Privacy notice


Royalton Partners S.A. (Royalton Partners) is an authorized Alternative Investment Fund Manager headquartered and regulated in Luxembourg.

Royalton Partners is subject to the EU General Data Protection Regulation 2016/679 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 (“GDPR”) and any data protection law applicable in Luxembourg or other jurisdictions concerned.

This privacy notice (“Privacy Notice”) sets out how Royalton Partners S.A. will process personal data as defined below in its capacity as data controller and data processor. The identity of the data controller or data processor for data protection purposes will vary depending on the interaction with Royalton Partners as defined in the contractual arrangements.


I. The types of personal data we process

We collect and process a range data about individuals we deal with and those linked to our clients
and other counterparties.

Such information may include:

  • Personal details, such as name, home/professional address and other contact details, date of birth, nationality and marital status, tax and social security identifiers, employment history etc.;
  • Identification documentation, such as copies of your passport, ID card or other documentation required by law;
  • Details of your visits to our premises;
  • Information provided through our recruitment process;
  • Details of your visits to our websites;
  • Information regarding entities with which you are connected, including your employer; your advisors; banking and other service providers; and entities in which you have an interest;
  • Your marketing and other preferences;
  • Information, which you provide to us in the course of engagement with us;
  • Special category data, when required for the purposes of our legal and/or regulatory obligations


II. Purpose and legal basis for the processing

We are entitled to hold and process your personal data on the following lawful grounds:

  • for the purpose of concluding a contract and then performing that contract;
  • to comply with our legal and regulatory obligations;
  • the processing is necessary for our legitimate interests provided your interests and fundamental rights do not override those interests;
  • where we have obtained the necessary consent;
  • exceptionally, where we need to protect your interests (or someone else’s interests); and/or where it is needed in the public interest.


Some of the above grounds for processing described above will overlap and there may be
several grounds, which justify the use of your personal data.


III. Data Subjects’ rights

You have the right, under certain circumstances, to the following rights in respect of personal data:

  • the right to access and where relevant to port personal data;
  • the right to rectify personal data;
  • the right to restrict the processing or use of personal data;
  • the right to request that personal data is erased (“the right to be forgotten”);
  • the right to object to processing or use of personal data where we have considered this to be necessary for our legitimate interest;
  • where consent have been obtained, the right to withdraw the consent any time


You also have the right to lodge a complaint with the Luxembourg Data Protection Authority (CNPD) or a Supervisory Authority in the EU member state of your usual residence or place of work or of the place of any alleged breach of data protection legislation.


IV. Data accuracy and data minimization 

Royalton Partners will ensure that the personal data it processes is accurate and up-to-date and is limited to the relevant purpose of the processing.


V. Retention period and security measures 

Royalton Partners is obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, and legitimate business purposes. In general, Royalton Partners will hold this information for a period of ten years after the end of the business relationship, unless it is obliged to hold it for a longer or shorter period under law or applicable regulations.

Royalton Partners has/will maintain the appropriate technical and organisational security measures in order to protect your personal data against loss, destruction, theft, misuse, unauthorised access, modification or alteration.


VI. International transfers

Due to the international nature of our business, personal data may be transferred within the EEA and exceptionally outside the EEA, such as to jurisdictions where we conduct business or have a service provider, including countries that may not have the same level of data protection as that required by EEA data protection laws. In the latter case as well, Royalton Partners will take all necessary steps to ensure that personal data is treated securely, and that appropriate safeguards (in particular standard contractual clauses) are in place to protect privacy and integrity of such personal data in accordance with the applicable data protection laws.


VII. Our contact details 

Please contact Royalton Partners at 22-24, boulevard Royal, L-2449 Luxembourg (Attention: Katrin Katzenberger; with any questions about this Privacy Notice or requests with regards to personal data with hold.