Privacy Notice – GreenTech

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?

Green Tech has put in place appropriate physical and technical measures to safeguard the Personal Data Green Tech collects in connection with Green Tech’ services. In addition, Green Tech limit access to Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Personal Data on Green Tech’ instructions and are subject to a duty of confidentiality. However, please note that although Green Tech take appropriate steps to protect Personal Data no device, computer system, transmission of data or wireless connection is completely secure and therefore Green Tech cannot guarantee the absolute security of Personal Data.

8. INTERNATIONAL TRANSFER OF DATA

The Personal Data that Green Tech collect may be stored and processed in the European Economic Area (“EEA”) or transferred to, stored at or otherwise processed outside the EEA. Where Personal Data is transferred outside the EEA Green Tech will take all steps reasonably necessary to ensure that the Data is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located. Appropriate transfer agreements and mechanisms (such as the EU Model Clauses) will be put in place to help ensure that Green Tech third party service providers provide an adequate level of protection for Personal Data. Green Tech will only transfer Personal Data outside the EEA in accordance with applicable laws or where the Data Subject has given Green Tech consent to do so.

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

Green Tech retains Personal Data for as long as necessary to fulfil the purposes for which the Data has been collected as outlined in this Privacy Notice unless a longer retention period is required by law. Data is kept under regular review to ensure that it is not held longer than is strictly necessary, whilst taking account of Green Tech’ other regulatory obligations such as the requirement to retain evidence of anti-money laundering checks. When Personal Data is no longer required for the purpose it was collected or as required by applicable law, it will be deleted or in certain circumstances returned to the Data Subject in accordance with applicable law.

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

Green Tech will collect, store and process Personal Data in accordance with the Data Subject’s rights under the GDPR. Under certain circumstances the Data Subject has the following rights in relation to their Personal Data:

the right to request details of their Personal Data held by Green Tech and to request copies of such information;

where Green Tech’ use of Personal Data is based upon their consent, the right to withdraw such consent at any time;

the right in certain circumstances to request Green Tech to port (i.e. transmit) their Personal Data direct to another organisation;

the right to request Green Tech to rectify or update any Personal Data that is incorrect or complete;

the right to have Personal Data erased in certain specified circumstances;

the right to request Green Tech to stop processing their Personal Data and to only store such Data;

the right to object to specific types of processing of Personal Data, for example where it is being used for the purpose of direct marketing; and

the right in certain circumstances not to be subject to decisions being taken solely on the basis of automated processing (e.g. profiling).

11. HOW CAN A DATA SUBJECT ENFORCE THEIR RIGHTS?

In the event of a Data Subject wishing to enforce any of their rights under the GDPR then please use the contact details at section 14. A response to the request will be made without undue delay and no later than one month from receipt of such a request. Green Tech will not charge a fee for processing such a request. If a Data Subject is concerned that Green Tech have not complied with their legal rights under applicable Data Protection Laws, they may contact National Commission for Data Protection (https://cnpd.public.lu/en.html) which is the data protection regulator in Luxembourg. Non-Luxembourg Data Subject’s may contact their local data protection supervisory authority.

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

Green Tech’ websites, applications and products may contain links to other third-party websites that are not operated by Green Tech, and Green Tech website may contain applications that can be download from third parties. These linked sites and applications are not under Green Tech’ control and as such, Green Tech is not responsible for the privacy practices or the content of any linked websites and online applications. If a user chooses to access any third-party websites or applications, any Personal Data collected by the third party’s website or application will be controlled by the Privacy Notice of that third party. Green Tech strongly recommend that you take the time to review the privacy policies of any third parties to which you provide Personal Data.

13. CHANGES TO THIS PRIVACY NOTICE

Green Tech will update this Privacy Notice from time to time. Any changes will become effective upon posting the revised Privacy Notice on Green Tech’ website. Green Tech will provide notice to Data Subjects where any of the changes are material and, where required by applicable law, Green Tech will obtain your consent. Green Tech will provide this notice by e-mail or by posting notice of the changes on Green Tech’ website.

14. CONTACT Green Tech / FURTHER INFORMATION

If you have any questions concerning the content of this Privacy Notice, including any requests to exercise your legal rights, the relevant contact details are set out below. Contact details Email address: [ ] Postal address: [ ]