Privacy policy
The purpose of this data protection policy is to inform you how Sparinvest S.A. (henceforth “Sparinvest” or “we”) processes your personal data when acting as data controller and your rights in relation to the collection, processing and storage of your personal data. The protection of data is important to Sparinvest, which is why we have implemented a series of measures to ensure that this protection is respected and compliant with the legislation regarding the protection of personal data.
Why we process your personal data
There are several important reasons why Sparinvest processes your personal data:
We process your personal data in order to deliver more accurate and relevant investment consulting including carrying out transactions, the administration of the customer relationship and to provide you with interesting and relevant communication. The processing of your personal data is necessary in order for us to provide you with our services.
Please note that telephone conversations with employees of Sparinvest regarding trading are recorded for documentation purposes. The legal basis for this processing is the fulfilment of a contract with you or your employer, particularly in relation to your relationship with us as a customer, client or business partner art. 6of GDPR1, which stipulates the conditions under which processing of personal data is necessary.
Furthermore, Sparinvest has a legitimate interest in processing personal data (art. 6, 1f GDPR). These interests are invoicing for services rendered, our communication with you if Sparinvest has any questions regarding specific services, storage of data for documentation purposes, handling of a current or potential legal dispute and/ or retention and improvement of customer relations with you.
Personal data is also processed for the purpose of complying with applicable Anti-Money Laundering legislation and any other legal obligations. In this case, the legal basis for the processing of your personal data is compliance with a legal obligation (art. 6, 1c GDPR).
Personal data is also used for marketing purposes including refining and targeting our communication with you based on interests and focus areas as well as being able to contact you with relevant marketing material in the form of newsletters, information about our products, invitations to events and more. We use the information to improve the user experience on our website and in relation to the services that we offer. The legal basis for the processing of personal data will in this case be the legitimate interest of Sparinvest in marketing its products to interested customers (art. 6, 1f GDPR) or based on your freely given, specific and informed consent (art. 6, 1a GDPR), as required, which could apply if we contact you for the purpose of direct marketing by email or other electronic means.
If you apply for a job at Sparinvest we process general personal data provided by you in your application, CV, during a job interview and any other relevant information provided by you for the purpose of evaluating your qualifications with regard to the position applied for. The legal basis for the processing of your personal data is here Sparinvest’s legitimate interests (art. 6, 1f GDPR). If invited to a second interview we ask you to perform a personality test and/or an intelligence test. You will receive the questions asked directly from the test provider of the personality test and/or intelligence test. Sparinvest will receive the test result but not the answers. Sparinvest will ask for your permission and consent before asking you to perform an intelligence test. The legal basis for the processing of your personal data will in this instance be Sparinvest’s legitimate interests or your consent (art. 6, 1f or art. 9, 2a GDPR). If you are offered the position and are to be employed in Luxembourg, a medical exam has to be made by an official practitioner. This is a condition for entering into an employment contract in Luxembourg. Sparinvest receives data regarding your name, address, national security number and the conclusion from the medical exam whether or not a candidate is considered fit or unfit for the intended position. The legal basis for this processing of your personal data is the legal obligation (art. 6, 1c and art. 9, 2g GDPR) according to L-326-1 of the Luxembourg Labour Code. Furthermore, if offered the position Sparinvest will ask you to provide a criminal record certificate. We do this to assess your qualifications for a certain position in Sparinvest, as you as an employee at Sparinvest will get access to information which potentially can be misused for criminal purposes. Sparinvest will ask for your consent to process this information (art. 6, 1a and art. 9, 2a GDPR).
Data collection and categories of personal data
We gather and process the personal data, which you have submitted in relation to investment consulting, execution of transactions and the administration of the client relationship. In general, your personal data is collected when you contact us (by telephone, via a website or email) with a view to you obtaining consulting services from Sparinvest for carrying out transactions on your behalf.
We also collect personal data when you navigate our website. You can read about our cookie policy here.
In some circumstances we also collect data from publicly accessible websites and social media for marketing purposes. The purpose of this would be to gather further information on companies, their employees and/or their board of directors.
Sparinvest processes general personal data such as name, contact information, information about your finances and any services that you receive. If you are a legal person, the same processing of personal data will apply to the contact person(s) and/ or beneficial owner(s).
Sparinvest does not process special categories of personal data (from the category defined as sensitive personal data).
Notwithstanding the above, Sparinvest will handle a copy of your passport and national identification number if required to do so by any applicable law such as anti-money laundering laws as well as other relevant legislation.
If you are a candidate for a job, Sparinvest may as well process special categories of personal data. Please refer to afore mentioned in the previous section.
Who receives your personal data?
