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The purpose of this document is to provide you with information on our use of your personal data in accordance with the data protection law applicable to the Grand-Duchy of Luxembourg, including the law of 2 August 2002 as amended by Regulation EU 2016/679 of 27 April 2016 on the protection of natural persons relating to the processing and the free movement of personal data (all referred to as “Data Protection Law”).

Please read carefully the below information.

This Privacy Policy may be amended form time to time with no need to obtain your prior consent to such changes.


Who is the data controller?

The data controller is Pegaso Capital SICAV, with registered office at 4, rue Thomas Edison L-1445 Strassen (hereinafter the “Data Controller” or the “Company”).

The controller, pursuant to the Data Protection Law is “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law”.

In this document “we”, “us”, and “our” refer to the Company.


Which Personal Data we hold and process?

We are in charge of processing personal data within the framework of your participation in the Company.

The Personal Data that we may collect, store and process include but is not limited to your name, address, date and place of birth, gender, information on your identification documents, contact details (e-mail address, telephone number), bank and financial data, transaction history of each investor, data concerning personal characteristics, information you provide us by completing forms or contacting us, information about our business relationship, your creditworthiness and solvency (hereinafter referred to as “Personal Data”).

In case the investor is a legal person, the Company may collect, store and process Personal Data concerning contact persons and “controlling persons” who are natural persons exercising control over the entity investing in the shares of the Company.


How may we use your Personal Data?

Your Personal Data is processed by electronic or other means in order to enter into and execute the subscription in the Company, for our legitimate interests and to comply with the legal obligations imposed on us as Data Controller.

In particular, the Personal Data supplied by you, as investor, is processed for the purposes of:

  1. subscribing in the Company,

  2. maintaining the shares register;

  3. processing investments and withdrawals of and payments of dividends to the shareholders;

  4. account administration;

  5. opening, closing and blocking of accounts in the name of the shareholders,

  6. sending legal information or notices to the shareholders,

  7. complying with applicable anti-money laundering rules and other legal obligations, such as maintaining controls in respect of CRS/FATCA obligations.

Personal Data is not used for marketing purposes.


To whom we may transfer and who may use your personal data?

Your Personal Data may also be processed by the Data Controller’s data processors (the “Data Processors”) which, in the context of the above mentioned purposes, refer to the Management Company, the Registrar and Transfer Agent, the Domiciliation and Listing Agent, the Authorized Independent Auditor and the legal advisors. The Depositary and Fund Administrator of the Fund, in the framework of its depositary’s and administrator’s activities, will act as Data Controller. The Global Distributor and the appointed sub-distributor(s) as well as the appointed local paying agents may act, as the case may be, either as Data Controller or as Data Processors.

The Data Processors may, under their own responsibility and only under prior general authorization of the Data Controller, disclose the Personal Data to their agents and/or delegates (the “Sub-Data Processors”), which shall process the Personal Data for the sole purposes of assisting the Data Processors in providing their services to the Data Controller and/or assisting the Data Processors in fulfilling their own legal obligations and in compliance with the same level of protection of Personal Data as applied to the Data Processors.

Data Processors and Sub-Data Processors may, as the case may be, process the Personal Data as Data Processors (when processing the Personal Data upon instructions of the Data Controller), or as distinct data controllers (when processing the Personal Data for their own purposes, namely fulfilling their own legal obligations).

The Personal Data may also be transferred to third-parties such as governmental or regulatory agencies, including tax authorities, in accordance with applicable laws and regulations. In particular, Personal Data may be disclosed to the Luxembourg tax authorities which in turn may, acting as data controller, disclose the same to foreign tax authorities.

It should be noted that the Company and its Data Processors and Sub-Data Processors may, subject to applicable data protection laws, disclose Personal Data to a regulatory, fiscal or judicial authority as required under local applicable laws and regulations.


Transfer of Personal Data abroad

Personal Data collected may be processed and stored on a cross-border basis within entities located in EU Member States and/or outside EU (including Switzerland) having equivalent data protection requirements.  The European Commission has passed an adequacy decision for Switzerland in accordance with art 45 of Regulation EU 2016/679 of 27 April 2016, meaning that Switzerland offers a sufficient level of Data Protection.

By subscribing for Shares of the Company, you agree to the aforementioned processing of your personal data and in particular, the disclosure of your personal data to, and the processing of your personal data by, the parties referred to above including affiliates situated in countries outside of the EU.


Refusal to communicate Personal Data

At your discretion, you may refuse to communicate the Personal Data to us. In this case, however, we may reject your request for subscription or holding of shares in the Company or proceed with the compulsory redemption of all shares already held, as the case may be, under the terms and conditions set forth in the Articles of Incorporation and in the Prospectus of the Company.


Your Data Protection rights

In accordance with and subject to the conditions laid down by the Data Protection Law, you have rights concerning your Personal data:

  • the right to access your Personal Data;

  • the right to correct your Personal Data where it is inaccurate or incomplete;

  • the right to object to the processing of your Personal Data;

  • the right to ask for erasure of your Personal Data;

  • the right to ask for Personal Data portability.

A complete list of such rights is contained in the Data Protection Law.

You can exercise the above rights by writing to us at the following address: 4, rue Thomas Edison L-1445 Strassen.

You also have right to lodge a complaint with the competent supervisory authority (in Luxembourg, the National Commission for Data Protection, 1, avenue du Rock’n’Roll, L-4361 Esch-sur-Alzette, Luxembourg, Tel.: (+352) 26 10 60-1,


How long do we keep your Personal Data

Your Personal Data shall not be held for longer than necessary with regard to the purpose of data processing observing legal periods of limitation.

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