1. INTRODUCTION
For BASE INVESTMENTS SICAV (hereinafter the “FUND”, “we”, “us” or “our”) privacy is a major concern. In accordance with the provisions of the 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 (the “GDPR”) and any applicable national data protection laws (including but not limited to the Luxembourg law of 1st August 2018 organizing the National Commission for data protection and the general system on data protection, as amended from time to time) (together with the GDPR, the “Data Protection Laws”), the present Cookies and tracking tools policy (hereinafter “Cookies Policy”) has the purpose to inform Users about the processing of namely their IP address (which constitutes personal data) and the use of cookies and other tracking tools by the FUND’s website https://www.basesicav.lu/en/ (the “Website”).
We give Users the possibility to agree to the use of non-essential cookies for the purposes listed in point 4 below. Users may refuse at any time the use of non-essential cookies and other tracking tools, but that this may affect the User’s experience and ability to exploit the full functionality of the Website. This is further explained below.
2. WHAT ARE COOKIES AND HOW DO THEY WORK?
Cookies are small files that contain text information used to identify the User’s device and are saved in the User’s browser and/or the User’s device when he/she visit Internet pages. When the User accepts the use of non-essential cookies, the small files are added to the browser and the cookie isused to identify that specific user and improve their web browsing experience.
In addition to cookies, the FUND uses similar tracking tools such as tracking pixels, unique identifiers or tags (together with the cookies, hereinafter referred to generically as “tracking tools”). Tracking pixels, on the one hand, are small images embedded in web pages used to track User interaction by identifying their IP addresses. Tags, on the other hand, are small pieces of code embedded in the web pages used to track User’s behaviour by identifying their IP addresses.
The FUND uses tracking tools managed directly by the FUND (commonly referred to as “first-party” tracking tools) and tracking tools that enable services provided by third parties (commonly referred to as “third-party” tracking tools). If not otherwise specified within this Cookies Policy, these third parties have access to the respective tracking tools. The duration and expiration of tracking tools may vary depending on what is set by the FUND or each third-party provider. Some of them expire at the end of the Users’ browsing session (session cookies) while others remain on the User’s device for a certain period of time or until deleted manually (persistent cookies). In addition to what is specified in the description of each of the categories of activities reported in point 4 of this Cookies Policy, Users may obtain more detailed and updated information on the duration, as well as any other relevant information – such as the presence of other tracking tools – in the privacy policy of the respective third-party providers published on their websites and which we invite Users to read.
In addition to the terms of this Cookies Policy, any additional terms and conditions that may be set out in any consent statement or other contractual terms of the FUND to which Users may be subject, such as the Privacy Notice available on the FUND’s Website (BASE Investments SICAV – Privacy Notice (basesicav.lu)) as well as any applicable regulations to which the FUND is subject.
3. DATA COLLECTED BY THE FUND
By using the tracking tools, the FUND will collect the following information through its Website:
- Aggregated non-identifying User data that our servers automatically record when the User visits the FUND’s website (e.g., IP address, type of device used, type of browser used, pages of the FUND’s website visited by the Users, date and duration of access and other technical information);
- information from different channels and devices that the User interacts with during its visit to the FUND’s Website, to recognize them, remember their preferences and tailor the content we provide them;
- Information from third parties or delegated third-party service providers (such as, but not limited to, aggregated non-identifying User’s information collected through third-party provider’s app with which we have a relationship or through cookies, pixels, social plugins, tags and other similar technologies).
4. WHAT DO WE USE COOKIES FOR?
The FUND uses tracking tools to improve the overall User experience on its Website and tailor it to the Users’ needs and preferences. Tracking tools are also employed for targeted advertising and to show relevant content based on the User’s past searches. Please also note that in order to improve the User experience, third-party components may also be used, which, under certain circumstances, collect anonymised information on the utilisation by the User of the corresponding website and make it available to the FUND in an anonymised form.
In particular, the data collected by tracking tools are used for the following purposes:
- Website and User relationship administration
In order to improve content and browsing, the FUND uses tracking tools to keep track of Users’ preferences (such as language, time zone, timeouts after periods of inactivity).
- Website operation
The FUND may use cookies for authentication or technical purposes.
- Product implementation and execution
The FUND may use tracking tools to improve the quality of its products and services provided.
