Cedrus Capital is subject to the duty to protect the personal data it collects and has access to in the performance of its functions, in accordance with the provisions of Regulation (EU) 2016/679 (hereinafter "GDPR") 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 and Law No. 58/2019, which ensures the implementation, in the domestic legal system, of the GDPR.
This Policy contains the rules applicable to the collection and processing of personal data by all companies belonging to Cedrus Capital, in accordance with the GDPR.
These rules do not replace any clauses that are the subject of a specific agreement with any customer, partner or supplier. In such case, this Policy may supplement, but does not replace, such documents. The terms "holder" and "user" are used interchangeably in this Policy to designate the holder of the personal data.
This Policy applies to all personal data received, and it is up to all Cedrus Capital employees to guide their activity towards strict compliance with the legal provisions in force, as well as the rules and procedures established in this document.
Cedrus Capital, in the processing of personal data, guides its activity towards strict compliance with the following principles:
The person responsible for the processing of the personal data collected is Cedrus Capital, with registered office at Avenida da Liberdade n.º 262, 4.º Esq., 1250-149 Lisboa, registered at the Commercial Registry Office of Lisbon, with the single registration number and legal person 516148834, with a share capital of EUR 125,000.00 (one hundred and twenty five thousand euros).
Currently, Cedrus Capital manages specialised alternative investment undertakings (OIA) and carries out the activities necessary to pursue its corporate purpose under the terms provided for by law.
To this end, Cedrus Capital needs to collect personal data for the following purposes:
"Personal data" means information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, online identifiers or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.
Cedrus Capital collects the following categories of personal data: name, nationality, date of birth, identification document number, type of identification document, address, tax number, telephone number, profession, employer, e-mail, PEP (Politically Exposed Person), experience and knowledge in financial instruments and markets, investment objectives and characterization of the financial situation.
Cedrus Capital has access to personal data by filling in the forms that are available on its website, which are filled in by the holder of the personal data.
Cedrus Capital may transmit your personal data:
No personal data is transferred outside the European Union.
Cedrus Capital will keep your personal data only for the period necessary for the purposes described in this Policy. However, it may be necessary to retain certain personal data for a longer period for the purpose of complying with legal obligations.
Beyond these periods, some personal data may be kept for archival or statistical purposes, in which case they are anonymised.
Cedrus Capital will maintain data security, protecting the confidentiality, integrity and availability of personal data.
To ensure data security, Cedrus Capital adopted technical and organizational measures to prevent unauthorized use or access, modification, illicit or accidental destruction and accidental loss, backup copies, and disaster recovery procedures.
The data subject has at any time, the right to access, rectify, update or delete their personal data, as well as the rights of portability, limitation and opposition to the processing of the same.
The data subject may exercise any of these rights in writing through the contacts provided in this Policy and must identify themselves in all communications with their full name and respective tax identification number (NIF).
In the event of a dispute regarding the use of their personal data, the data subject has the right to file a complaint with the National Data Protection Commission (CNPD).
This Privacy Policy is effective as of 18-09-2020. Cedrus Capital may change this policy from time to time, in order to reflect changes in legislation or changes on the website itself and its contents.
Any significant changes will be communicated with the same degree of publicity as when you launched your initial version.
The Privacy Policy is accessible for consultation by any interested entity at www.cedruscapital.pt.