CompaM Fund (hereafter “Compam”) is a company with many years of experience in international finance (asset management, investment funds, trading and bond broking, estate and succession planning, risk management).

The processing of personal data, to which Compam may become privy, is carried out in compliance with Article 13 of the RGPD 679/2016 “General Data Protection Regulation”, as well as taking into account the principles of correctness, lawfulness, transparency and all limitations aimed at the preservation, minimization and accuracy of data, i.e. in compliance with the protection of personal integrity and confidentiality of all sensitive information attributable to the person.

This Privacy Policy is intended to be for the website (hereinafter the “Website”).

The Data Controller is CompaM Fund. 

To request further information about the processing of your personal data or to exercise your rights, you can contact us:

by writing to:CompaM Fund
49, Avenue J.F. KennedyL – 1855 Luxembourg
by writing to the email
  1. What is personal data and what is processed

Personal data is information that directly or indirectly identifies or can identify an individual and can provide information about his or her characteristics, habits, personal relationships, etc. The following is considered personal data, including but not limited to: first name, last name, address or other contact details, an identification number or an online identifier.

Processing is any operation performed with or without the aid of automated processes and applied to personal data. Processing includes, but is not limited to: the collection, recording, organisation, storage, modification, consultation, erasure or destruction of data.

  1. What personal data is being processed
  1. Browsing data

During their normal operation, the computer systems and software procedures responsible for the operation of the Website acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects, but may by its very nature enable the User to be identified through processing and association with data held by third parties. This data includes: the IP addresses or domain names of the computers used by the User who connects to the Website; the URI addresses of the resources requested (Uniform Resource Identifier); the time of the request; and finally, other parameters relating to the User’s operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Platform to control its correct functioning, to identify anomalies and/or abuses and is deleted immediately after processing. The data could be used to ascertain liability in the event of cyber attacks against Compam or third parties.

  1. Data provided by the User through the “Info” Form

The User’s data is collected by the Data Controller when completing a form (hereinafter referred to as the “form”), in order to comply with the request for information.

  1. Data provided voluntarily by the User

The optional, explicit and voluntary sending of email to the addresses indicated on this website involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data entered in the letter.

  1. Purpose of processing

Your personal data will be processed for the following purposes:

  1. Respond to the request submitted to Compam by the User;
  2. Fulfil the pre-contractual, contractual, administrative and tax obligations arising from the relationship that may be established between the User and Compam;
  3. Send the User service-related communications/notifications;
  4. Fulfil the obligations established by law, current regulations, practice and requirements of the competent authority;
  5. To exercise their rights (both in and out of court) by Compam;
  1. Legal basis for the processing of User’s data

Each processing is justified by one of the following legal assumptions:

  1. Such processing is necessary for the execution of the contract between the parties. The provision of personal data is optional in this case but failure to provide it means that it is impossible to conclude the contract and perform the service requested;
  2. Processing is necessary for compliance with a legal obligation. In this case, the provision of data is mandatory and failure to provide it will result in it being impossible to conclude the contract and to perform the requested service;
  3. Processing is necessary for the pursuit of the legitimate interests of the Controller, provided that the interests or fundamental rights and freedoms of the User that require the protection of personal data do not prevail. In this case, the provision of data is optional.
  4. Processing is only possible where the User has consented to certain specific purposes. In such cases the provision of data is optional, and the User may revoke the consent previously given at any time.
  5. To whom might the data be disclosed

In the context of Compam’s activities and for the purposes specified above, your personal data may be shared with:

  • Duly appointed data processors providing specific processing services or accessories on behalf of Compam; the User may at any time request an up-to-date list of Data Processors;
  • Autonomous Data Controllers to whom the data may be communicated pursuant to legal provisions or orders of the Authorities;
  • Individuals authorised by Compam to process personal data necessary for carrying out activities strictly connected with the provision of services and who have an appropriate legal and contractual obligation of confidentiality (e.g. Compam’s employees and/or contractors).

Compam does not intend to sell or otherwise disclose your personal data to third parties.

  1. Where the data is stored

All personal data is stored electronically on servers located in the EU.

  1. How long are the data stored?

Your personal data is kept in compliance with the confidentiality and regulations in force for a maximum period of 10 years from the end of the contractual relationship. Any CV submitted by the User as candidates will be retained for a maximum period of 2 years after submission.

  1. What are your rights?

At any time, you can request confirmation as to whether or not your personal data is being processed and you have the right to: 

  • request access to the data to obtain information on the purposes pursued with the processing, the recipients to whom the data may be disclosed, the duration of the processing (where possible) and any consequences of processing based on profiling;
  • request the correction of personal data if it is inaccurate or incomplete;
  • request the deletion of data, if it is no longer necessary for Compam for the intended purposes; 
  • request that data processing be restricted, in the cases provided for by law;
  • request the transfer of data to another Data Controller in a commonly used format that can be read by a computer device, in the cases provided for by law;
  • object to the processing of your data and, specifically, have the right to object to decisions concerning you, if based solely on automated processing of your data, including profiling;

To exercise your rights, you can use the contact details provided under paragraph 1 or access the website of the Luxembourg Data Protection Authority 

  1. Automated Decision Making

You are not subject to decisions based on automated processing.

  1. Cookies

Cookies are text rows which act as computer markers sent from a server (in this case, the one on the Website) to a user’s device (usually to the Internet browser) when they access a given page of a website; cookies are automatically stored by the user’s browser and retransmitted to the server that generated them each time the user accesses the same Internet page. In this way, for example, cookies allow and/or facilitate access to certain Internet pages in order to improve the user’s browsing experience (i.e. they allow the storage of pages visited and other specific information, etc.), or in some cases they allow profiling activities. Therefore, for a facilitated and complete use of the Website, it is useful if, on your first time accessing the Website, you express your preferences regarding the placement of cookies. 

Characteristics and purposes of cookies

Our Site uses the following categories of cookies:

Necessary Cookies” (known as Technical cookies): These are necessary to enable the User to browse the Website and use its functionalities. In particular, they enable functions without which it would not be possible to use the Website fully, since their presence enables basic functions such as page navigation and access to the protected areas of the Website.

Session Cookies” are active cookies for the relevant session only, which allow you to temporarily store the information needed to navigate from page to page and avoid having to re-enter it.

The User’s consent is not required for the use of Necessary (“Technical”) cookies.

  1. Amendments

Compam reserves the right to amend or simply update the content of this Privacy Policy, in part or in full, including as a result of changes in applicable legislation. These changes will be binding as soon as they are published on the Site. If you continue to access or use the service after such posting you will be deemed to have expressly accepted these changes. Compam therefore invites the User to visit this section regularly to take cognizance of the latest and updated version of the Privacy Policy so that they can always be updated on the data collected and the use that Compam makes of it.

15 February 2023