Information about the processing of personal data

For persons contacting Leonarto Funds SCSp or Leonarto Management Sarl

In accordance with article 13.1 and 13.2 (whenever we obtain your personal data directly from you) or in accordance with article 14.1 and 14.2 (whenever we obtain your personal data from other sources) of the 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, and repealing Directive 95/46/EC (General Data Protection Regulation), we inform that:

The data controller of your personal data (including identifying data, contact data and other data related to the case in which you are contacting us, as well as in case of entering into an agreement with us – the data that is necessary in order to enter into the agreement and to perform it, and any other data that we are obliged to collect in accordance with the provisions of law or for collection of which you give us your consent) is Leonarto Funds SCSp or Leonarto Management Sarl (hereinafter referred to as “Data Controller” or “We”).

In matters regarding the protection of personal data, you can contact us by sending an e-mail to: rodo@leonarto.vc.

Your personal data will be processed:

  1. on the basis of art. 6.1.a GDPR – in a situation where you give your consent to the processing of personal data for a specific purpose (including for marketing purposes, sending the newsletter) – your data will be processed until such consent is withdrawn,
  2. on the basis of art. 6.1.b GDPR – in a situation where the data were provided for the purpose of concluding or performing a contract with the Administrator and to the extent that they are necessary for its conclusion or performance. Your personal data will be stored for the time needed to perform this contract (and subsequent contracts, if concluded), its settlement, and then for the period necessary due to the investigation or defense against claims related to this contract,
  3. on the basis of art. 6.1.c GDPR – in a situation where data are necessary to perform a legal obligation incumbent on us, including in particular in the field of counteracting money laundering and financing of terrorism – your data will be processed for the duration of this obligation or for other period as specified in law,
  4. on the basis of art. 6.1.f GDPR – in a situation where processing is necessary for purposes arising from our legitimate interests, including:
  5. for the purposes of contacting you, if you contact us for a purpose other than entering into a contract. For this purpose, your data will be processed for the time needed to respond to your inquiry,
  6. if you have concluded a contract with us – for the purposes of marketing of our products and services – your personal data will be stored for the duration of the relationship between you and one of the Data Controllers, or until an objection is raised, if you have objected effectively to such processing. And in a situation where you additionally give separate consent to the processing of your data for marketing purposes for a longer period or by other entities, then your personal data will be processed for the time indicated in the consent, but no longer than until the withdrawal of this consent,
  7. for the purposes of making a back-up / archiving – in the event that your data are archived or backed up, they will be processed for this purpose for the time set by the Data Controllers for storing such a backup or archive.

After fulfilling the conditions specified in the GDPR, you have the right:

  1. to access your personal data, the right to rectify it, delete it, as well as the right to limit their processing,
  2. the right to transfer data – if their processing is based on consent or for the purpose of performing or concluding a contract),
  3. the right to object to the processing of your personal data – if their processing is based on a legitimate interest,
  4. the right to withdraw your consent at any time (by sending your statement in the selected form for this purpose – in accordance with the Data Controller’s contact details provided above) – if the processing of data is based on your consent. The withdrawal does not affect compliance with the right of processing based on consent before its withdrawal,
  5. the right to lodge a complaint to the supervisory authority, if you think that the processing of your personal data violates the provisions of the GDPR.

Please be advised that your personal data may be transferred to other companies from the capital group to which the Data Controller belongs, subsidiaries and affiliates, entities providing accounting and legal services as well as entities that process data on behalf of the Administrator, including Atdomco Sarl based in Luxembourg.

Your personal data may be transferred outside of Luxembourg, in particular in connection with Data Controller’s use of cloud solutions that require the transmission and storage of personal data in the data center of the providers of these solutions. In the event that this data will be forwarded to the so-called third countries, i.e. outside the European Economic Area, Leonarto will make reasonable efforts to comply with the law and relevant data security requirements, e.g. after the conclusion of model contractual clauses approved by the European Commission or in the scope of data transfer to the USA such transfer will take place to entities that are certified under the so-called Privacy Shield.

Please be advised that we may additionally obtain your data from publicly available sources (such as business registers, websites, newspapers).

Talk – Action = Bullshit