Website Privacy Notice

For the purpose of this Privacy Notice:

• “Data Protection Law” means data protection law applicable in Luxembourg, 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 (the “GDPR”) and the Law of 1 August 2018 on the organisation of the CNPD and the general data protection framework;
• “Personal Data”, “Processing”, “Purposes”, “Controller”, “Processor”, “Data Subject”, “Recipient”, “Appropriate Safeguards” and “Supervisory Authority” shall have the meaning ascribed to them in the GDPR;
• “we”, “us” and “our” shall refer to the Bank; and
• “you” and “your” shall refer to the Data Subject in connection to the personal data processing.

2. Controller Identity and Contact Details

We are:
FundBank (Europe) S.A.
13 Rue Jean Fischbach,
3372 Leudelange,
Luxembourg
Email: dataprivacy_lux@fundbank.com

3. Personal Data We Process

We collect personal data when persons interact with our website, which may include:

1. 1. Identifiers/Contact Information. When you contact us through the website, or directly via email or phone, we collect certain personal data from you, such as your name, company name, email address, phone number (if contact via phone), industry, your message including any personal data that you otherwise submit to us.
   2. Survey Responses. When you fill out our surveys, we may collect your survey responses, including information regarding preferences, your opinion about our Services or the survey topic. Participation in our surveys is voluntary.

We also collect and derive personal data related to your use and interaction with our website by means of cookies and other tracking technologies. Such information may include:

1. 3. Device and Browsing Information. We may collect device IP address, general location information, domain name, pageviews, date and time stamps, browser type, device type, device ID, Internet service provider, referring and exiting URLs, device operating system, language, clickstream data, and similar device and usage information.
   4. Activities and Usage. We also collect activity information related to your use of the services, such as information about links clicked, searches, features used, pages viewed, and time spent within the services.

We may collect (depending on the nature of the services and your role), your personal data when you work in a professional capacity with FundBank but not in the context of a client relationship (e.g. FundBank contractors and suppliers), which may include:

1. 5. Professional Information. When you work with us in your professional capacity, information about your company/employer, postal address, and phone number, your email address, and your position with the company. Depending on the role, this may extend to information demonstrating your professional qualifications and skills.
   6. Communications and Interactions. When you email or otherwise communicate (in written) with us or members of our team, we collect and maintain a record of your communications.
   7. Signed Contracts. We collect names and signatures of the signatories of contracts / order forms on behalf of your organisation where applicable.
   8. Video recording. You may be recorded either in the context of recorded virtual meetings or the CCTV systems installed in the premises of the Bank.
   9. IT and security-related data. If you are a contractor authorised to work on FundBank premises and/or to have access to FundBank IT systems, personal data processed may include user accounts in IT systems including physical access control system for badge access, IT system logs (access and usage), communication records (when using FundBank communication tools).

Finally, we collect your personal data when you attend events organised by FundBank, which may include:

10. 10. Event registration information. If you register for or attend an event that we host or sponsor, we may collect personal data related to your registration for and participation in such event including name, email address, phone number, company name, industry, job title.
    11. Event survey. After the event, we may invite you to complete a survey. These would usually be anonymous and used to improve our services.
    12. Photos and video recordings. We may take photos or videos during the event for public relations. These may be used on our website, social media, or shared with media and event partners. You can object at any time by contacting dataprivacy_lux@fundbank.com.
    13. Further communications and events. If you wish to be informed about future events or services provided by FundBank.