- Marketing activity
The FUND may use tracking tools to develop its advertising initiatives, assess their effectiveness on social media and improve them according to Users’ preferences. Tracking tools also allow the re-direction of people to specific social channels with relevant content.
5. THE FUND’S TRACKING TOOLS
The FUND may use “essential” or “functional” cookies or other similar tracking tools to carry out activities that are strictly necessary to ensure the operation or provision of the Website (such as cookies for login or registration, language preferences). The FUND may also use “non-essential” cookies or other similar tracking tools for the purposes defined in point 4 of this Cookies Policy which will be collected with the User’s explicit consent in compliance with the Data Protection Laws.
Please note that non-essential tracking tools set out below are used and stored by the FUND for as long as your consent remains valid (with a maximum one year without being renewed).
Third-party cookies | Type of tracking tool | Purpose | Third-party Privacy Policy | Place of establishment |
Google Analytics Google reCAPTCHA Google Tag Manager | – Navigation optimization – Navigation statistics management – Monitoring and measuring the use of the BASE Investments SICAV website – Personalization of content – Perform trend and statistical analysis to improve the user experience and performance of our Website – Improving the security, performance and user experience of our Website | Google Privacy Policy | Dublin, Ireland | |
Cloudflare | Optimization and distribution of the traffic | – Navigation optimization – Content customization – Improving the security, performance and user experience of our Website | Cloudflare Privacy Policy | San Francisco, CA |
Meta | Facebook Instagram Widgets | – Navigation optimization – Content personalization – Monitor social media content to manage relationships with our customers (both existing and potential, retail and institutional) and promote our business and brand – Improve the security, performance and user experience of our Website | Facebook Privacy PolicyInstagram Privacy Policy | Dublin, Ireland |
LinkedIn Insights | – Navigation optimization – Content personalization – Monitor social media content to manage relationships with our customers (both existing and potential, retail and institutional) and promote our business and brand – Improving the security, performance and user experience of our Website | LinkedIn Privacy Policy | Sunnyvale, California |
6. THE USERS’ RIGHT TO MANAGE PREFERENCES AND THE USERS’ RIGHT TO GIVE OR WITHDRAW CONSENT OF USING COOKIES
Our Website has a pop-up banner to inform the User of the use and storage of cookies on their device when visiting our Website for the first time.
There are several ways to manage preferences for tracking tools and to give or withdraw consent where necessary.
Users can manage their tracking tools preferences directly through their Internet browser’s settings, for example, they can prevent the use or storage of tracking tools. These settings are usually found in the ‘options’ or ‘preferences’ menu of the Internet browser. If you wish to change the settings of your browser with respect to the use of cookies, please find the step-by-step guides on how to disable cookies for different devices, operating systems, and browsers:
- The guide on how to disable cookies on Android.
- The guide on how to disable cookies on iPhone.
- The guide on how to disable cookies on iPad.
- The guide on how to disable cookies on Macbook.
- The guide on how to disable cookies in Chrome.
- The guide on how to disable cookies in Firefox.
- The guide on how to disable cookies in Safari.
- The guide on how to disable cookies in Edge.
Please remember if you turn off cookies in your browser then the settings would apply to all other websites as well, and not just this one.
In addition, whenever the use of tracking tools is dependent on consent, Users may give or revoke such consent by setting their preferences within the Cookies Policy or by updating such preferences via the tracking settings widget, if any. It is also possible to remove previously saved tracking tools by means of special browser or device functions.
Other tracking tools in the local browser memory can be removed by deleting the browsing history.
As regards third-party tracking tools, Users may manage their preferences and revoke their consent by visiting the relevant link of opt-out (if available), using the tools described in the third party’s privacy policy or by contacting the third-party directly.
Users are free to decide whether or not to give consent. However, please note that tracking tools allow the FUND to provide a better experience and improved functionalities to Users (in line with the purposes outlined in this Policy under point 4). Therefore, declining them may prevent the User from taking full advantage of the Website.
7. UPDATES TO THIS COOKIES POLICY
We may make changes to the way in which we use cookies and other tracking tools. If changes require us to update this Cookies Policy, we will notify Users of our Website and notably endeavour to display it in our pop-up banner, should this be required.
8. CONTACTS
Users that would like to receive further information about this Cookies Policy, can contact us at the following address:
BASE INVESTMENTS SICAV 4, rue Robert Stumper L-2557 Luxembourg
e-mail: info@basesicav.lu