HOLON Real Estate S.C.A. SICAV-RAIF (hereinafter the "Fund"), represented by its general partner HOLON General
Partner (the "GP") through its website and all connected using of personal information is subject to the
European regulation of April 27th 2016 about General Data Protection Regulation (GDPR) and applicable
in all European Union since the 25th of May 2018.
Following this rule, the GP cannot keep or use this personal information for any use without the agreement
of the user.
For the purposes of data protection law, we are a data controller in respect of your personal data. The GP
is responsible for ensuring that it uses your personal data in compliance with data protection law.
In this sense, users of this website are informed that their personal data may be used by the GP and manually
processed, only if and when this agreement will be obtained. Users are also informed that by accessing this
website their personal data may be temporarily stored in the memory or registered on their own computer for
purposes of facilitating navigation on the website (cookies).
At the same time, users are entitled, in respect to their personal data and in accordance with the General Data
Protection Regulation (GDPR) or any other applicable data protection laws and regulations, to exercise, to the
extent granted under the relevant data protection regime, their rights of access and rectification to their
personal data, together with the right to erasure, shall they no longer wish for their personal data to be
processed by the GP.
If you would like further information on the collection, use, disclosure, transfer or processing of your
personal data, the exercise of any of the rights described and listed above, or if you have any other questions
about the processing of your personal data, please address questions, comments and requests to the Data
Protection Officer of the GP per mail at firstname.lastname@example.org
or per letter
to the following address.
HOLON General Partner S.à r.l.
Data Protection Officer
47 route d’Esch
Grand Duchy of Luxembourg
PERSONAL DATA COLLECT
The following personal data about its user during the navigation experience may be collected:
Information that you provide directly to us
This includes information about you that you give us by filling in forms or by communicating with us,
whether face-to-face, by phone, e-mail or otherwise. This information may include:
Identity (for example, your name, address and date of birth), contact and financial information
about you as an investor, as well as about directors, partners, members, shareholders, and
personal data in any of the above forms about other named applicants. You must have the authority
to provide the personal data to us and have shared this privacy notice with them beforehand;
information provided to us during the course of your investment with us (including, certain
personal, identity, contact and financial information about directors, partners, members,
shareholders, and beneficial owners); and
Information about the devices you use to access our content and services (for example, your IP
Information we collect or generate about you
This may include, data held on our customer relationship management systems, information provided by the
applicant, records of your investments and of our payments to you, and records of your activity on any
information technology system maintained and provided by us or by any of our affiliates.
Information we obtain from other sources
We may also obtain information about you from third parties including fraud prevention agencies, insolvency
practitioners, debt advisers, tracing agents, commercial databases, public records and other publicly
available information sources, including information about your business or company.
PERSONAL DATA USE
Your personal data may be stored and processed by the GP in the following ways and for the following purposes:
To assess whether you are eligible to make an investment: the investments which we offer are only available
to persons who are eligible for those investments, as a matter of financial services law. If you are
applying for one of our investments, we will need to assess whether you satisfy the eligibility criteria.
This may require us to assess matters including your financial position, employment history, criminal
records, and identity.
To verify your identity and prevent any fraud or money laundering: by, for example checking details provided
on applications for the investments that we offer.
If you give us false or inaccurate information and/or we suspect or identify fraud or money laundering
risks, we will record this and may allow law enforcement agencies to access and use your personal data to
detect, investigate and prevent crime. We may also access and use information recorded by fraud prevention
agencies in other countries. This information may contain your personal data.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse
to provide the services or financing you have requested and/or we may stop providing existing services to
To provide you with the investment products that you contract for with us: this will include maintaining
accounts, updating our records, verifying your identity, transferring or receiving money and servicing your
For audit: we are required to process certain data to meet our audit obligations.
For statistical analysis: for the purposes of aggregating, reporting and other efficiency
For investor communications purposes: we may use your personal data in order to provide you with information
about your investments and about the performance of our products. In some cases, this will include
information which we are required to provide to you pursuant to our investment contract with you.
For informational purposes: we may process certain personal data to send you select communications (these
will generally be emails to you from us) which we believe would be of interest to you. You (or someone
acting on your behalf) can opt out of receiving these types of communications at any time.