Green Tech’ products and services. Green Tech does not sell any Personal Data to third parties and Green Tech does not share Personal Data with third parties for the third parties’ marketing purposes.

However, Green Tech may need to disclose Data strictly on a need to know basis to Green Tech’ service providers, contractors, suppliers and other parties such as banks, brokers, registrars, lawyers, accountants, actuaries and regulators.

7. WHAT DOES Green Tech DO TO KEEP PERSONAL DATA SECURE?

8. INTERNATIONAL TRANSFER OF DATA

9. DATA RETENTION – HOW LONG IS PERSONAL DATA STORED / KEPT?

10. ACCESSING PERSONAL DATA AND OTHER RIGHTS THAT A DATA SUBJECT HAS

11. HOW CAN A DATA SUBJECT ENFORCE THEIR RIGHTS?

12. THIRD-PARTY LINKS AND PRODUCTS ON Green Tech’ SERVICES

13. CHANGES TO THIS PRIVACY NOTICE

14. CONTACT Green Tech / FURTHER INFORMATION