Privacy Policy

The controller for the processing of your personal data within the meaning of Regulation (EU) 2016/679 of April 27, 2016 (General Data Protection Regulation, hereinafter referred to as "GDPR“) is Alceda Fund Management S.A. We recognise the trust you are placing in us. Therefore we would like to provide comprehensive information to you on how we handle your personal data. In particular, we would like to inform you on the type of data we collect when you visit and/or use our website and our online services and on how we use this data. If we have received personal data from you through other communication channels (e.g. by e-mail), the following Privacy Notice applies as well.

On our website we use various technologies that are meant to improve user friendliness, effectiveness and security. In this context we, or third parties used or contracted by us (providers of technical services), may collect data.

Given that our website and the technologies on which it is based are subject to continuous development, the Privacy Notice may need to be changed too. All future changes will be published on this website.

1. Legal regulations

We take the protection of your personal data very seriously. We process personal data in accordance with the data protection regulations of the country in which the registered office of Alceda Fund Management S.A., as the controller, is located.

To provide comprehensive protection of your personal data, we comply with the relevant legal provisions of the Data Protection Act of Luxembourg and the GDPR, as well as all applicable enabling provisions of data protection law.

2. Responsibility

We, Alceda Fund Management S.A., represented by the managing directors Dr Harald Schönebeck, Désirée Eklund, Jens Eisenbart and Albert Sowa, Airport Center Luxembourg, 5 Heienhaff, 1736 Senningerberg Luxembourg (Tel.:+352 248 329-1 / receptionist, Fax: +352 248 329-442), as the provider of this website, are the controller within the meaning of Art. 4(7) GDPR.

3. Contact data of the data protection officer:

The data protection officer of the Aquila Group can be reached as follows:

Alceda Fund Management S.A.
c/o the data protection officer
Airport Center Luxembourg
5, Heienhaff,
1736 Sennigerberg Luxembourg

4. Restriction of the scope of this Privacy Notice for visits to our website

Our Privacy Notice only applies to our content which is stored on our servers. It expressly does not cover any links to websites of third parties in our offerings.

5. Collection of personal data in the context of informational use

If you only use our website for informational purposes, we do not collect any personal data aside from the data transmitted by your browser to enable you to visit the website.

That data is:

  1. Date and time of your request
  2. Duration of your visit
  3. Time zone difference compared to Greenwich Mean Time (GMT)
  4. Content of the request (specific page)
  5. Access status / HTTP status code
  6. Website & provider from/by which the request is made
  7. Browser
  8. Operating system
  9. Language and version of the browser software

We store data related to the end device in order to create use statistics, for example, or to identify and trace unauthorised attempts to access our web servers. We only create profiles regarding the use of our website in anonymised form and only to improve user navigation and optimise our products and services. We do not create or process behaviour profiles relating to a specific person from the aforementioned information.

In addition to the aforementioned data, cookies are stored on your computer when you use our website. For more details on cookies, see section 15 of this Privacy Notice.

6. Collection of personal data during the use of our website features

  1. We only store personal data, such as your e-mail address or your name, if you choose to provide this information to us, e.g. in the context of an application or for the performance of a contract (principle of direct collection).
  2. If you want to search for information on specific products via the tabs “Products” and then “All Funds”, we collect the following data from you: your status as an institutional or a private investor, your country of origin, and information on the pages you have visited on our website.
  3. In addition, we use the data you directly provide mainly in the following areas:
    1. We use your personal data for correspondence.
    2. We use your personal data to occasionally inform you about our products and services, as well as new developments.
  4. If you also use our website to provide a profile/resume to us, we will also use that personal data to create our own professional profile for you in accordance with this Privacy Notice. Given that we will store your work history in this case, your submission must not contain any sensitive information with respect to race or ethnic origin, political opinions, religion or beliefs, trade union or political party memberships, genetic, physical or mental health status, dependencies, sexual orientation, criminal offences or criminal proceedings and related penalties or fines, social security number or national ID. If your profile contains such information regardless, you agree that we may store that information and also use it in accordance with this Privacy Notice. Please also note that where you provide information of a third party to us as a reference you are responsible for ensuring that the person involved is aware of your disclosure of his/her personal data and has provided his/her written consent to this disclosure.

7. Disclosure to third parties

  1. To facilitate the purposes described we may exchange your data with third parties we use to process orders and inquiries. In this context we may provide access to your information to third parties that support our provision of services to you. Examples are third parties used to manage our web servers and to analyse data who may be able to access your data in this context.
  2. If you make your personal data available to us for the purpose of potential future cooperation, potential investments and/or to enable us to contact you, we may disclose this data to affiliated companies (as defined in Sections 15 et seqq. of the German Stock Corporation Act).
  3. Otherwise we only provide your personal data to third parties if we are obligated to do so by compulsory legal regulations, if you ask us to do so or have consented to the disclosure, or after the data has been anonymised or pseudonymised.
  4. We only transfer data to third parties established in a third country with your consent or to fulfil our contractual obligations pursuant to GDPR 44 et seqq.

