Privacy Policy

1. Data Controller

Oak Ridge Partners S.à r.l. ("we", "us", or "the Company") is the data controller responsible for processing your personal data. We are committed to protecting your privacy in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Luxembourg Law of 1 August 2018 on the organization of the National Commission for Data Protection (CNPD).

2. Personal Data We Collect

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

• Identity Data: Name, title, professional position
• Contact Data: Email address, telephone number, business address
• Professional Data: Employer name, investment interests, professional qualifications
• Technical Data: IP address, browser type, device information, cookies
• Communication Data: Content of inquiries and correspondence

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under Article 6 GDPR:

• Consent (Art. 6(1)(a)): Where you have given explicit consent for specific processing activities
• Contractual Necessity (Art. 6(1)(b)): To perform a contract or take pre-contractual steps at your request
• Legal Obligation (Art. 6(1)(c)): To comply with Luxembourg financial regulations and CSSF requirements
• Legitimate Interest (Art. 6(1)(f)): For business development, website improvement, and fraud prevention

4. Cookies and Tracking Technologies

Our website uses cookies in accordance with CNPD guidelines. We categorize cookies as follows:

• Essential Cookies: Required for the website to function properly. These do not require consent.
• Analytics Cookies: Help us understand how visitors interact with our website. Require your consent.
• Marketing Cookies: Used to deliver relevant content. Require your consent.

You can manage your cookie preferences at any time through our cookie banner or your browser settings.

5. Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

• Right of Access (Art. 15): Obtain confirmation and access to your personal data
• Right to Rectification (Art. 16): Correct inaccurate or incomplete data
• Right to Erasure (Art. 17): Request deletion of your personal data
• Right to Restriction (Art. 18): Restrict processing in certain circumstances
• Right to Data Portability (Art. 20): Receive your data in a structured format
• Right to Object (Art. 21): Object to processing based on legitimate interests
• Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time

To exercise these rights, please contact us at privacy@oakridgepartners.lu.

6. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. For investor-related data, we comply with Luxembourg AML/KYC retention requirements of 5 years after the end of the business relationship. Contact inquiries are retained for 3 years unless you request earlier deletion.

7. Data Transfers

We may transfer personal data to recipients outside the European Economic Area (EEA) only where appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or where the recipient is located in a country with an adequacy decision.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and regular security assessments.

9. Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the National Commission for Data Protection (CNPD):

10. Updates to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.