Vertis Global Carbon Fund > Privacy Statement

Privacy Statement

We at STX Asset Management S.a.r.l. (hereinafter “we”, “our”, “us” or “STX AM”) respect your privacy and undertake to protect your personal data. 

This privacy statement (the “Privacy Statement”) aims to give you information on how we collect and process your personal data through your use of this website (“our Site”). 

The Privacy Statement applies to the privacy practices of STX AM with respect to its collection and processing of personal information through our Site and does not apply to information that STX AM collects and processes by way of any other methods.

  1. Collection of Information: 

When you register to use our Site or choose to submit information to our Site, we collect and process the following data from you: 

  • Information you provide to us: This is information that you provide to us by filling in forms on our Site (such as an online contact form or, registration to receive the newsletter) or due to corresponding with us, or having contacted us (by phone, post, email or other method). The information you provide to us may include your name, postal address, email address, telephone number and your firm’s name.
  • Other information you provide to us: such as through subscription documents and other onboarding documents (that may include tax ID numbers or other government-issued identification numbers, to the extent permitted by applicable law), and other forms and documents you send us in connection with an investment or potential investment in Vertis Carbon Fund.
  • Information we collect about you when you visit this website: namely technical information (IP address used to connect your computer to the internet, type of browser and version, time setting, type and versions of browser plug-ins, operating system and platform), information about your visit, including uniform resource locators (URLs), the clickstream to, through and from our website (including date and time); the products/services viewed or searched; page response time, errors in downloading, length of visits to certain pages, information on interactions with the page (such as scrolling, clicks, mouse movements), and the methods used to exit the page.
  1. How we use your information 

 We use the information you supply to us and we collect about you in the following ways:

  • to provide you with the information, products and services that you request from us and to answer any questions you have posed; 
  • to carry out our obligations arising from any contracts entered into between you and STX AM;
  • to comply with our legal and regulatory obligations such as to carry out identity and anti-money laundering checks where you or your related organization are applying for our products or services;
  • to administer our Site and to carry out internal operations such as troubleshooting, data and usage pattern analysis, testing, research, statistical and survey purposes;
  • to improve our Site and to tailor the content and layout of our Site to meet your needs and preferences;
  • to measure the effectiveness of and to improve STX AM’s marketing and promotional efforts through our Site;
  • to contact you to provide you with information that we believes may be useful to you, such as relevant market updates and information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
  1. Disclosure of Information: 

We do not sell or broker any of your personal information to third parties.

We will not disclose your personal information to third parties, except in the following circumstances: 

  1. when we are under a legal obligation to do so or to protect the rights, property or security of STX AM, our customers, or others. This includes sharing information with public authorities (such as governmental, tax, regulatory body or law enforcement agency) and will extend to situations in which we disclose information to such authorities upon forming a reasonable belief in good faith that such action is required to comply with applicable law or to report or prevent a crime or to protect national security;
  1. to share your information with our affiliates and persons or entities that we engage in the course of outsourcing certain functions, such as professional advisers, service providers, IT service providers, sub-contractors and providers of analyses and search engines that help us to improve and optimize our site. 
  1. STX AM reserves the right to transfer personal information we have collected about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets related to the Site (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution or liquidation). 
  1. Transfer of your information 

We may transfer your information outside the European Economic Area (“EEA”), if necessary: (i) to achieve one of the purposes set out in Section 3 and/or (ii) to disclose your information to third parties in accordance with Section 4 of this policy. 

If your information is transferred outside the EEA, we will ensure that it is protected such as by means of one of the following guarantees: 

  • the laws of the country to which your information is transferred provide a suitable degree of data protection as approved by the European Commission by way of adequacy decision; or 
  • the transfer is governed through the provision of appropriate safeguards as approved by the European Commission, such as standard contractual clauses and binding corporate rules, and on condition that enforceable rights and effective legal remedies are available for individuals. 
  1. Security of the information collected

We maintain physical, technical, organisational and procedural safeguards which are designed to protect personal information against unauthorized or unlawful access or disclosure, use, loss, alteration or destruction. 

When deciding upon the appropriate safeguards to utilise, we conduct a risk-based assessment which involves a consideration of the following factors: 

  • the state of the art of commercial available technology;
  • the cost of implementation; 
  • the nature, scope, context and purpose of processing; and 
  • the severity and likelihood of the risks. 

However, the confidentiality of any communication or other material that is conveyed to us or that we convey to third parties via our website or by email cannot be guaranteed. We shall not be held liable for the security of information conveyed via these means.  

  1. Retention of your data

We will retain your personal information in accordance with the applicable legal requirements with respect to data protection. Your information will only be kept for as long as necessary to fulfil the purpose for which we collected it, unless the processing of your data is required for us to comply with any legal or regulatory duty, in which case the information will be kept for as long as necessary in order to comply with such duty. 

To determine the appropriate retention period for personal data, we consider the amount, nature, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 

Once your personal information is no longer needed, we will ensure that it is destroyed securely or, in some circumstances, we may irreversibly anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Such personal data, once anonymised, cannot be used to identify you.  

  1. Your rights 

You have certain rights with respect to the information we hold about you. In certain circumstances and to the extent permitted by law, you may have the following rights in relation to the processing of your information:

  • Access: To request access to the personal information we process in relation to you and to be informed about how use and share your information.
  • Object: To object to the processing of your information if (i) we are processing your information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your information for direct marketing purposes. 
  • Correction: To request that we update the information we process in relation to you, or to correct information that you think is incorrect or incomplete. 
  • Erasure: To ask that we delete information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it. 
  • Restriction: To request that we restrict the way in which we process your information, for example, if you dispute the accuracy of your information or have raised an objection which is under consideration. 
  • Portability: To request a copy of your information that you have provided to us in a commonly used electronic format. 
  • Automated decision making: To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar significant effect to you. 
  • Complain: The right to lodge a complaint about the way in which we process your information with the National Commission for Data Protection (1, avenue du Rock’n Roll, L-4361 Esch-sur Alzette, www.cnpd.public.lu).  

If you wish to exercise any of the rights above, please email us at compliance@stxgroup.com.

When exercising a right we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or to exercise any of your other rights. This is to ensure that information is not disclosed to any person who does not have authority to receive it. We may also request further details and information in relation to your request to help us to locate the information processed in relation to you, including, for example, the nature and location of your relationship with us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, to the extent permitted by applicable law, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Should we require more than one month (from the receipt of your request) to respond to your request, we will duly inform you.

  1. Other Websites

The Site may contain links to third-party websites over which STX AM has no control. Such links are provided for information purposes only and STX AM is not responsible for the privacy policies or practices of such other websites. We encourage you to review the privacy policies, if any, on such websites.

  1. Cookies:

STX AM may place a small text file called a “cookie” in the browser files of your computer. The cookie itself does not contain personal information, although it will enable the Site to relate your use of the Site to information that you have specifically and knowingly provided to the Site (such as username) and to track your use of the Site. Tracking information (aggregated through Google Analytics) is used to gather information on user demographics and Site traffic patterns on an aggregate basis and is not connected to the identities or other personal information of individual users.

The Site uses JavaScript for no other reason than to improve the user experience.

  1. Changes to our Privacy Policy 

STX AM reserves the right to modify this Privacy Statement from time to time, in its sole discretion, by updating this web page. It is your responsibility to review this Privacy Statement periodically. This Privacy Policy was last updated on [X]. 

  1. Contact details

If, at any time, you would like us to stop contacting you using the personal information that we have collected, or you would like us to update or delete the information we have about you, or if you have any questions concerning our Privacy Statement, email us at: compliance@stxgroup.com.