1. INTRODUCTION

This Privacy Policy sets out the basis on which Laurion Fund SLP collects, processes and uses your personal data.

This Policy applies to www.laurionfund.lu (our Website) and of our services, offline and online.

As we are committed to protecting your privacy and personal information, please read this Privacy Policy and ensure you understand our policies regarding your personal data and how we will handle it.

 

  1. INFORMATION WE MAY COLLECT

We may collect the following personal information which we have grouped together as follows:

  • Information provided by filling in forms on our Website to request a contact such as your name, address and contact details – please note we may automatically capture, store or otherwise process this information even if you abandon the request process.
  • Information provided when contracting our services. This may include your personal documentation, financial situation, bank account details, evidence of identity, evidence of address
  • Account information such as your username, password, account number, account balance, trading activity and history
  • Financial information such as your bank account and payment card details.
  • Use of our services information such as information about your use of our Website, products and services. This includes your preferences, feedback and survey responses.
  • Technical information such as your internet protocol (IP) address, login information, browser type and version, time zone setting, operating system and platform, server logs and other similar data.
  • Marketing and communications information such as your preferences in receiving marketing from us and our third parties, and records of correspondence you have entered into with us via e-mail, post or telephone.

We may also collect aggregated or de-identified data when you use our Website or Trading Platform. For example, we may use Uniform Resource Locators (URL) clickstream analysis information to collect, analyse and report data about which site you have visited our Website from and which site you go to after our Website, which pages you visit and in what order, length of visits to certain pages, page response times, page interaction information, products you have viewed or searched for, download errors and methods used to browse away from the page.

 

  1. HOW WE USE YOUR PERSONAL INFORMATION

We collect, use, disclose, transfer and store personal data when needed to provide you with our services and for our operational, legal, regulatory and business purposes in relation to those services and as described in this policy. We may use your personal information for the following purposes:

  • To engage with you for the purposes of starting a mercantile relationship and register you as a customer and to set up and administer an account for you, including to provide you with any or customer support
  • To verify your identity and conduct checks on our customers including initial and ongoing anti-money laundering, sanctions, fraud, credit risk and customer due diligence checks which we are required to complete (which may be done by our third-party service providers). We may use and retain this information even after you have closed your account.
  • To provide you with information, products or services you request and to respond to your questions.
  • To make suggestions about new products and services that may be of interest to you
  • To administer our Website including troubleshooting, data analysis, testing, system maintenance and support, reporting and hosting of data.
  • To personalize your experience as a customer on our Website and Trading Platform.
  • To protect the security of our Website including through preventing and detecting security breaches, fraud or other criminal or malicious activities.
  • To notify you about changes to our products or services including any changes to our Privacy Policy.
  • To analyse and make improvements to our products or services through data analytics, research and auditing.
  • To enable you to participate in surveys, competitions, draws that may be of interest to you where you have been consented to be contacted for such purposes.
  • To comply with any other applicable law or regulation including any court order or any legal or regulatory requirements

In line with applicable regulations, we want to provide you with choices in relation to certain personal data uses – such as marketing and advertising communications. If you receive any communications from us and you want these to stop please unsubscribe to our marketing communications. If you unsubscribe to marketing communications, you may will still continue to receive operational communications from us that we deem necessary for our business relationship.

We do not disclose information about identifiable persons to our third-party advertisers or partners who provide content to our Website, but we may provide them with aggregated information about users.

 

  1. WHY WE PROCESS YOUR INFORMATION

We may be required to retain, process and use your personal information on one or more legal grounds:

  • the processing is necessary for the development of our business relationship;
  • to comply with our legal or regulatory obligations or;
  • the processing is necessary for our legitimate interests or the legitimate interests of a third party that receives your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedom.

Please note the processing of your data may be based on your consent where you have expressly given that to us.

 

  1. WHEN WE SHARE OR DISCLOSE YOUR INFORMATION

We may share or disclose your personal information with selected parties. When we share personal data, we do so in accordance with applicable data privacy laws and our internal security standards.

