1. Why are you seeing this notice?
You have provided or may need to provide Personal Data to us as part of your agreement with Moonfare GmbH (“Moonfare“).
We want you to understand how and why we use, store and otherwise process your Personal Data when you deal with us or our relevant affiliates.
This Data Privacy Notice applies to you to the extent that EU data protection legislation applies to our processing of your Personal Data or to the extent you are a resident of the EEA. If this Data Privacy Notice applies to you, you have certain rights with respect to your Personal Data which are contained in this Data Privacy Notice.
“Personal Data” has the meaning given in the EU data protection legislation and includes any information relating to an identifiable individual (such as name, address, date of birth or economic information).
2. Who is providing this notice?
This privacy statement is made on behalf of Moonfare. Moonfare is committed to protecting and respecting your privacy.
Where we use the terms “we“, “us” and “our” in this Data Privacy Notice, we are referring to Moonfare.
When you provide (or have provided) us with your Personal Data, Moonfare acts as a “data controller“. In simple terms, this means that:
3. What Personal Data do we collect about you?
The types of Personal Data we process, hold and share depends on the product or service you have with us and the nature of your investment. This can include or be related to:
The Personal Data collected about you will help us provide you with a better service and facilitate our business relationship.
4. Where do we obtain your Personal Data?
We collect, and have collected, Personal Data about you from a number of sources, including from you directly:
Personal Data that you give us:
Personal Data we obtain from others:
5. Why do we process your Personal Data?
We process your Personal Data for the following reasons:
It is necessary to perform our contractual obligations with you to:
It is necessary for compliance with an applicable legal or regulatory obligation to which we are subject to:
For our legitimate interests or those of a third party to:
We only rely on these interests where we have considered that, on balance, our legitimate interests are not overridden by your interests, fundamental rights or freedoms.
Monitoring as described at (3) above
We monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with our regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems.
6. Who we share your Personal Data with
Your Personal Data will be shared with:
We share your Personal Data with our Associates and related parties. This for:
In exceptional circumstances, we will share your Personal Data with:
7. Do you have to provide us with this Personal Data?
Where we collect Personal Data from you, we will indicate if:
Unless otherwise indicated, you should assume that we require the Personal Data for business and/or compliance purposes.
Some of the Personal Data we request, or have requested, is necessary for us to perform our contract with you and if you do not wish to provide us with this Personal Data, it will affect our ability to provide our services to you and manage your investment.
8. Sending your Personal Data internationally
We may transfer your Personal Data to members of our group, managers of the Partnership and related parties, managers of the target fund a Partnership intends to invest in and related parties, and third party service providers outside of the EEA, which may not have similarly strict data protection and privacy laws.
Where we transfer Personal Data to other members of our group, or our service providers, we have put in place data transfer agreements and safeguards using European Commission approved terms.
Please contact us if you would like to know more about these agreements or receive a copy of them. Please see below for our contact details.
9. Consent – and your right to withdraw it
We do not generally rely on obtaining your consent to process your Personal Data.
If we do, you have the right to withdraw this consent at any time.
Please contact us or send us an email at firstname.lastname@example.org at any time if you wish to do so.
10. Retention and deletion of your Personal Data
We keep your Personal Data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us.
As a general principle, we do not retain your Personal Data for longer than we need it.
We will usually delete your Personal Data (at the latest) after you cease to be an investor in any fund and there is no longer any legal or regulatory requirement or business purpose for retaining your Personal Data.
11. Automated decision-making
We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of Personal Data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the requirements of EU data protection legislation and other applicable laws.
12. Your rights
You have certain data protection rights, including:
From 25 May 2018, you also have the right in some circumstances to request for us to “port” your Personal Data in a portable, re-usable format to other organisations (where this is possible).
14. The use of tracking technologies
The use of Google Analytics:
15. Concerns or queries
We take your concerns very seriously. We encourage you to bring it to our attention if you have any concerns about our processing your Personal Data.
This Data Privacy Notice was drafted with simplicity and clarity in mind. We are, of course, happy to provide any further information or explanation needed. Our contact details are below.
If you want to make a complaint, you can also contact the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose. A list of the EU data protection authorities is available by clicking this link: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
16. Contact us
Please contact us if you have any questions about this Data Privacy Notice or the Personal Data we hold about you.
Contact us by email at email@example.com.
Contact us in writing using this address:
17. Changes to this Data Privacy Notice
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Data Privacy Notice at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Data Privacy Notice regularly for changes. You can determine if changes have been made by checking the Effective Date below. Your continued use of our website following the posting of any changes to this Data Privacy Notice means you consent to such changes.