Privacy Notice
This Privacy Notice explains how GENTIS Partners collects, uses and protects personal data. It is provided to satisfy our obligations under the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") and applicable Luxembourg law.
1. Who we are
"GENTIS Partners" refers to the private equity investment group operating under that name. The group is currently in formation. Pending incorporation of our group entities, this notice is provided by the founding partners of GENTIS Partners; it will be updated to identify the formal data controller upon incorporation.
If you have any questions about this notice or wish to exercise your rights, please contact us at enquiries@gentispartners.com.
We have assessed our obligations under Article 37 GDPR and concluded that we are not required to appoint a Data Protection Officer. All data protection enquiries should be directed to the address above.
2. The data we collect
We collect personal data from the following groups of individuals:
- Visitors to this website. Our website is a static site with no analytics, no tracking, no cookies and no third-party scripts. We do not record visits, place cookies or otherwise collect technical information about visitors. The only personal data we receive via this website is your email address (and any information you choose to include) when you click the contact button to send us an email.
- Prospective and existing investors. If you are an investor or prospective investor (or representative thereof), we process: identification and contact data; professional and accreditation data; financial information necessary for subscription, capital calls and distributions; KYC, AML and sanctions screening data; correspondence, meeting notes and (where notified) call recordings.
- Portfolio company contacts and counterparties. For individuals at portfolio companies, prospective investments, intermediaries, advisers and other counterparties, we process: identification and business contact data; professional information; deal-related correspondence and notes.
- Service providers and advisers. For individuals at our service providers, advisers and other third parties, we process the contact and professional data necessary to operate the relationship.
3. How we use your data and our legal basis
We process personal data for the following purposes:
- To respond to enquiries you send us — based on our legitimate interests and, where you have requested information with a view to a possible contractual relationship, on steps taken at your request prior to entering into a contract.
- To manage relationships with prospective and existing investors, including investor communications, fundraising and reporting — based on our legitimate interests, performance of contract, and legal obligations.
- To source, evaluate, monitor and exit investments — based on our legitimate interests and performance of contract.
- To meet anti-money-laundering, counter-terrorist-financing, sanctions, tax and regulatory obligations — based on legal obligations under Luxembourg and EU law.
- To operate our IT systems, ensure information security and meet record-keeping obligations — based on our legitimate interests and legal obligations.
- To engage and manage service providers and advisers — based on our legitimate interests and contractual necessity.
We do not engage in automated decision-making or profiling that produces legal effects on you.
4. Who we share data with
We share personal data only where necessary, with the following categories of recipient:
- Our service providers acting as processors on our instructions — including our customer relationship management platform, email and document storage, AI assistant, virtual data room and website host. Each is bound by a written data processing agreement.
- The authorised alternative investment fund manager (AIFM) and other regulated service providers (including fund administrators, depositaries and banks) engaged in connection with our funds — each acting as a separate data controller (or, where applicable, joint controller) under their own regulatory and contractual obligations.
- Our legal, tax and other professional advisers, acting as separate data controllers under their own professional obligations.
- Public authorities and regulators where we are legally required to disclose data, including the CSSF, Luxembourg tax authorities, and equivalent authorities in other relevant jurisdictions.
We do not sell personal data and we do not share data for marketing purposes with third parties.
5. International transfers
Some of our service providers are located outside the European Economic Area, primarily in the United States and the United Kingdom. Where personal data is transferred outside the EEA, we rely on appropriate safeguards under Chapter V GDPR — typically the European Commission's Standard Contractual Clauses (with the UK Addendum where applicable) — and on European Commission adequacy decisions where they apply (including for the United Kingdom and Switzerland).
6. How long we keep data
We retain personal data only as long as necessary for the purposes set out above and to comply with our legal and regulatory obligations. In particular:
- Investor and KYC records — duration of the relationship plus a minimum of five years thereafter, in line with Luxembourg anti-money-laundering legislation.
- Tax and accounting records — ten years, in line with Luxembourg law.
- General correspondence — typically retained for the duration of the relevant relationship and reviewed periodically.
- Enquiries via our website — retained only for as long as necessary to respond and follow up.
7. Your rights
Subject to the conditions in GDPR, you have the right to:
- access the personal data we hold about you;
- obtain rectification of inaccurate or incomplete data;
- request erasure of your data in certain circumstances;
- request restriction of processing in certain circumstances;
- object to processing carried out on the basis of legitimate interests;
- request data portability where applicable;
- withdraw consent at any time, where processing is based on consent.