8. Contract processing

We may contract third party service providers for the systemic processing of personal data. In this case the personal data are only processed at our instruction and only for the purposes specified in compliance with requirements of data protection law.

9. Legal grounds

Personal data are processed based on Art. 6 GDPR .

10. Consent

By using our website and/or submitting your personal data, you consent to the storage and use of your data as described. By entering your personal data you consent to the processing of the data and their use, including their disclosure to third parties, as described. If you provide personal data of third parties to us, you are responsible for ensuring that the data subjects have consented to the disclosure and processing of the personal data.

11. Revocation

You can revoke your consent to our use or disclosure of your personal data at any time and with future effect, for example by sending an e-mail to .

12. Data storage period

The storage period of your personal data depends on the extent of the cooperation or the existing contractual relationship.

If you only visit our website, the data storage is limited to 14 months.

If you provide application documents for employment with Alceda Fund Management S.A. to us, your personal data is stored for processing and is deleted after a period of four (4) months if there is no other legal ground for storing your personal data.

If you are interested in an investment and provide personal data to us for this reason, we only store your data until you revoke your consent or until the expiry of the period permitted by law.

If there is a contractual relationship, data are stored even after the termination of the contractual relationship to comply with legal obligations, such as legally required retention periods and obligations to provide information. We also store your data to provide further information about our products to you. If you do not want us to contact you for informational purposes, please send us a mail to the following address: .

13. Data security

  1. Alceda Fund Management S.A. and the companies affiliated with it take diligent precautions to protect your data managed by us against manipulations, loss, destruction and against access by unauthorised persons. We continuously improve our security measures in accordance with the development of technology.
  2. Our employees are obligated to maintain data confidentiality in accordance with the provisions of the German Federal Data Protection Act.

14. Technologies used

Parts of this website may use technologies that are widely used on the internet, such as JavaScript, Java, Flash or ActiveX, to allow us to present the information requested in a form that is more convenient for you. We do not use these technologies in any way to spy out personal data or manipulate data on your computer.

15. Cookies

  1. We need certain information to enable us to design our websites based on user needs. For the collection of this information we also use cookies. Cookies are meant to facilitate the use of the internet and communication. Cookies are stored on your PC or another end device to anonymously identify the device and to support the application when you return to our websites.
  2. If you want to, you can suppress the storage of cookies in general through your web browser or you can decide if you want to be asked if a cookie should be stored or not. However, if you do not accept cookies, some pages may not be displayed correctly any more.
  3. This website uses the following cookies:
    1. Transient cookies (temporary use)
    2. Persistent cookies (use for a limited time)

      Transient cookies are deleted automatically when you close your browser. They specifically include session cookies. Session cookies store a “session ID” which allows to allocate various requests from your browser to a joint session. This allows the website to recognize your computer when you return to the website. Session cookies are deleted when you log out or close your browser.Persistent cookies are deleted automatically after a specified period which may vary depending on the type of the cookie. You can delete the cookies at any time in the security settings of your browser.

      You can configure your browser settings according to your preferences and may refuse to accept individual or all cookies, for example.

      More information on how cookies work can be found on the following website: http://www.allaboutcookies.org.
  4. The data generated by the cookies will not be linked to your other data.

16. Google Analytics

This website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics uses “cookies”. As mentioned above, cookies are text files that are stored on your computer and enable us to analyse your use of the website. The information on your use of this website generated by the cookie is transferred to a Google server in the USA and is stored there. Google will use this information to analyse your use of the website, prepare reports on the website activities for website operators and provide other services related to the use of the website and the internet. This is also where our legitimate interest in data processing lies. The legal basis for the use of Google Analytics is § 15 para. 3 TMG and Art. 6(1)  f. GDPR. The data sent by us and linked with cookies, user IDs (e.g. user ID) or advertising IDs are automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month. Google may also transfer information to third parties if this is required by law or if this data is processed by third parties on behalf of Google. Google will not connect your IP address with other Google data under any circumstances. By using this website you agree that Google may process the data collected about you in the above described manner and for the above specified purpose. You can also prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at: https://tools.google.com/dlpage/gaoptout?hl=de

By activating the add-on that can be downloaded through this link you effectively object to the collection, use and processing of your data by Google Analytics.

This website uses the anonymisation option provided by Google Analytics. We only collect your IP address in shortened form which means it cannot be traced back to you.

If you object to the use of cookies, we place a simple cookie which expires after your browser session and only memorises that data should not be collected about you.

17. Your rights

You have the following rights with respect to your personal data:

– Right of access,

– Right to rectification or erasure,

– Right to restriction of processing,

– Right to object to processing,

– Right to data portability.

Please e-mail us at if you wish to exercise any of these rights. You also have the right to complain with a data protection supervisory authority about our processing of your personal data.