Available Policies and Procedures
The main policies of ADEPA Asset Management S.A. are made available through the following links
These policies and procedures can be obtained free of charge upon request to the following e-mail address of ADEPA Asset Management S.A. compliance@adepa.com, by fax (+352) 26 89 80 51, by phone at (+352) 26 89 80-1 or by written request to Adepa Asset Management S.A., 6A, rue Gabriel Lippmann, L-5365 Munsbach, Grand Duchy of Luxembourg.
Complaints can also be sent to the address above.
The person responsible for complaints handling in Adepa Asset Management S.A. is Mr. Francisco Garcia Figueroa (email: f.figueroa@adepa.com and tel: (+352) 26 89 80-1).
ADEPA ASSET SERVICING LUXEMBOURG
Public limited company (Société anonyme)
Registered office: 44, avenue J.F. Kennedy, L-1855 Luxembourg
RCS Luxembourg No. B 74.296
Authorisation: Specialised PSF
CSSF No. P00000652
Authorised statuses
• Registrar agent
• Domiciliation agent of companies
• Family Office
• Professional providing company incorporation and management services
Other statuses
• Administrative agent of the financial sector
• Client communication agent
Information on Complaints
In case of a complaint, please use the following email address: reclamations@fidupar.eu.
According to the internal procedure for handling complaints from clients and suppliers, your complaint will be processed according to the following timetable:
- An acknowledgment of receipt will be sent to you no later than ten working days following receipt of the complaint, unless the response itself can be provided within that same period.
- A detailed and appropriate response will be provided to you no later than one month after receipt of the complaint.
- If it is not possible to provide a response within the aforementioned timeframe, you will receive an interim letter informing you of the reasons for the delay and the date by which your case is expected to be closed.
- When you have not received any response, or when the response at the first level of complaint is not satisfactory, FIDUPAR will provide you with the contact details of an authorisedmember of Management to whom you may escalate the complaint.
We also inform you that if you are not satisfied with the response given by an authorised member of Management within one month, or if you have not received any response, the CSSF is competent to receive complaints from clients (individuals and legal entities) concerning professionals under its supervision and may act as a mediator to seek an amicable settlement.
You will find all useful information, including the online complaint form or PDF version to be submitted to the CSSF, at the following link: https://www.cssf.lu/fr/reclamations-clientele/.
A complaint may be submitted:
- By completing the online form;
- By sending the completed form:
- By ordinary mail to the following address:
Commission de Surveillance du Secteur Financier
Département Juridique CC
283 Route d’Arlon
L-2991 Luxembourg
- Or by email to: reclamations@cssf.lu
The Management of FIDUPAR undertakes to use the out-of-court complaint resolution procedure with the CSSF as defined by CSSF Regulation 16-07.
Personal data protection policy of adepa asset servicing luxembourg
Introduction
Respect for privacy is important for ADEPA ASSET SERVICING LUXEMBOURG.
For any processing of personal data, ADEPA ASSET SERVICING LUXEMBOURG is committed to protecting the data of users of its website https://www.adepa.com (the “Website”) in accordance with the General Data Protection Regulation (EU) 2016/679, hereinafter referred to as “GDPR,” which is directly applicable in all EU Member States and concerns the protection of individuals with regard to personal data.
In this policy (the “Policy”), personal data refers to any information relating to an identified or identifiable natural person, directly or indirectly.
For all processing carried out on the Website, ADEPA ASSET SERVICING LUXEMBOURG acts as the data controller within the meaning of the GDPR:
ADEPA ASSET SERVICING LUXEMBOURG
Public limited company (Société anonyme)
44 avenue J.F. Kennedy, L-1855 Luxembourg
Grand Duchy of Luxembourg
Tel. +352 26 26 38 38
Fax +352 26 26 38 88
Email: info@fidupar.eu
VAT LU 18320846
RCS Luxembourg B74296
Data Protection Officer (DPO):
Julien Winkin
Tel. +352 26 26 38 38
Email: data.protection.officer@fidupar.eu
1. Types of personal data processed
1.1 Data provided directly by the user to ADEPA ASSET SERVICING LUXEMBOURG
ADEPA ASSET SERVICING LUXEMBOURG collects the personal data provided by the user when filling in the contact forms available on the Website. The following data is collected:
- First name, surname
- Email address
- Telephone number
- Content of the message
If the user subscribes to the newsletter of ADEPA ASSET SERVICING LUXEMBOURG, their email address will also be requested.
Furthermore, ADEPA ASSET SERVICING LUXEMBOURG collects personal data when the user contacts the company through any communication channel (e.g., by sending an email to addresses indicated on the Website).
1.2 Data indirectly collected by ADEPA ASSET SERVICING LUXEMBOURG
While browsing the Website, the following data may also be collected:
- Connection data such as date, time of connection, type of browser used, IP address, or MAC address
- Browsing data such as the device’s operating system, pages visited, and searches performed
- Data from cookies and other trackers: when visiting the Website, a banner appears at the bottom of the screen informing you of the use of cookies. Cookies are small, limited-size text files downloaded to the visitor’s device, enabling customization of services and improving browsing experience. ADEPA ASSET SERVICING LUXEMBOURG only uses session cookies, which are deleted once the browser is closed. These cookies do not collect personal data but simply ensure a better browsing experience.