To exercise any of these rights, please email us at enquiries@gentispartners.com. We will respond within one month, although that period may be extended by a further two months for complex requests.
You also have the right to lodge a complaint with the Luxembourg supervisory authority, the Commission nationale pour la protection des données (CNPD), or the supervisory authority of your habitual residence.
8. Changes to this notice
We will update this notice when our processing activities change or when GENTIS Partners is incorporated. The "last updated" date at the top of this notice will reflect any changes.
Cookie Notice
This Cookie Notice explains the position of GENTIS Partners on the use of cookies and similar tracking technologies on our website at gentispartners.com.
In short: we do not use any cookies or similar tracking technologies on this website. We do not run analytics, advertising trackers or third-party scripts. There is nothing for you to accept or reject.
What we do not use
This website does not place any cookies on your device. We do not use:
- analytics or measurement tools (no Google Analytics, no Plausible, no Fathom, no equivalents);
- advertising or marketing trackers;
- social media plugins or share buttons that load third-party scripts;
- third-party content delivery networks for scripts or analytics;
- session cookies, preference cookies or any other client-side storage.
Because we do not use any non-essential cookies, no cookie consent banner is required under the ePrivacy Directive or applicable Luxembourg legislation.
What happens when you contact us
If you click the contact button on our website, your own email client opens a draft message addressed to us. We do not capture or process any data via the website itself. The email is sent through your usual email service and reaches us through Microsoft 365. The handling of personal data contained in any email you send us is described in our Privacy Notice.
What happens at the network level
When you visit any website, your browser exchanges technical information (including your IP address) with the website's host so the page can be delivered to you. Our website is hosted on Netlify; this is necessary for the site to function. Netlify acts as our hosting service provider and processes such technical data only to deliver the website to you. We do not retain or analyse this data ourselves.
To display our typography, our website also requests font files from Bunny Fonts (operated by BunnyWay d.o.o., based in Slovenia, EU). Bunny Fonts is a privacy-focused font service that does not log requests, does not set cookies and does not retain IP addresses. Their service is hosted within the European Union.
Future changes
If at any point we introduce cookies or similar technologies (for example, basic analytics), we will update this notice, present a clear consent mechanism on first visit, and only enable non-essential cookies after you have given consent.
If you have any questions about this notice, please contact us at enquiries@gentispartners.com.
Legal Notice
This Legal Notice is provided pursuant to applicable e-commerce and information society services legislation, including the EU E-Commerce Directive 2000/31/EC as transposed in the relevant jurisdiction.
| Publisher | GENTIS Partners — a private equity investment group, currently in formation. The corporate details below will be updated upon incorporation of the relevant group entity. |
|---|---|
| Legal form | To be confirmed upon incorporation |
| Registered office | To be confirmed upon incorporation |
| RCS number | To be confirmed upon incorporation |
| VAT number | Not applicable / to be confirmed |
| Contact | enquiries@gentispartners.com |
| Responsible for content | The founding partners of GENTIS Partners |
| Hosting provider | Netlify, Inc., 44 Montgomery Street, Suite 300, San Francisco, CA 94104, United States — www.netlify.com |
|---|---|
| Domain registrar | GoDaddy.com, LLC, 2155 E. GoDaddy Way, Tempe, AZ 85284, United States — www.godaddy.com |
Intellectual property
The content of this website — including text, graphics, logos, the GENTIS mark and tree motif, page layout and design — is the property of GENTIS Partners (and pending incorporation, of the founding partners) and is protected by Luxembourg and international intellectual property law. Any reproduction, representation, modification, publication, transmission or alteration of all or part of this site, by any means and on any medium, is prohibited without express prior written authorisation.
Liability
The information on this website is provided for general information only. While we take reasonable care to ensure that information is accurate at the time of publication, we make no warranties or representations as to its completeness, accuracy or suitability for any particular purpose. Nothing on this website constitutes an offer or solicitation to invest in any fund associated with GENTIS Partners or to enter into any other transaction. Any future fund offerings will be made only through formal offering documents, by the relevant fund manager, to qualified investors in jurisdictions where such offerings are permitted.
External links
This website may contain links to third-party websites. GENTIS Partners has no control over such websites and accepts no responsibility for their content, availability or privacy practices.
Governing law
This Legal Notice and the use of this website are governed by Luxembourg law. The courts of Luxembourg City have exclusive jurisdiction over any dispute arising in connection with this website, without prejudice to mandatory consumer protection rules.