4. Purpose of Processing and Legal Basis

We use the personal data you provide:

Legal bases	Purposes	Categories of Personal Data (by reference to information referred to under Section 3 above)
For the fulfilment of contractual obligations (Art. 6 para.1b GDPR)	To receive and manage services from suppliers and service providers. To provide access to internal IT systems and resources (for contractors).	(e), (f), (g), (i)
In the context of our legitimate interest not overriding your interests or fundamental rights and freedoms (Art. 6 para. 1f GDPR)	To answer inquiries or establish a professional relationship.	(a), (e)
	To prevent fraud and misconduct and protect the Bank. To ensure the security of office premises and safety of individuals. To manage and secure the use of the Bank’s IT systems and data.	(c), (f), (h), (i)
	For event planning and management, including registration, attendance, surveys/feedbacks, event promotion (e.g. photos) on website or social media.	(j), (k), (l)
Based on your consent (Art. 6 para. 1a GDPR)	To administer surveys, such as for market research, conduct statistical and data analytics, to improve our products and services; To contact you about other relevant FundBank events and/or services offered by FundBank or our affiliates. To use non-essential cookies on the website to improve our services and your experience on the website.	(b), (d), (m)

 

5. Sharing Your Personal Data

Set out below are the parties with which FundBank may share personal data:

• Our outsourced service providers where involved in processing personal data on our behalf (i.e., acts as data processor), including, for example, our information technology service providers.
• FundBank affiliates or members of our corporate group or under common majority ownership with us, including internal service companies.
• Analytics and advertising network providers, sponsors, or traffic measurement services, who may use this information to help us better understand how users access and use the services and to improve and measure the effectiveness of our advertisements and those of other parties.
• When we believe it is appropriate to do so to investigate, prevent, or take action regarding suspected illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our supplier / service provider agreements, site or services terms of use, or other agreements we have with you or this Privacy Policy, or as evidence in litigation in which we are involved.

Each data sharing is thoroughly assessed to ensure adequate mechanisms are implemented prior to data disclosure i.e. use of consent, implementation of data processing agreements with service providers, etc.

6. Third Country Transfer

Recipients referred to in previous section can be located outside of Luxembourg and the European Economic Area. In those cases, except where the relevant country has been determined to provide an adequate level of protection, we require such recipients to comply with appropriate measures designed to protect personal data including use of standard contractual clauses where applicable.

7. Data Security

FundBank has implemented a comprehensive information security framework consisting of strategies, policies, procedures, IT protocols and tools to duly and adequately protect Bank information assets including personal data and IT assets including IT systems processing personal data. We have also put in place procedures to deal with any suspected data security breach and will notify you and competent data protection authority of a suspected breach when regulatory conditions are met.

8. Retention of Personal Data

FundBank will retain your personal data for the duration of your relationship with FundBank or for as long as reasonably necessary to fulfil the purposes for which it was collected, and, or to enable FundBank to be able to deal with any complaint, claim, or dispute that might arise. For service provider / supplier relationships, data is typically retained for 10 years after the end of the relationship. CCTV video recordings are retained no longer than 8 days. Event attendees’ information is retained for 2 years unless you consented to be contacted for future FundBank events and services. When personal data is collected on the basis of consent, the latter can be withdrawn by contacting dataprivacy_lux@fundbank.com.

9. Your Rights

You have the following rights regarding your personal data (under certain circumstances, and without prejudice to applicable laws and regulations):

• The right to access your personal data.
• The right to correct any inaccurate or incomplete personal data.
• The right to request the deletion of your personal data.
• The right to restrict the processing of your personal data.
• The right to object to the processing of your personal data.
• The right to data portability.
• The right to withdraw your consent at any time (only where consent is used as legal basis).

To exercise these rights, please contact us at dataprivacy_lux@fundbank.com.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded or excessive.

You also have the right to lodge a complaint with the Data Protection Authority at: https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html

10. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. If we make any material changes to reflect changes to our practices or for other operational, legal, or regulatory reasons, we will bring this to your attention and may do so by any means such as by e-mail, letter, or otherwise post a notice on our website and update the “Last Updated” date at the bottom of this Privacy Notice. A copy of the latest version may be requested from dataprivacy_lux@fundbank.com at any time.

11. Contact Us

If you have any questions about this Privacy Notice, please contact us. Please refer to contact details under section 2.

Last Updated: July 1, 2025