Privacy Notice

1. Context and introduction

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.

2. Identity and contact details of the Data Controller and the Supervisory Authority

Data Controller:

Governance Partners

Joachim Kuske

1, rue Louvigny

L-1946 Luxembourg

Grand Duchy of Luxembourg



Supervisory Authority:

Commission Nationale pour la Protection des Données

Service des plaintes

1, avenue du Rock’n’Roll

L-4361 Esch-sur-Alzette

3. Categories of Personal Data concerned

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:

Compliance with a legal obligation:

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;

Performance of a contract with a Data Subject:
a) Fulfilling the obligations of Governance Partners under any agreement that Governance Partners may have entered into with a Data Subject;
b) Fulfilling Governance Partners’ obligations under any agreement between a Data Subject and a third party, under which Governance Partners has to fulfil any duties.
Consent of the Data Subject:

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:
a) Managing and administering the relationship between Governance Partners and a Data Subject;
b) Maintaining a client relationship management database for communication and promoting services offered by Governance Partners to Data Subjects;
c) Monitoring and recording, correspondence, telephone calls and emails in accordance with Governance Partners’ IT set-up.

Governance Partners’ legitimate interest results from Governance Partners’ activities, consisting in the provision of independent directorship services and economic advice (conseil économique).

5. Recipients of Personal Data

Governance Partners may share Personal Data with the following Recipients:

Any service providers of Governance Partners and any service providers of the Data Subjects, including Google and LinkedIn ;
Any lawyers, auditors, consultants or other professionals which Governance Partners may consult to obtain advice or assistance for the performance of its duties;
The CSSF or other supervisory authorities, tax authorities, law enforcement agencies in order to allow Governance Partners to comply with any legal or regulatory obligations and instructions.

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. 

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

6. Transfer of Personal Data to Third Countries

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:

The transfer is to a Recipient in a country or territory approved by the European Commission as providing an adequate level of protection for Personal Data;
The transfer is to a Recipient that has entered into European Commission standard contractual clauses with Governance Partners;
The transfer is to a Recipient in the United States of America which is registered under the EU/US Privacy Shield; or
The Data Subject has explicitly consented to the transferof Personal Data. In this regard, and as detailed above, Governance Partners will from time to time need to pass certain identity related data about a Data Subject toservice providers of Governance Partners located outsideof the EEA in order to allow Governance Partners to perform its business activities.

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.

7. Period for which the Personal Data of the Data Subject is stored by Governance Partners

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.

8. Rights of information and access to Personal Data by aData Subject under the GDPR

A Data Subject has the following principal rights under GDPR:

To obtain confirmation from Governance Partners as to whether or not Personal Data concerning the Data Subject is being Processed by Governance Partners;
As the case may be, to obtain access to, and copies of, the Personal Data that Governance Partners holds about the Data Subject;
To obtain the following information about:
o The purposes of the Processing of Personal Data and the categories of Personal Data concerned;
o The Recipients or categories of recipient of Personal Data to whom Personal Data has been or will be disclosed by Governance Partners, in particular if such Recipients are located outside the European Economic Area (“EEA”) or to International Organisations;
o Insofar as possible, the envisaged period for which Personal Data will be stored, or, if not possible, the criteria used by Governance Partners to determine that period;
To require that Governance Partners rectifies or erases Personal Data;
To request a restriction of the Processing of Personal Data or to object to such Processing;
To obtain the Personal Data concerning the Data Subject, which was provided by the Data Subject, in a structured, commonly used and machine-readable format that can be transmitted to another Data Controller in certain circumstances;
To lodge a complaint with the Supervisory Authority indicated in section 2.

The list of the above rights is not absolute and requests may be refused where exceptions apply.

Date: 15 October 2018

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