Privacy Policy

Introduction

alfilacltv B.V. ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website alfilacltv.live, use our services, or otherwise interact with us.

This policy applies to all users of our services and website visitors. By using our services or visiting our website, you agree to the collection and use of information in accordance with this policy.

Data Controller

alfilacltv B.V. is the data controller responsible for your personal data. Our contact details are:

Data Collection

The data we collect includes personal information that you voluntarily provide to us when you express interest in obtaining information about us or our services, participate in activities on our website, or contact us.

Personal Information We Collect:

• Contact information (name, email address, phone number, postal address)
• Financial information relevant to our services (investment objectives, risk tolerance, financial situation)
• Identification information (for compliance and verification purposes)
• Communication records (emails, phone calls, meeting notes)
• Website usage data (IP address, browser type, pages visited, time spent)
• Cookies and similar tracking technologies

We collect this information directly from you, through our website, during consultations, and through automated technologies when you interact with our digital services.

How We Use Your Information

We explain how we use your information to provide and improve our asset management services, comply with legal obligations, and maintain our business operations. The use of your data is based on legitimate interests, contractual necessity, and legal compliance.

We use your information for:

• Providing asset management and financial advisory services
• Assessing your financial needs and investment objectives
• Managing your investment portfolio and accounts
• Communicating with you about our services and your investments
• Complying with legal and regulatory requirements
• Preventing fraud and ensuring security
• Improving our website and services
• Marketing our services (with your consent where required)

Legal Basis for Processing (GDPR)

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal bases:

• Contractual necessity: To provide our asset management services
• Legitimate interests: To improve our services and prevent fraud
• Legal obligation: To comply with financial regulations and reporting requirements
• Consent: For marketing communications and cookies (where required)

Information Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties except as described in this policy. We may share your information with:

• Service providers who assist us in operating our business
• Professional advisors (lawyers, accountants, auditors)
• Regulatory authorities when required by law
• Financial institutions for investment transactions
• Third parties in connection with business transfers (with appropriate safeguards)

Data Retention

We retain your personal information for as long as necessary to provide our services and comply with legal obligations. Specific retention periods include:

• Client records: 7 years after termination of services (regulatory requirement)
• Financial transaction records: 7 years (regulatory requirement)
• Marketing communications: Until you unsubscribe or withdraw consent
• Website analytics: 26 months (Google Analytics default)
• Cookies: As specified in our Cookie Policy

Your Rights Under GDPR

As a data subject under GDPR, you have the following rights regarding your personal data:

• Right of access: Request copies of your personal data
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your data (subject to legal requirements)
• Right to restrict processing: Request limitation of data processing
• Right to data portability: Request transfer of your data
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent for consent-based processing

To exercise these rights, please contact us at privacy@alfilacltv.live. We will respond to your request within one month.

International Data Transfers

We primarily process data within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses, or certification schemes approved by the European Commission.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication measures
• Regular security assessments and updates
• Staff training on data protection
• Secure disposal of data when no longer needed

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyse website usage. For detailed information about our use of cookies, please refer to our Cookie Policy.

You can control cookie settings through your browser preferences or our cookie consent banner displayed when you first visit our website.

Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information, please contact us, and we will take steps to remove such information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.

Contact Information

If you have any questions about this Privacy Policy, wish to exercise your rights, or need to contact us regarding data protection matters, please contact us using the following information:

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe we have not handled your personal data in accordance with applicable law.