Legal & Compliance

This privacy statement (the “Privacy Statement”) is maintained by Good Harvest Ventures Management S.à r.l. for and on behalf of itself and for all the Astanor Entities (as defined in the List of Astanor Entities, as amended from time to time and available upon request) (collectively, “Astanor” “Astanor Ventures”, “we”, “us” or “our”). This Privacy Statement explains how Astanor collects, stores, shares, protects, and uses personal information of our website visitors, business contacts, investment advisors, investors and management teams involved in business relationship or a potential business relationship with Astanor (“you”, “your”).

General Statement
We are committed to ensuring that your privacy is protected, and any data you provide will be used in accordance with Regulation 2016/679 (EU) 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 (GDPR) as well as any adapting or implementing text (together Data Protection Law). This Privacy Statement may be updated from time to time in accordance with applicable Data Protection Law.

Collection of Personal Data
(a) How do we collect personal information?
If you contact us notably through the submission of forms on astanor.com (our Website), social media channels, by post, phone, email, or in person, we may retain the communication for records, including any information included within it. We also may make use of systems that collate publicly available information. In addition, there is information that is collected automatically when you visit our Website, such as IP addresses.
(b) What personal information do we collect from you?
You may communicate to us from time to time, in which context we may collect the following

Personal Data:

1. Name, job title and company name;
2. Contact information including e-mail address and phone number;
3. Employment and education details mentioned in any documents or resumes you send us;
4. Information required for Astanor Ventures to meet legal and regulatory requirements, particularly in respect of anti-money laundering legislation;
5. Meetings attended in and visits to our offices; and
6. Electronic identification data such as information concerning the name of the domain and host from which you access the internet, the browser software and operating system of your computer, the internet protocol (“IP”) address of your computer and the internet address of the site from which you linked directly to the Website will be collected and stored;
7. Traffic data (date/time you accessed the Website); and
8. Any other information you send to us.

(c) How long will we retain information?

1. As regards information you provided on our on-line forms: for the time necessary to respond to your question or handle your request. The retention of such information will normally not exceed two years from registration, unless you have requested us to delete such information or application, subject however to our legal obligations; and
2. As regards technical data collected during your use of our Website: for a maximum period of time of six months from the date of collection.

Note that data may be kept longer for permitted purposes, upon prior notification to the data owner.
(d) How is the information used?
We use data (including personal data) for the following purposes and on the following lawful basis:

1. To carry out any obligations under a contractual agreement or for pre-contractual measures between us (contractual basis);
2. For our legitimate interests (to manage our relationship with you, for internal record keeping, to identify, evaluate, and execute in- and divestment opportunities);
3. To monitor and support portfolio companies;
4. To contact you for administrative and promotional purposes relating to our services, for internal record-keeping, to administer, protect and improve our Website, to handle potential claims and disputes): you can opt-out at any time by emailing privacy@astanor.com; and
5. To comply with legal obligations, particularly in respect of tax, accounting, and anti-money laundering legislation (legal basis).

(e) Where is the information stored?
We are committed to ensuring that your information is secure. In order to prevent any unauthorized access, use or disclosure, all information is securely stored with GDPR- compliant services.
(f) Who is the information shared with?
Consistent with any of the purposes mentioned above, we may share your data with:

1. our business partners and third-party agents and contractors, such as e.g., intermediaries which introduced you to us, or professional advisors. Personal data will only be transferred to a person who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation; and
2. to the extent required by law, e.g., we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;

(g) Where do we transfer your personal data?
Data-sharing may include transfers to companies or organizations in countries outside of the

European Union / European Economic Area (EU/EEA) without an adequate standard of data
protection. In these cases, we transfer personal data in accordance with the provisions of
Data Protection Law on the international transfers of personal data, including by using
appropriate safeguards to secure the transfer of your Personal Data and ensure its protection
(such as Standard Contractual Clauses).
(h) What are your rights?
We respect your privacy rights. You can contact us at any time to:

1. Request access to the personal data we have on you; we process a large quantity of
   information, and can thus request, in accordance with GDPR, that before the
   information is provided, you specify the transaction, information or processing
   activities to which your request relates;
2. Rectify your personal data that are incorrect and/or incomplete;
3. Restrict or delete your personal data, in specific cases provided for by art. 17 and 18
   GDPR;
4. Object to the processing of your personal data for reasons related to your particular
   situation. We will consider your objection and comply with it unless we have a
   compelling legitimate reason or for reasons of defending legal rights. In the case it is a
   matter of commercial prospecting, you may object without reason; and
5. Request portability of your personal data, in certain cases (subject in particular to
   technical feasibility) and, where technically possible and with regard only to the data
   you have provided to us, to request receipt of your personal data in a structured and
   commonly machine-readable format.
   To exercise any of these rights, you may contact us by emailing privacy@astanor.com by postal mail:
   Good Harvest Ventures Management S.àr.l.
   46a, avenue J.F. Kennedy
   L-1855 Luxembourg
   
   

If you are not satisfied with our handling of your data or any answer, you have the right to lodge a complaint with the National Data Protection Commission – Luxembourg – cnpd.public.lu.

Links to other websites
Our Website may contain links to other websites. We do not have any control over these
websites. Therefore, we cannot be held responsible for the protection and privacy of any
information which you provide whilst visiting such sites and such sites are not governed by
this Privacy Statement. You should exercise caution and look at the privacy notice applicable
to the website in question.

Cookies
Cookies are small files that are stored on each website user internet browser. We use cookies and similar technologies to ensure our website works properly, personalize your browsing experience, and analyze how website users use our website. This includes cookies which are necessary for the operation of our website. For these reasons, we may share website user usage data with our analytics partners. Each website user can choose whether or not they want to consent to our use of cookies through the Astanor website. More information can be found on our Cookie Policy.

Data Protection Officer
Antoine Cuny is appointed as Data Protection Officer for Astanor.