Sparinvest may disclose or transfer personal data to certain third-party recipients if necessary or required by law. Such third-party recipients include public authorities, funds managed by Sparinvest, governmental or regulatory agencies, service providers or intra-group companies (collectively referred to as “Recipients”).
Intra-group companies in scope of reception of personal data include Sparinvest S.A. and its Danish branch, ID-Sparinvest, filial af Sparinvest S.A., Sparinvest Holdings SE, Nykredit Bank A/S, Nykredit Realkredit A/S, Nykredit Portefølje Adminstration A/S and Nykredit Group.
The Recipients may process personal data when personal data is processed on behalf of Sparinvest and in accordance with an instruction given by Sparinvest in order to assist Sparinvest in the context of the aforementioned purposes or act as data controller when processing personal data for own purposes). Please note that the Recipients are not entitled to process personal data for their own purposes unless so required through legislation and/or the relevant authorities or if prior consent was given.
Transferring your personal data to a country outside the EU/EEA
In certain cases, personal data may be transferred to recipients and/ or sub- recipients located in countries outside the European Union/ European Economic Area (EU/EEA), for example if Sparinvest uses a data processer located in a third country. Sparinvest ensures that any transfer of data takes place in accordance with the relevant data protection legislation. This means that any party outside of the EU/EEA receiving your personal data must ensure an adequate level of data protection, for example by committing to the EU/US Privacy Shield or accepting the standard contractual arrangements of the EU Commission. Should you have any questions regarding this, you are welcome to email Sparinvest at GDPR@sparinvest.lu
Storage of your personal data
Sparinvest stores your personal data for as long as it is necessary to fulfil the purposes mentioned above.
This means that your personal data will be stored as long as you have an active customer relationship with Sparinvest and for a reasonable period of time following the end of the customer relationship for documentation purposes. The length of this period is normally 5 years.
Sparinvest also stores your personal data related to specific transactions for legal, financial and accounting purposes. Please note that accounting and transaction records are kept for up to 10 years from the end of the fiscal year to which the material relates and in accordance with the regulations for storing accounting records as specified in current accounting legislation. All personal data will be deleted at the end of the applicable retention period.
For non-Sparinvest customers, data is normally kept for up to 3 years from the date of your last inquiry.
Telephone conversations with employees of Sparinvest regarding trading are stored for 5 years.
Personal data is stored for 2 years from the date of the last contact in the case where you have consented to receive direct marketing by electronic means.
The personal data of unsuccessful job applicants is stored for 6 months.
Your rights
When you become a data subject you have the possibility to exercise the following rights under certain conditions as set out by the GDPR:
The right to request access to the personal data that Sparinvest processes about you. Sparinvest must then provide a copy of the personal data that is processed free of charge or disclose the information in electronic form.
The right to rectify incorrect personal data including completing incomplete personal data and the right to have personal information deleted.
The right to restrict Sparinvest’s processing of your personal data.
When data processing is based on consent or a contract and the processing takes place automatically, you have the right to receive your personal data in a structured and accessible format. If it is technically possible, you have the right to have this personal data transferred to a third party without hindrance from Sparinvest.
The right to object to Sparinvest’s processing of your personal data.
It is emphasized that if your personal data is processed for direct marketing purposes you have an unconditional right to object at any time to the processing of personal data for such marketing purposes.
If your personal data is processed because processing is necessary for the purposes of legitimate interests of Sparinvest (art. 6, 1(f) GDPR) you have the right to object to the processing on grounds related to your particular situation.
If processing of your personal data is based on your consent you have the right to withdraw your consent at any time. Please note that this does not affect Sparinvest’s processing of your personal data prior to the withdrawal of your consent.
If you wish to exercise any of the above-mentioned rights, please contact Sparinvest at GDPR@sparinvest.lu.
Submission of complaints
If you wish to submit a complaint regarding Sparinvest’s processing of your personal data, please contact Sparinvest at GDPR@sparinvest.lu
You have also a right to file a complaint to your national supervisory authority or Luxembourg National Commission for Data Protection:
Commission Nationale pour la Protection des Données
1, Avenue du Rock’n Roll
L-4361 Esch-sur-Alzette
Telephone number: (+352) 26 10 60 – 1
Website: www.cnpd.public.lu
Changes to this data protection policy
This privacy policy is updated on a regular basis including when necessary as a result of changes in relevant legislation. This privacy policy contains information regarding the date at which the latest version came into force. If the changes to this privacy policy are substantial or significant, you will be explicitly informed, either through Sparinvest’s website or via email.
Implementation date for the latest update of this data protection policy
23 April 2025
1) Regulation (EU) 2016/679 of The European Parliament and The Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)