Last updated: 24 April 2026

Privacy Policy

FundVision S.à r.l. and all its current and future affiliated Entities (together "FundVision Group") respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we process your personal data when you visit our website and tell you about your privacy rights and how you are protected. This website is not intended for children, and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you.

Preamble

Key definitions and terms used throughout this Privacy Policy.

GDPR

EU Regulation n°2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Data Laws

GDPR and any other data protection law applicable to the Grand Duchy of Luxembourg.

Personal data / personal information

Any information about an individual from which that person can be identified. It does not include data where identifying information has been removed (anonymous data).

Legitimate Interest

The interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and weigh any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted by law.

Comply with a legal or regulatory obligation

Processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

External Third Parties

External third parties include:

Service providers, acting as processors, who provide IT and system administration services such as Google Analytics and Matomo
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
Event organisation professionals including caterers, event and communication agencies, photographers, and videographers

Who We Are

This privacy policy is issued on behalf of FundVision S.à r.l. When we mention "FundVision", "Equinodes", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in FundVision responsible for processing your data. FundVision is the controller and is responsible for this website.

Controller & Web Master

FundVision, société à responsabilité limitée — Mailing address: 1b, rue Heienhaff, L-1736 Senningerberg — Establishment year: 2025 — International VAT Number: LU36445803 — Trade Register Number: B294087 — Capital: €12,500

Web Hosting

This website is hosted on Amazon Web Services (AWS), operated by Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109, USA.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO at: info@equinodes.com. You have the right to make a complaint at any time to the Commission Nationale pour la Protection des Données (CNPD), the Luxembourg supervisory authority for data protection issues (cnpd.public.lu). We would appreciate the chance to deal directly with your concerns before you approach the CNPD.

Your Duty to Inform Us of Changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, including changes to your physical or electronic address, company, or job title.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Data We Collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows.

Identity Data

First name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data

Delivery address, email address and telephone numbers.

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data

Your username and password, your interests, preferences, feedback and survey responses.

Usage Data

Information about how you use our website.

Marketing and Communications Data

Your preferences in receiving marketing material from us and your communication preferences. For the purposes of catering during events, we also collect and store data regarding your dietary restrictions, where you provide this information. Please note that this information will only be transmitted in aggregate form, with no identifying data. Your picture may also be taken during an event and shared on social media and on our website. You have the right to refuse that a picture of you, individually (not as part of a group), appears.

Aggregated Data

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data by law as it does not directly or indirectly reveal your identity. However, if we combine aggregated data with your personal data so that it can identify you, we treat the combined data as personal data in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How We Collect Your Data

We use different methods to collect data from and about you.

Direct Interactions

You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Subscribe to our service or publications
Request marketing material to be sent to you
Give us feedback through a survey
Comment on our blog
Automated Technologies or Interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.

Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties and public sources, including:

Visitor statistics providers such as Google Analytics and Matomo
Networking and social website providers such as LinkedIn
Your own company's website, if your contact data is publicly available

How We Use Your Data

We will only use your personal data when permitted by law or with your active consent. Most commonly, we will use your personal data in the following circumstances.

Purposes of Processing

We process your personal data for the following purposes:

To manage our relationship with you: sending newsletters, inviting you to events, asking for surveys or reviews, notifying you about policy changes, and analysing job applications — Legal basis: your active consent, legal obligation, legitimate interests
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance and hosting) — Legal basis: legitimate interests, legal obligation
To deliver relevant website content and measure the effectiveness of our communications — Legal basis: legitimate interests
To use data analytics to improve our website, products, services and marketing — Legal basis: legitimate interests
To make suggestions and recommendations to you about goods or services of interest — Legal basis: legitimate interests
Third-Party Marketing

We will never sell or share your personal data with any company outside the FundVision Group for marketing purposes.

Unsubscribe

You can ask us to stop sending you marketing messages at any time by following the unsubscribe link on any marketing message sent to you, or by contacting us directly at info@equinodes.com. You can ask to be unsubscribed from all marketing messages, or only for a specific purpose (e.g. newsletters, event invitations).

Cookies

For more information about what cookies are and how we use them on the Equinodes website, please refer to our Cookies Policy available at equinodes.com/cookie-policy.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Disclosures of Your Data

We may have to share your personal data with the parties set out below for the purposes described in this policy.

We may share your personal data with:

Within FundVision Group
External Third Parties as set out in the Preamble
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We may also have to share your personal data if subject to a judicial request by the competent authorities.

International Transfers

We share your personal data within the FundVision Group, which may involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Some of our external third parties are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is available by ensuring that at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
When we use certain service providers, we may use specific contracts which give personal data the same protection it enjoys in Luxembourg

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach when we are legally required to do so.

Data Retention

We will only retain your personal data as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data — see Your Legal Rights below. In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

To the fullest extent permitted by Data Laws, upon request you have the right to:

Access your personal data
Correct your personal data if it is inaccurate or incomplete
Object to the processing of your personal data under certain circumstances
Ask for the removal or deletion of your personal data
Ask for data portability under certain circumstances
Withdraw your consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent

These rights can be exercised by sending an email to info@equinodes.com. You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within one month.

Equinodes | A smarter way to structure your investments