Privacy Statement
1 - Who is responsible for your personal data
This Privacy Statement explains how Blue Colibri Capital SARL (“Blue Colibri”, “we”, “us” or “our”) processes your Personal Data when you visit our website in accordance with applicable data privacy laws, including the General Data Protection Regulation 2016/679 (“GDPR”) which is applicable as of 25 May 2018.
When we process your Personal Data, for the purposes outlined in this Privacy Statement, we act as a “Data Controller” as defined by the GDPR.
2 - Personal data
When using the term “Personal Data” in our Privacy Statement, we mean information that relates to you and allows us to identify you, either directly or indirectly, in particular by reference to an identifier such as your name, an identification number or an online identifier.
Personal Data that we collect about you is provided to us directly by you when using our website. It may include data such as your contact details (through the “contact us” form), information about the device you have used to visit our website (e.g. IP addresses, web logs), the webpages you have visited and the time and duration of your visit on our website.
We will use your Personal Data to establish contact with you (e.g. reply to your questions), when you have initiated information requests via the “contact us” form. Using Cookies, we will collect statistical information from you on a non-anonymised basis, but only if you agree to this (refer to section 7).
We will only use your Personal Data for the above mentioned purposes, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for any other purpose, we will notify you and we will explain the legal basis which allows us to do so.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing personal data for the purposes outlined above is your consent. You are able to remove your consent at any time. You can do this as follows :
For the cookies: through the “Cookie” section on our website, where you will have the ability to personalize Cookies settings
For all consents that do not involve Cookies, by contacting us at privacy@bluecolibri.lu
The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.
We may also process personal data based on our legitimate interest to guarantee the basic functioning of our website (e.g. cookies to provide functions across pages).
3 - Your rights in relation to your Personal Data
Under the GDPR you have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:
request access to your Personal Data (commonly known as a “data subject access request”): you have the right to ask us for copies of your personal information;
request rectification of your Personal Data: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
request the erasure of your Personal Data: you have the right to ask us to erase your personal information in certain circumstances;
request the restriction of processing of your Personal Data: you have the right to ask us to restrict the processing of your personal information in certain circumstances;
request to transmit your Personal Data to another data controller where the processing of personal data is carried out by automated means (commonly known as a “right to data portability”).
request to object to the processing of your personal data: you have the right to object at any time to processing of personal data concerning you (e.g., processing of your personal data for direct marketing purpose).
If you want to exercise one of these rights or lodge a complaint, please contact us at privacy@bluecolibri.lu.
You also have the right to lodge a complaint at any time with the National Commission for Data Protection (“CNPD”), the Luxembourg supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.
4 - Security of your Personal Data
We are committed to taking appropriate technical and organisational measures to protect your Personal Data against unauthorised or unlawful processing and against accidental loss, modification, destruction or damage.
Your personal data is not subject to any fully automated processing activity. If this becomes the case, you will be informed beforehand, and you will have the possibility to object to this processing activity.
5 - Retention period
We will only retain your Personal Data for as long as we need it in order to fulfil the purposes for which it was collected and processed. For instance, personal data shared by you when sending us a request for information through the contact form will be kept for no longer than 5 years after the last contact with you.
For those processing activities administered by our Cookies provider the retention period of your Personal Data are outlined in the Data retention section of their Data privacy and security document.
6 - Sharing your Personal Data
Where consent has been provided, your personal data will be shared with parties both internal (e.g. Blue Colibri staff) and external (i.e. cookie provider and third party advisers) to Blue Colibri. Further information can be found on our Cookies provider's Data privacy and security document.
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
In addition, we may disclose Personal Data to our IT service providers which maintain our website and the cookies banner on our website.
7 - Cookies
A cookie is a piece of data that websites send to a user’s web browser in order to understand more about that user’s interests and intentions in using the Website. Cookies help Blue Colibri to know which pages are visited more often, how you interact with the Website, create metrics and statistics and allow us to ensure that our Website responds to the user’s needs.
By clicking the “OK, accept all” button on our Cookies banner you consent to the placing and use of analytical cookies on your devices or equipment. Kindly note that the some cookies are strictly necessary for the website to function and cannot be switched off in our systems. You can customize your setting by clicking the “Personalize” and select certain types of cookies. Please note that you are also free to revoke your consent at any moment by going to the “cookie” section on the right side of our website. This is in line with Section 3.1 of the CNPD guidelines on the cookies and other trackers tools.
8 - Fees
You will not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Statement. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
9 - International transfer of personal data
In certain instances, your personal data may be transferred outside of the European Economic Area. In this case, we will take steps to ensure that appropriate safeguards are in place to protect such data. Adequate safeguards may include a data transfer agreement with the data recipient based on the European Commission Standard Contractual Clauses (SCCs) or other appropriate mechanisms. For further information, please contact us at privacy@bluecolibri.lu.
10 - Updates to our Privacy Statement
We reserve the right to update the Privacy Statement at any time, and we will make an updated copy of the Privacy Statement publicly available.
The latest version of this document is dated 01/02/2024.
11 - Contact information
If you have any concerns or require any further information, please do not hesitate to contact us at or send your request to the following address:
Blue Colibri Capital
Attn. COMPLIANCE COORDINATOR
29, rue Avenue Monterey
L-2163 Luxembourg
privacy@bluecolibri.lu