This Privacy Notice (the “Notice”) has been prepared in accordance with the requirements of 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 (the “GDPR”).
All capitalised words used in the Notice shall have the same meaning as they are defined or referred to in the GDPR, unless specifically indicated to the contrary herein.
Governance Partners, acting through Joachim Kuske(“Governance Partners”) is the Data Controller of the Personal Data of any Data Subjects with whom Governance Partners deals in the daily performance of its duties and delivery of services, as further described herein.
Governance Partners is committed to hold the Personal Data in confidence in strict compliance with the provisions of the Notice, any internal procedures, the GDPR, as well as any Luxembourg law.
This Notice contains the information prescribed by article 12 of the GDPR.
1, rue Louvigny
Grand Duchy of Luxembourg
Commission Nationale pour la Protection des Données
Service des plaintes
1, avenue du Rock’n’Roll
Governance Partners will process the following Personal Data from a Data Subject:
Name(s), Surname, Work contact information (telephone numbers, email addresses, postal address, website title, function in the Data Subject’s organisation), IP address, the outcome of technical processes (such as cookies, analytics, third party embeds) and other incidental work related details.
4. Purpose of the Processing and legal basis of the Processing
Governance Partners will use Personal Data for the following purposes with the relevant associated legal basis:
Ensuring compliance with anti-money laundering/combatting financing of terrorism legislation, including, but not limited to the amended law of 12 November 2004 on the fight against money laundering and terrorist financing;
Governance Partners may use Personal Data for any other purpose expressly agreed on by the Data Subject, provided that such consent may be withdrawn at any time by the Data Subject, without however affecting any Processing performed by Governance Partners prior to such withdrawal.
Governance Partners’ legitimate interest results from Governance Partners’ activities, consisting in the provision of independent directorship services and economic advice (conseil économique).
Governance Partners may share Personal Data with the following Recipients:
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
Governance Partners may transfer Personal Data to Recipients that are located outside the European Economic Area (“EEA”) or to International Organisations.
When sharing the Personal Data of a Data Subject with Recipients that are located outside the European Economic Area (EEA), Personal Data of a Data Subject will only be transferred on one of the following bases:
In such case, Governance Partners must obtain the explicit consent of the Data Subject to transfer the Data Subject’s Personal Data outside of the EEA. If the Data Subject doesnot consent to some or all of these processing activities, then Governance Partners may not be able to continue to offer its services to the Data Subject and/or the Data Subject’s employer. A Data Subject may also withdraw his/her consent at any time.
Governance Partners will store the Personal Data of the Data Subject in line with applicable legal and regulatory requirements in Luxembourg.
Analytical data will be stored indefinitely.
A Data Subject has the following principal rights under GDPR:
The list of the above rights is not absolute and requests may be refused where exceptions apply.
Date: 15 October 2018