1. USER INFORMATION
Who is the controller of your personal data?
TOWER ALTERNATIVE INVESTMENTS SCA is the CONTROLLER of the USER’s personal data and informs you that these data will be processed in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR), as well as the Luxembourg Act of 1 August 2018 on the organization of the National Data Protection Commission and the general data protection framework (Loi du 1er août 2018 portant organisation de la Commission nationale pour la protection des données et du régime général sur la protection des données).
Why do we process your personal data?
To maintain and manage the professional, contractual, and commercial relationship with the USER. The planned processing operations are:
- Sending commercial advertising communications by email, SMS, MMS, social networks, or any other electronic or physical means, present or future, that enable commercial communications. These communications will be carried out exclusively by the CONTROLLER and will be related to its products and services, or those of its partners or suppliers with whom it has reached a promotional agreement. In this context, third parties will never have access to the personal data.
- Conducting market research, satisfaction surveys, and statistical analysis.
- Processing orders, corporate requests, responding to queries, or handling any type of request made by the USER through any of the contact methods available on the CONTROLLER’s website.
- Sending the corporate online newsletter with news, updates, offers, and promotions related to our activity.
Why can we process your personal data?
The processing is legitimized in strict compliance with Article 6 of the GDPR under the following legal bases:
- With the USER’s explicit consent (Art. 6.1.a GDPR): for sending commercial communications, promotional updates, and newsletters.
- For the performance of a contract or taking pre-contractual steps (Art. 6.1.b GDPR): for processing orders, managing technical requests, and executing requested interactions.
- In the legitimate interest of the CONTROLLER (Art. 6.1.f GDPR): for conducting market research, operational tracking, statistical analysis, and processing standard contact requests submitted by the USER.
How long will we keep your personal data?
Data will be stored for no longer than necessary to fulfill the purposes for which they are processed, or to comply with applicable statutory limitation periods under Luxembourg law (including commercial and tax retention obligations under the Luxembourg Commercial Code / Code de Commerce, which may mandate retention up to 10 years). Once no longer required for these purposes, the data will be permanently deleted, anonymized, or destroyed using appropriate, state-of-the-art security technical measures.
To whom do we disclose your personal data?
Personal data will not be communicated or disclosed to external third parties except where legally required by authorities or when strictly necessary for the technical development and execution of the processing purposes (such as IT hosting partners, cloud infrastructure providers, or logistical services). In all such cases, the CONTROLLER has executed mandatory Data Processing Agreements (DPAs) in accordance with Article 28 of the GDPR, ensuring that processors comply with identical strict confidentiality and data protection obligations.
What are your rights?
The USER holds the following statutory rights under the GDPR:
- Right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right of access, rectification, portability, and erasure (right to be forgotten) of their data.
- Right to restriction of processing and the right to object to processing.
- Right to lodge a complaint with the competent Supervisory Authority if they consider the processing does not comply with current regulations. In Luxembourg, the competent supervisory authority is:
Commission Nationale pour la Protection des Données (CNPD)
15, Boulevard du Jazz, L-4370 Belvaux
Web: www.cnpd.lu
Contact information to exercise your rights:
TOWER ALTERNATIVE INVESTMENTS SCA
85, GRAND – RUE L-1661 LUXEMBOURG
E-mail: info@azurgroup.eu
2. COMPULSORY OR OPTIONAL NATURE OF THE INFORMATION PROVIDED BY THE USER
By checking the corresponding validation boxes and entering text or values in fields marked with an asterisk (*), the USER explicitly, freely, and unequivocally accepts that their data are strictly necessary for the fulfillment of their specific request. The USER guarantees that the personal data provided to the CONTROLLER are accurate and assumes full responsibility for communicating any modifications or updates thereto.
The CONTROLLER informs the USER that all fields requested via the website marked as mandatory are strictly necessary to provide an optimal, high-quality service and ensure functional processing. Should the USER choose not to provide the requested data, the CONTROLLER cannot guarantee that the information, products, or services requested will be fully customized or accurately delivered.
3. SECURITY MEASURES
In accordance with current data protection regulations, the CONTROLLER strictly complies with all provisions of the GDPR and applicable Luxembourg legislation, implementing the fundamental data protection principles set forth in Article 5 of the GDPR.
The CONTROLLER guarantees that appropriate technical and organizational security measures have been engineered and deployed to protect the integrity, confidentiality, availability, and resilience of the data, thereby safeguarding the rights and structural freedoms of the USERS.
For any further information, inquiries, or clarifications regarding this Privacy Policy, the USER may contact the CONTROLLER directly:
TOWER ALTERNATIVE INVESTMENTS SCA
85, GRAND – RUE L-1661 LUXEMBOURG
E-mail: info@azurgroup.eu