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 in combination with other information that we may hold.
Personal Data that we collect about you is provided to us directly by you. 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 such personal data is your consent. You are able to remove your consent at any time. You can do this through the “PRIVACY” section on our website, where you will have the ability to personalize Cookies settings, or by contacting us at firstname.lastname@example.org, for all consents that do not involve Cookies.
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”).
If you want to exercise one of these rights or lodge a complaint, please contact us at email@example.com.
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 stored in the European Union in electronic form within a secured IT infrastructure.
You will be informed prior to where your Personal Data is processed using automated means, and will have the ability to restrict 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 those processing activities administered by our Cookies manager 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 (e.g. Service providers) to Blue Colibri. Further information can be found on our Cookies management provider’s Data privacy and security document that can be accessed via our Cookie notice.
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 manage 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.
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 - 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 07/04/2021.
10 - 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