Privacy Notice

v2022.01.a

 

Introduction

Palana is an advisory and service firm focusing on Asset & Wealth Management and Asset Servicing. Palana works with all actors of the vanilla and alternative asset value chain across the full spectrum of their challenges.

For more information about Palana and the services which we provide, please see our website at www.palana.lu.

 

About this Notice 

This Privacy Notice explains who we are, how we collect, share, safeguard and use your personal data, and how you can exercise your privacy rights.

We are a data controller in accordance with the provisions of the data protection law applicable to the Grand-Duchy of Luxembourg and the General Data Protection Regulation (“GDPR”).

We are committed to ensuring your privacy is protected. Should you provide us with personal information by which you can be identified, then you can be assured that we will use that information only in accordance with this privacy notice. All of our employees and third parties who have access to or are involved in the processing of personal information respect the confidentiality of such personal information. 

 

Who we are?

Palana S.A., a public limited liability company (“Société Anonyme”) under Luxembourg law with registered office at 51, Cité Bettenwiss, L-8479 Eischen (herein referred to as “Palana”), is the data controller where Palana collects, stores and processes, by electronic or other means, personal data for our own purposes and in order to provide the services required and to comply with our legal obligations.

 

Updates to this Privacy Notice 

This Privacy Notice is updated from time to time, all versions are dated and numbered at the top of the notice which is posted on this page. Please check back frequently to see any updates or changes to our privacy notice.

 

Third Party Websites

Links to and from other websites, which are independent of Palana, are maintained by third parties. Palana is not responsible for the content or privacy practices of any third-party websites and shall not be liable for any damages or harm arising from the content and use of such websites.

Any links to other websites are provided as a convenience to you as a user, and do not imply our endorsement of the linked websites or association with their operators.

 

Cookies 

As a website visitor, Palana collects personal data from you to administer the site, to improve your browsing experience, and to enable visitors to be better informed of the services available from Palana. Such data is obtained through the use of cookies and similar technologies. 

For further information on our use of cookies please see the Palana Cookie Notice.

 

What is covered by this Notice?

Palana collects personal data about the following types of interactions, contacts or stakeholders to allow us to undertake our business:

  • Candidates for job opportunities
  • Prospective and active client contacts
  • Attendees to our events
  • Distribution list members for our email newsletters or other communications
  • Participants to our physical or online surveys or trainingsupplier contacts to support our services
  • Employees
  • External consultants, sub-contractors, temporary workers
  • Visitors to our website
  • Communication with us via phone calls, chat, email, web forms, social media and other methods of communication

 

Types of data Palana collects

  • Identity Data. This includes but is not limited to first name, last name, date of birth, place of birth, nationality, passport details, national identity card number or social security number
  • Personal, Familial and Social Background Data; language used, marital status, photo, image or sound, communication and behavioral information from social medias (LinkedIn profile), postings, any personal data about you included in free text boxes on a form (including in relation to enquiries or comments submitted to us), feedback and survey response, etc. 
  • Contact Data; this includes email address, telephone number(s) and postal address
  • Financial Data; this includes banking details, income details, tax information, source of wealth
  • Employment Details; this includes job titles, career history, qualifications, education details
  • Technical Data; subject to your cookie settings this may include internet protocol (IP) address, browser type and version, device used, type of browser, operating system, language used, access logs, information received through emails

 

Legal basis for Palana to process Personal Data

Data Protection law restricts Palana to process personal data only where we have a valid legal basis to do so. 

We must have one of the following legal basis to process your personal data : 

  • To enter into, or for the performance of a contract
  • Where Palana has a legal duty or obligation
  • Where it is in the public interest
  • Where we need to protect your vital interests
  • Where it is in our legitimate interest 
  • Where you consent to it

 

Sharing your Personal Data 

Palana may share your personal data with: 

  • Vendors and administrative support, infrastructure, and other service providers handling your information on our behalf, such as AML/KYC providers; in each case, such vendors and service providers will be contractually bound by confidentiality and privacy obligations consistent with the obligations in this Privacy Statement
  • Tax, government and any relevant regulatory authorities
  • Prosecuting authorities and courts, and/or other relevant third parties connected with legal proceedings or claims
  • Fraud prevention and/or law enforcement agencies
  • Third parties where Palana is required to do so by law
  • Third parties to whom we disclose information in the course of providing services to you or to the entity that has engaged us to provide the services

 

Security of Personal Data

We are committed to protecting the security of your personal information. We use a variety of technical, administrative and physical security measures, including but not limited to, firewalls, antivirus and SSL encryption in order to protect your personal information from: 

  • Unauthorised access
  • Improper use or disclosure
  • Unauthorised modification or alteration
  • Unlawful destruction or accidental loss

 

Where we store and process your Personal Data?

The data that we collect from you may not be transferred to, and/or stored at, and/or processed at a destination outside the European Union unless: 

  • Allowed by a decision by the European Commission (to countries that provide an adequate level of personal data protection), or
  • Appropriate safeguards are implemented such as the use of EU Standard Contractual Clauses (SCC), allowing for data protection legislation compliant contracts and data sharing agreements.

By submitting your personal data, you agree to these potential transfers, storing or processing.

Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

Retaining Personal Data 

Palana retains your personal data only for as long as is necessary for our purposes or is required to meet legal or regulatory obligations and for the exercise and/or defence of any legal claims.

 

What are your Data Protection rights?

You have the right to be informed about what, how and why we process your personal data, as outlined in this Privacy Notice. You have the right to access the information we hold about you. Where we are legally permitted to do so, we may refuse your request and will provide you with our reasons for doing so. 

 Furthermore, you have the following rights:

  • Rectification - The right to have personal data corrected where it is inaccurate or incomplete
  • Erasure (right to be forgotten) - The right to have personal data erased
  • Data portability - The right to receive personally or have data sent to a third party in a common and machine-readable electronic format
  • Object - The right to complain and to object to processing to a relevant supervisory authority and/or claim compensation for damages or distress
  • Restriction of processing (purpose limitation) - The right to limit the extent of the processing of personal data
  • Automated decision-making and profiling - The right not to be subject to decision making without human involvement


Contact us

You may exercise the above rights by sending an email to dataprotection@palana.lu or by writing to Palana’s Data Protection Officer at:


Palana S.A.

Attention: Data Protection

33, rue du Puits Romain

L-8070 Bertrange

Grand Duchy of Luxembourg. 

 

How to contact the appropriate authority ?

Should you wish to lodge a complaint or if you feel that Palana has not addressed your concern in a satisfactory manner, you may contact the CNPD :

 

CNPD (Commission Nationale pour la Protection des Données)

1, avenue du Rock’n’Roll

L-4361 Esch-sur-Alzette

 

Tél. : (+352) 26 10 60 -1

https://cnpd.public.lu/fr.html