Protecting the data of each of our existing or prospective investors or, in general, of the user of this website (together, the “User” or “You”) is of the highest importance to Planven and we go to great lengths to make sure that we keep it safe. Planven is a group of Luxemburg based investment funds managed by a CSSF supervised AIFM and advised by CRDH Capital AG (“CRDH Capital” or “Us”), a Swiss based asset manager supervised by FINMA. We take your trust and right to privacy seriously. Nevertheless, in the course of serving our Users with this website, we may process information which constitutes Personal Data (as defined in section “What Is Personal Data?”) under data protection laws such as the General Data Protection Regulation of the European Union, the Swiss Act on Data Protection or equivalent laws in other jurisdictions around the globe.

Please note that the use of the website of Planven (hereinafter, the “Site”) is governed by the Terms and Conditions, available at the following link (hereinafter the “Terms & Conditions”).

1. What Is Personal Data?

Your name, address, email address, age and your IP address are elements of data processed by Us, that describe You and that may be correlated with You as an individual.

Additional information that CRDH Capital may request from You in order to register and create your personal access to the Site (i.e., gender, nationality, profession, etc.) may qualify as data that describes You and that may be correlated with You as an individual.

Your name, address of residence, IP address, email address, age, profession and any other personal information required for the creation of your personal access to the Site are deemed to be “Personal Data”.

By accessing the Site, You are expressly consenting to the Processing of your Personal Data, as set forth hereinafter. We use cookies to save your preferences and to make your use of the Site as seamless as possible (more details on cookies can be found in section “Does CRDH Capital Use Cookies?”).

2. How and Where Does CRDH Capital Process Personal Data?

We store and process the Personal Data that You have provided to Us as well as data that we may infer from your use of the Site (the latter generally being in anonymous form).

Your Personal Data may be subject to storage, collection, registration, organization, preservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, communication, transmission, cancellation and destruction (the “Processing”). Any of these operations may be performed applying those electronic or physical instruments and legal means that we deem appropriate for the security, confidentiality and protection of Personal Data.

Personal Data is processed at operating offices of CRDH Capital and at any other places where the parties involved in the Processing are located. More details on the parties involved in the Processing can be found in section “Who Processes My Personal Data?”.

CRDH Capital uses its own servers and may use third-party providers servers, located within the European Union.

While processing Personal Data, we make sure to take all reasonably possible security measures, both technically and organizationally, to keep Personal Data safe. If You would like to know more about how we keep You and your Personal Data safe, please see section “How Safe Is It to Use the Site?”.

3. Why Does CRDH Capital Process Personal Data?

CRDH Capital may process Personal Data for the following purposes:

(1) to improve the content, functionality and performance of the Site;

(2) to provide services to You;

(3) to enhance your browsing experience;

(4) to recognize You when You return to the Site;

(5) to provide (technical) support when You reach out to Us;

(6) to assess and manage risk and fulfil our legal and regulatory requirements;

(7) to exercise and defend our legal rights; and

(8) for any other legitimate business purposes.

4. Is the Processing Legally Justified?

Our Processing activity is executed in conformity with the applicable legal requirements:

• the processing activities set forth in items (1) to (5) above are necessary for the use of the Site and your consent;
• the processing activities set forth in items (6) and (7) above are necessary to comply with our legal obligations; and
• the processing activities set forth in items (8) above are based on our legitimate interest.

CRDH Capital does not sell or otherwise distribute your Personal Data to third parties other than those indicated in section “Who Processes My Personal Data?” and shall not use your Personal Data for any other purposes than stated above without your prior consent. Be aware that we allow our advertisers to add third party cookies in their wallpaper campaigns. For more details on cookies, please see section “Does CRDH Capital Use Cookies?”.

5. For How Long Is My Personal Data Processed?

Our retention periods for Personal Data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When Personal Data is no longer needed, our policy is to either irreversibly anonymize Personal Data (and we may further retain and use the anonymized information) or securely destroy such Personal Data.

Based on your consent for the processing activities set forth above, we keep your Personal Data in our database for as long as required for the use of the Site and for a maximum time period of five (5) years thereafter, subject to statutory limitation periods, whereupon it will be deleted.

You have the right at any time to request the deletion of all of your Personal Data (more details on deletion of Personal Data can be found in sections “What Are My Rights As User?” and “Questions?”) in accordance with the Terms & Conditions.

6. Who Processes My Personal Data?

CRDH Capital AG., Uraniastrasse 14, 8001 Zurich, Switzerland, registered with the Zurich commercial register under no. CHE-175.568.236, is the data controller.

CRDH Capital has several data processors to operate the Site and we may need to share some of your Personal Data with them.

CRDH Capital’s data processors can be categorized as:

• CRDH Capital’s directors, officers, employees, agents, counsels or other advisers (the “Representatives”);
• CRDH Capital’s legal advisors;
• CRDH Capital’s IT persons;
• CRDH Capital’s auditors;
• CRDH Capital’s administrators; and
• [CRDH Capital’s third-party service providers entrusted with its client relationship management.]

Unless we tell You differently, our data processors do not have any right to use the Personal Data we share with them beyond what is necessary to assist Us in providing the Site to You.

When we cooperate with data processors and they process your Personal Data on our behalf, we make sure that your Personal Data will be handled with the same integrity and security as we do.

7. How Safe Is It To Use the Site?

CRDH Capital carries out the Processing of Personal Data in compliance with the principles of correctness, fairness, lawfulness, transparency and confidentiality, and in accordance with any applicable law (such as the European GDPR and the Swiss FADP) or additional rules protecting these principles.

CRDH Capital takes appropriate technical and organizational measures to protect your Personal Data against loss or other forms of unlawful processing.

8. What Are My Rights as a User?

The rights with respect to Personal Data include your rights, at any time: (i) to receive confirmation regarding the Processing of Personal Data and the persons involved in the Processing of Personal Data, (ii) to access Personal Data, (iii) to obtain Personal Data in a structured and organized way, (iv) to object to the Processing of Personal Data, (v) to obtain rectifications of, to apply restrictions on, Personal Data and (vi) to be informed about any data breach of Personal Data.

As we Process your Personal Data for the performance of services to You, You may ask Us to refrain from Processing your Personal Data or have Personal Data erased or transformed into anonymous form only in accordance with the Terms & Conditions. If You do not agree on the Processing of your Personal Data, we will no longer process your Personal Data, but we will no longer be able to provide You with the services. If You no longer want Us to Process your Personal Data, simply terminate your use of the Site in accordance with the Terms & Conditions and ask Us to delete your Personal Data. Be aware that the termination of contract does not suspend You from other obligations according to the Terms & Conditions.

If You need more information on your Personal Data, let Us know by sending Us an email to office@planven.com.

9. Does CRDH Capital Use Cookies?

10. Revisions to This Privacy & Cookie Policy

We may from time to time change and adapt this Privacy & Cookie Policy and publish them on the Site, without giving the User specific notice thereof. CRDH Capital recommends that You review the Site from time to time and take note of any changes. If You do not agree with this Privacy & Cookie Policy, You should no longer use the Site. By continuing to use the Site, You accept any changes made to this Privacy & Cookie Policy.

11. Questions?

If You have any questions, email Us. If You have questions about the way CRDH Capital processes your Personal Data or the personal information CRDH Capital stores about You, please contact CRDH Capital by sending an email with your question to office@planven.com.