  • Laurion Systems, SL: we may make personal information available to any member of our group, which means any subsidiary company or holding company, and/or any subsidiary company of such holding company (the Group). This may be necessary to provide you with or administer our products, services, customer and technical support. All of our employees, agents and contractors are required to follow our privacy and security policies when handling personal data.
  • Third party service providers: We may share your personal information with our third party service providers so that they can support our products and services, such as system and platform maintenance services, conducting customer due diligence or credit checks, collecting customer feedback, marketing and advertising services, and data analytics and search engine services. Our third party service providers are permitted to use your personal information only for the purpose of providing services to us and may not otherwise share or use your personal information.
  • Fraud prevention and credit reference agencies: We may share your personal information with our third-party service providers to conduct anti-money laundering, fraud, sanctions, credit risk and customer due diligence checks, credit reference checks and fraud prevention checks.
  • Introducers and advisers: we may disclose your personal information to an introducer if they directed you to us.
  • Courts, Regulatory Agencies, Tribunals and Law Enforcement Agencies: we will share your personal information when we believe it is required to comply with applicable legal or regulatory obligations and to respond to requests from government authorities, including law enforcement or financial regulators. This may include authorities outside your country of residence.

Other third parties: We may share personal information in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

We may also make personal information available to protect our rights, users, systems and services.

 

  1. WHERE WE TRANSFER AND STORE YOUR PERSONAL INFORMATION

The personal information that we collect from you may not be sent, stored at, and used in a which does not offer the same level of protection as the EEA. It may, however, be processed by staff operating outside the EEA who work for us, one of our suppliers, introducers, business partners, agents or subcontractors – only and if there is an agreement to operate under EEA standards as well as our internal policies. By submitting your personal data, you agree to this transfer, storing and processing. We are committed to ensure all steps necessary for your protection are taken, and your information is treated securely and in accordance with our legal obligations and standards. Where this is not possible and we are required to disclose your personal information, for example because we are required by law to disclose your personal information, we will do this in accordance with applicable legal and regulatory obligations.

 

  1. INFORMATION SECURITY

We will implement and maintain the adequate technical and organizational measures to keep your personal information secure and to protect it from damage, loss, alteration, unauthorized access or disclosure, unlawful or accidental destruction.

For example, we will use the following types of measures, where appropriate:

  • encryption of personal information,
  • back-up servers and facilities,
  • testing, and
  • ongoing monitoring of the effectiveness of security measures.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. INFORMATION RETENTION

We will only retain your personal information for as long as required to by business reasons, legal reasons, regulatory reasons or reporting requirements.

 

  1. YOUR RIGHT OF ACCESS TO YOUR PERSONAL INFORMATION

Subject to certain legal parameters, you have rights in relation to your personal information which include:

  • Access to personal information: You have the right to ask us for copies of the personal information we hold on you and information regarding our processing activities. Before providing you with access, we may ask you to provide evidence of your identity and we may be unable to disclose some of the information for legal or regulatory reasons. You can request us to provide the information to you by using the contact form on the webpage or writing directly at info@laurionfund.lu
  • Right to rectification: You have the right to ask us to correct or amend your personal information if it is inaccurate, requires updating, or is incomplete.
  • Right to deletion (right to be forgotten): You also have the right to request us to delete your personal information unless we are required to hold it for legal or regulatory reasons
  • Right to object to or restrict processing of your personal information: You have the right to request us to stop all processing altogether or for a certain purpose. In circumstances where you ask us to erase or stop processing your personal data, this may result in us being unable to continue to provide you with our services and/or closing your account with us.

If you wish to exercise any of these rights, please contact us using the details found in part 11. We will respond to any requests referenced above within fourteen (14) calendar days of receipt. We will not charge you a fee for a request.

You may also make a complaint if you have a concern about our handling of your personal information. We will consider any complaints which we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.

 

  1. CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our Privacy Policy in the future will be posted on our Website. This policy was last updated on 31st of August 2018.

 

  1. CONTACT US

We welcome any questions, comments and requests regarding this Privacy Policy. Please contact us at info@laurionfund.lu