Data Controller
Circle Securitisation S.à r.l., Avenue Charles de Gaulle 2, L-1653 Luxembourg ("we", "us", "our") is the data controller responsible for the processing of your personal data in connection with the Acentra platform and this website.
Personal Data We Collect
We may collect and process the following categories of personal data:
- Identity data: Full name, nationality, date of birth
- Contact data: Email address, telephone number, postal address
- Professional data: Company name, role, investor type
- Financial data: Intended investment amount, investment horizon, source of funds (as required for KYC/AML compliance)
- Technical data: IP address, browser type and version, time zone setting, operating system and platform
- Communication data: Records of correspondence with us
Legal Basis for Processing
We process your personal data on the following legal bases under the GDPR:
- Consent: Where you have given explicit consent to the processing of your personal data for specific purposes (e.g., receiving communications).
- Contractual necessity: Where processing is necessary for the performance of a contract or to take pre-contractual steps at your request.
- Legal obligation: Where processing is necessary for compliance with AML/KYC, tax reporting, or other regulatory obligations.
- Legitimate interest: Where processing is necessary for our legitimate business interests, such as improving our services and ensuring the security of our platform.
How We Use Your Data
We use your personal data to assess your suitability as an investor, process your enquiries, comply with legal and regulatory obligations (including AML/KYC requirements), communicate with you about investment opportunities, and improve our website and services.
Data Sharing
We may share your personal data with our service providers (including fund administrators, legal advisors, and auditors), regulatory authorities where required by law, and banking partners in connection with the processing of investments. We do not sell your personal data to third parties.
International Transfers
Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). Where such transfers take place, we ensure appropriate safeguards are in place in accordance with the GDPR, including standard contractual clauses approved by the European Commission.
Data Retention
We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. For AML/KYC records, Luxembourg law requires retention for a minimum of five years following the end of the business relationship.
Your Rights
Under the GDPR, you have the right to:
- Access your personal data
- Request rectification of inaccurate data
- Request erasure of your data (subject to legal retention obligations)
- Restrict processing
- Data portability
- Object to processing
- Withdraw consent at any time
To exercise any of these rights, please contact us at info@acentra.lu.
Cookies
This website uses only essential technical cookies necessary for the functioning of the website. We do not use advertising or tracking cookies.
Changes to This Policy
We may update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date.
Contact
For any questions regarding this privacy policy or your personal data, please contact:
info@acentra.lu
Circle Securitisation S.à r.l.
Avenue Charles de Gaulle 2
L-1653 Luxembourg