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Privacy Policy

EFFECTIVE DATE: December 01, 2022

Ilavska Vuillermoz Capital ("us", "we", or "our") operates the www.ilavska-vuillermoz.com / www.ivc.fund website (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.iv-ii.com

Definitions

Service

Service is the iv-ii.com website operated by Ilavska Vuillermoz Capital

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

TYPES OF DATA COLLECTED

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

·       Email address

·       First name and last name

·       Cookies and Usage Data

Usage Data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

·       Session Cookies. We use Session Cookies to operate our Service.

·       Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

·       Security Cookies. We use Security Cookies for security purposes.

Use of Data

Ilavska Vuillermoz Capital uses the collected data for various purposes:

·       To provide and maintain our Service

·       To notify you about changes to our Service

·       To allow you to participate in interactive features of our Service when you choose to do so

·       To provide customer support

·       To gather analysis or valuable information so that we can improve our Service

·       To monitor the usage of our Service

·       To detect, prevent and address technical issues

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Ilavska Vuillermoz Capital legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Ilavska Vuillermoz Capital may process your Personal Data because:

·       We need to perform a contract with you

·       You have given us permission to do so

·       The processing is in our legitimate interests and it's not overridden by your rights

·       To comply with the law

Retention of Data

Ilavska Vuillermoz Capital will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Ilavska Vuillermoz Capital will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Luxembourg and choose to provide information to us, please note that we transfer the data, including Personal Data, to Luxembourg and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Ilavska Vuillermoz Capital will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

LEGAL REQUIREMENTS

Ilavska Vuillermoz Capital may disclose your Personal Data in the good faith belief that such action is necessary to:

·       To comply with a legal obligation

·       To protect and defend the rights or property of Ilavska Vuillermoz Capital

·       To prevent or investigate possible wrongdoing in connection with the Service

·       To protect the personal safety of users of the Service or the public

·       To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Ilavska Vuillermoz Capital aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Ilavska Vuillermoz Capital relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Disclaimer

The Information contained in this Web Site is for general guidance. It should not be construed as professional advice or services. We accept no responsibility for any actions taken as response hereto.

While every effort has been made to ensure that the information in this Site has been obtained with due care, we are not responsible for any errors, omissions or inaccuracies of this information.

Linking Policy

Certain links in this Site connect to third party Web Sites. We have no control over what information third parties track or collect. We make no representations regarding the accuracy or any other aspects of the information contained in other Web Sites.

SFDR Disclosures

Ilavska Vuillermoz Capital sarl makes the following disclosures in accordance with the Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”)

Sustainability risk policies (SFDR Article 3)

Under Article 3 of the SFDR, Ilavska Vuillermoz Capital sarl, hereafter ‘’IVC’’, is required to disclose how sustainability risks (as defined hereafter) are integrated into the investment decision-making process. That being said, ICV does not formally integrate an assessment of sustainability risks in its decision-making process in accordance with Article 3 of the SFDR.

A sustainability risk means an environmental, social, or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investments made by IVC. In the context of the AIFM, sustainability risks are risks that, if they were to crystallize, would cause a material negative impact on the value of the portfolios of the funds managed by the AIFM.

Such risks are principally linked to climate-related events resulting from climate change (i.e. physical risks) or to the society’s response to climate change (i.e. transition risks), which may result in unanticipated losses that could affect an investment. Sustainability risks can also affect companies by introducing social risks (e.g. gender gaps, social inequality) and governance risks (e.g. bribery issues, selling practices).

The impacts following the occurrence of a sustainability risk may be numerous and vary depending on the specific risk, region, and asset class. The Fund is exposed to the information technology sector where many IT companies collect, manage, and monetize sensitive information that is at risk of misuse. Any theft of corporate or individual information could damage an investee company's reputation and earnings prospects, and increase the risk of regulatory scrutiny and restrictions. In addition, as the investee companies in which the Fund invests develop and grow, the companies may begin to have a more significant social and/or environmental impact(s) and issues relating to diversity, employee/management relations, health, and safety at work as well as potential environmental liabilities may become more important and may imply reputational and regulatory risks.

Such risks are notably considered in the context of IVC's overall due diligence process and as a result of applying a prudent and good industry practice approach to selecting, making, and subsequently monitoring investments to the extent that such risks represent potential or actual material risks and/or opportunities to maximizing the long-term risk-adjusted returns of the Funds.

Notably, as part of its due diligence processes and consistent with good industry practice, IVC generally seeks to confirm (among other things): (i) that adequate employment agreements are in place at the investee company level; (ii) whether any employment-related claims have been made or may be made against the investee company; (iii) that the investee company complies with all applicable employment and social laws and regulations; and (iv) that the investee company complies with applicable environmental laws and regulations.

In addition, IVC seeks to use the governance rights available to it to minimize sustainability risks and improve the performance of investee companies. However, the fact that the funds generally hold minority stakes in investee companies means that IVC is not always able to influence the decisions that investee companies make concerning these risks.

No consideration of the adverse impacts of investment decisions on sustainability factors (SFDR Article 4)

For the moment, IVC does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR as there is no sufficient data available in satisfactory quality to allow IVC to adequately assess the potential adverse impact of its investment decision on sustainability factors. In particular, given the scope and nature of activities of the targeted investee companies as well as their size (notably limited size of their workforce as founder-owned and led businesses), IVC does not consider that the sectors in which the funds invest generally have a significant direct environmental impact. The position will be kept under review as the underlying rules are finalized and are embedded in the short to medium term.

Remuneration Policies (SFDR Article 5)

IVC pays its staff in accordance with its remuneration policy which takes into account compliance with all of IVC's internal risk management framework and internal policies. In this regard, IVC’s remuneration policies do not encourage risk-taking which is inconsistent with its internal risk limits or with the risk profile of the funds that IVC manages.