Privacy Policy

Last updated: 28 June 2025

This Privacy Policy explains how PNP INVESTMENT MANAGEMENT Sàrl, acting on behalf of PNP Investment Partners S.F., processes personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable Luxembourg data protection laws. It applies to all clients, prospective clients, and users of our products, platforms, and websites, including subsidiaries or affiliates where applicable. It should be read together with our Cookie Policy.

1. Data Controller / Who We Are

PNP INVESTMENT MANAGEMENT Sàrl is a société à responsabilité limitée incorporated in Luxembourg. We are an investment and asset management company providing advisory, fund administration and ohter related management services. This policy applies to all entities under PNP INVESTMENT MANAGEMENT Sàrl, including any subsidiaries or international branches, unless stated otherwise.

For all data privacy inquiries, please contact:
compliance@pnpfund.lu

2. Types of Personal Data We Collect

We may collect and process the following categories of personal data:

  • Identification information (e.g., name, address, phone number, email)
  • Financial information (e.g., bank account details, investment preferences)
  • Regulatory and compliance information (e.g., KYC/AML data)
  • Login or account credentials
  • IP address and device/browser information
  • Behavioral data (e.g., pages visited, services used, interactions)
  • Marketing and communication preferences

We collect this information directly from you, through our website, applications, communications, or from third-party providers and public sources.

3. Purpose and Legal Basis for Processing

Your personal data is processed for the following purposes and legal bases:

  • To provide and administer our products and services (performance of a contract)
  • To comply with legal and regulatory obligations (legal obligation)
  • For legitimate interests such as business improvement, security, analytics, and fraud prevention
  • For marketing and promotional purposes (with your consent, where applicable)

4. How We Share Your Data

We may share your data with trusted third parties including:

  • Subsidiaries and affiliated companies
  • Service providers such as IT, cloud hosting, legal or financial advisors
  • Regulatory bodies, law enforcement, or government authorities
  • Business partners (e.g., in the event of a merger, acquisition, or sale)

All third parties are required to adhere to appropriate data protection standards.

5. International Transfers

Where your personal data is transferred outside the European Economic Area (EEA), we ensure it is protected by appropriate safeguards such as the Standard Contractual Clauses approved by the European Commission.

6. Data Retention

We retain personal data only as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, or contractual obligations, in accordance with Luxembourg law.

7. Your Rights

Under applicable data protection laws, you may have the following rights:

  • Right to access the personal data we hold about you
  • Right to correct or update inaccurate data
  • Right to request deletion (“right to be forgotten”)
  • Right to object to processing or request restriction
  • Right to data portability
  • Right to withdraw consent (if processing is based on consent)
  • Right to lodge a complaint with the Luxembourg data protection authority (CNPD) or other relevant supervisory authority

To exercise your rights, please contact us at compliance@pnpfund.lu.

8. Data Security

We implement appropriate technical and organizational security measures to protect your personal data from unauthorized access, loss, misuse, or disclosure.

9. Cookies and Tracking Technologies

Our use of cookies and similar technologies is described in our Cookie Policy. You can manage your preferences using the cookie settings tool available on our website footer.

10. Updates to This Privacy Policy

We review and update this Privacy Policy regularly. Any significant changes will be communicated to you, and the latest version will always be available on our website.

11. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at:

PNP INVESTMENT MANAGEMENT Sàrl
Parc d’Activites Capellen, 8308, Luxembourg, Luxembourg
Email: compliance@pnpfund.lu