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Privacy Policy

This Privacy Policy governs the manner in which we, Funds Avenue S.A., collect, use, maintain and disclose information collected from clients and/or users (“User” or “Users”) of our website, mobile applications or any other services (the “Services”).

Compliance with Data Protection Law

We acknowledge and undertake to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and any other national applicable laws or regulations governing the processing of personal data in the framework of the Services.

Personal identification information

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our website, register on the website, fill out a form, sign a contract, purchase a product and in connection with other activities, use applications and benefit from Services proposed by us. Users may be asked for, as appropriate, name, date of birth, email address, mailing address, phone number, etc.

Non-personal identification information

We may collect non-personal identification information about Users whenever they use our website or application or other online service. Non-personal identification information may include technical information about Users’ means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on our website, as well as further non-personal analytical data to improve customer experience, products and services.

Each User recognizes and accepts that the performance of the Services may depend on the collection and processing of personal identification information and non-personal identification information.

Web browser cookies

We may use « cookies » to improve the User’s experience of the Services. In that case, the User’s Internet navigator places cookies on his hard drive to gather a certain set of information used to customize the navigation in the framework of the Services, thus enabling certain unique functionalities. For further information, please consult our Cookies Policy.

How we use collected information?

Principally, personal and non-personal identification information is used to provide the Users with the Services and to insure a full efficiency of the Services they have registered for or they requested in any other manner.
In this framework, we may collect and use Users’ personal and non-personal identification information for the following purposes:
• To improve Services: Information Users provided will help us to respond to certain Users’ requests.
• To personalize User experience: We may use non-personal identification information to understand how Users as a group use our Services.
• To improve our website presence as well as other communication tools or tools for specific Services: We may use feedback that Users provide to improve our products and services.
• To send periodic emails and other text messages and/or notifications: We may use the email address or mobile phone number provided by Users to respond to inquiries, questions, and/or other requests. If Users decide to opt-in to our notification list, they will receive periodic information that may include company news, updates, related product or service information, private sales, information from our service providers on joint projects etc. (the “Periodic Information Service”). In case Users would like to unsubscribe from the Periodic Information Service, we include detailed unsubscribe instructions at the bottom of each such email or other text message.

How do we protect personal identification information?

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ personal identification information within the limits of our role with respect to the relevant Services (as certain specific services might be rendered by third parties).

Sharing personal information

We do not sell, trade, or otherwise transfer to third parties Users’ personal identification information. However, each User accepts that his/her personal identification information can be transmitted to website hosting and editing partners and other sub-contractors who assist us in providing the Services, conducting our business, or servicing the User, so long as those sub-contractors undertake to process the information only according to our instructions and to comply with the applicable law regarding the protection of personal identification information. We may also release User’s personal identification information when we believe that such release is necessary to comply with the law, enforce our websites’ general terms of use, or protect our or others’ rights, property, or safety.
However, Users non-personal identification information may be provided to third parties for marketing, advertising, or other uses.

Changes to this Privacy Policy

We have the discretion to update this Privacy Policy at any time. We encourage Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.

Data Retention

We take all reasonable measures to ensure that User’ personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The Personal Data will be retained by us according to the following criteria:

(1) as long as we maintain an ongoing relationship with the User (e.g., where the User is a recipient of our services, or is lawfully included in our mailing list and has not unsubscribed);
(2) as long as the User’ personal data are necessary in connection with the purposes set out in this Privacy Policy, for which we have a valid legal basis
(3) until the expiry of a period of two (2) months following the end of any applicable limitation period under applicable law; and
(4) with the User’ prior consent, until the expiry of any additional retention period.

We undertake to delete or to anonymise the User’ personal data upon expiry of the retention period as described above.

Data Security and data transfer

We have implemented appropriate technical and organizational security measures designed to protect the User personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.
The User is responsible for ensuring that any personal data that he/she send to us are sent securely.
We do not transfer personal data to any third country nor to any international organisation, except as the case may be on the basis of:

• adequacy decisions;
• suitable Standard Contractual Clauses; or
• other valid transfer mechanisms under GDPR.

Data Accuracy and minimization

We take reasonable measures:

  • to ensure that the User’ personal data are accurate and, where necessary, kept up to date and accurate; and
  • that the User’ personal data are collected on an as needed basis in connection with the purposes set out in this Privacy Policy.

Data subject rights

Each User benefits under data protection law from a right of access, modification and opposition to the processing of his/her personal data, a right to delete and transfer his/her personal data by sending an email to Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the Luxembourg supervisory authority, namely the Commission Nationale pour la Protection des Données (National Data Protection Commission – Luxembourg (

Acceptance of these terms

By using the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, we recommend to such User that he/she shall not use the Services. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.