2. Purposes of processing personal data
The collected data is processed for the following purposes:
- Managing requests for information and contact
- Managing newsletter subscriptions
- Prospecting, including by email: preparation of commercial and marketing statistics, sending email alerts to prospects and clients, sending information on new or existing services to professional clients
- Improving the security of the Website
3. Legal bases for processing personal data
The processing of data is based on the following legal grounds:
- Execution of pre-contractual measures or legitimate interest
- Consent
- Legitimate interest
- Legitimate interest to improve the Website and its operation
4. Recipients of personal data
To fulfil the purposes listed in Article 2, data may be shared with service providers acting as processors on behalf of and under the instructions of ADEPA ASSET SERVICING LUXEMBOURG.
Relationships with such processors are governed by contracts providing for the implementation of appropriate technical and organisational measures in accordance with Articles 28 and 32 of the GDPR.
As a rule, no data is transferred outside the Grand Duchy of Luxembourg or outside the EU/EEA. However, when data is transferred (including via remote access) to a non-EU country without an adequacy decision, appropriate safeguards are implemented in accordance with Chapter V of the GDPR, such as the European Commission’s standard contractual clauses.
5. Retention period for personal data
ADEPA ASSET SERVICING LUXEMBOURG keeps data only as long as necessary for the purposes for which it was collected. Once this period has expired, the data will either be deleted or anonymised, unless a legal obligation requires longer retention.
Where processing is based on consent, you may withdraw your consent at any time by contacting: data.protection.officer@fidupar.eu.
6. Security of personal data
ADEPA ASSET SERVICING LUXEMBOURG uses appropriate technologies and procedures to protect personal data, including measures to:
- Protect data against accidental loss
- Prevent unauthorised access, use, destruction, or disclosure
- Ensure business continuity and disaster recovery
- Restrict access to personal information
- Carry out privacy impact assessments in line with the law and internal policies
- Train staff and contractors on data security
- Manage third-party risks through contracts and security reviews
ADEPA ASSET SERVICING LUXEMBOURG complies with all applicable regulatory standards and requirements for professionals in the financial sector in the Grand Duchy of Luxembourg.
7. Rights of individuals
7.1 Right of access and rectification
You have the right to access your personal data processed by ADEPA ASSET SERVICING LUXEMBOURG and to have it rectified.
Where processing is based on consent, you may withdraw your consent at any time by contacting: data.protection.officer@fidupar.eu.
7.2 Right to erasure (“right to be forgotten”)
You have the right to request deletion of your data where:
- Your data is no longer necessary for the purposes for which it was collected or otherwise processed
- You withdraw your consent and no other legal basis exists for the processing
- You object to the processing and there are no overriding legitimate grounds
- Your data has been unlawfully processed
- Your data must be erased to comply with an EU or Luxembourg legal obligation
- Your data was collected in connection with services offered by ADEPA ASSET SERVICING LUXEMBOURG under Article 8(1) of the GDPR
However, your data cannot be erased if processing is necessary:
- For exercising the right to freedom of expression and information
- To comply with a legal obligation required by EU or Luxembourg law, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in ADEPA ASSET SERVICING LUXEMBOURG
- For the establishment, exercise, or defence of legal claims
7.3 Right to restriction of processing
You have the right to restrict processing of your data where:
- You contest its accuracy (restriction applies during the verification period)
- The processing is unlawful and you oppose erasure, requesting restriction instead
- ADEPA ASSET SERVICING LUXEMBOURG no longer needs the data but you require it for legal claims
- You object to processing while it is being verified whether ADEPA ASSET SERVICING LUXEMBOURG’s legitimate grounds override yours
During restriction, your data may only be processed (aside from storage):
- With your consent
- For legal claims
- For protecting the rights of another person (natural or legal)
- For important public interest reasons of the EU or a Member State
7.4 Right to data portability
You have the right to data portability when processing:
- Is based on consent, or
- Is based on a contract, and
- Is carried out by automated means
Where applicable, you have the right to:
- Receive your personal data provided to ADEPA ASSET SERVICING LUXEMBOURG in a structured, commonly used, machine-readable format
- Transmit this data to another controller without hindrance from ADEPA ASSET SERVICING LUXEMBOURG
- Request that your data be transferred directly from ADEPA ASSET SERVICING LUXEMBOURG to another controller, where technically feasible
7.5 Right to object
You have the right to object to the processing of your data when it is based on Article 6(1)(e) or (f) GDPR, including profiling based on these provisions, for reasons relating to your particular situation.
Exceptions apply where:
- There are compelling legitimate grounds for processing which override your interests, rights, and freedoms, or
- Processing is required for legal claims
Where data is processed for marketing purposes, you may object at any time to such processing, including profiling related to marketing. If you object, your data will no longer be processed for these purposes.
To exercise your rights, you must submit a request accompanied by proof of identity (certified copy of ID card or passport).
Your request should be addressed to:
ADEPA ASSET SERVICING LUXEMBOURG
44 avenue J.F. Kennedy
L-1855 Luxembourg
Grand Duchy of Luxembourg
DPO contact: data.protection.officer@fidupar.eu
Requests are processed within 1 month of confirmation of your identity. This period may be extended by up to 2 additional months in the case of complex requests or a large number of requests.
If you are not satisfied, complaints may be submitted to the Commission nationale pour la protection des données (CNPD), 1 avenue du Rock’n Roll, L-4361 Esch-sur-Alzette, Grand Duchy of Luxembourg.
8. Hyperlinks
If ADEPA ASSET SERVICING LUXEMBOURG provides links to external websites or resources from its Website, this does not constitute approval, and the company assumes no responsibility for the content or information contained on such external websites.
9. Updates to the Policy
ADEPA ASSET SERVICING LUXEMBOURG may change, modify, add, or delete parts of this Policy at any time and will inform you of changes by publishing an updated version on the Website.