Privacy Policy

1. Introduction

Caladium S.A. ("Caladium", "we", "our", or "us"), registered in the Grand Duchy of Luxembourg under number B178704, is committed to protecting the privacy and personal data of all individuals who interact with our services, website, and communications. This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable Luxembourg data protection law.

2. Data We Collect

We may collect and process the following categories of personal data:

• Identity data: full name, date of birth, nationality, identification documents
• Contact data: email address, telephone number, postal address
• Financial data: investment history, account details, financial statements (for KYC/AML purposes)
• Professional data: employer, professional qualifications, regulatory status
• Technical data: IP address, browser type, pages visited (via our website)
• Communication data: records of correspondence between you and Caladium

3. Purpose and Legal Basis

We process personal data on the following legal bases:

• Contract performance: to provide investment advisory, portfolio management, and family office services
• Legal obligation: to comply with KYC/AML requirements, Luxembourg financial law, and EU regulatory obligations
• Legitimate interests: to operate our business, improve our services, and communicate with prospective clients
• Consent: where you have expressly consented to specific data processing activities

4. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal obligations (including regulatory retention requirements under Luxembourg law), and to resolve disputes. Financial and investment records may be retained for up to ten years following the end of a client relationship, in accordance with applicable regulatory requirements.

5. Data Sharing

We do not sell, rent, or trade personal data. We may share data with: regulatory authorities (as required by law), legal and compliance advisors bound by professional confidentiality, service providers acting as data processors under contractual obligations, and counterparties in transactions where disclosure is necessary for execution.

6. Your Rights

Under the GDPR, you have the right to: access your personal data, request rectification of inaccurate data, request erasure (where legally permissible), restrict processing, data portability, and to object to processing based on legitimate interests. To exercise any of these rights, please contact us at contact@caladium.lu.

7. Contact

For all data protection enquiries, please contact Caladium S.A. at contact@caladium.lu. You also have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD) in Luxembourg.