This Privacy Notice applies to personal information collected by Link Management prior to, during and after client relationship. It applies to those who uses our services, including customers, prospective customers, suppliers, and contractors.

 

Who we are:

 

Link Management guides private and corporate clients in the inception and constitution of their art collection. We also provide due diligence and appraisal of artworks, support the everyday management of a collection. Our company acts also as sole adviser to Griffin Art Partners, a securitization platform providing high-end non-recourse loans collateralized entirely by works of fine art. 

 

We are committed to protecting the privacy and security of your Personal Data.
Our address is:

50 rue des Prés

L-7333 STEINSEL

LUXEMBOURG

 

Why we will be using personal data and categories of personal data concerned:

 

We will collect and process various categories of personal data at the beginning and for the duration of your relationship with us. We will limit the collection and processing of information to information necessary to achieve legitimate purposes.

 

Personal data may include:

 

• personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address);

• business contact information (including e-mail address and telephone number);

• date of birth;

• marital status;

• copy of your passport;

• bank account details, tax residence and tax status information;

• documents gathered during the on-boarding process (including background vetting information, insurance policies, completed PEP Forms);

• passport, national identity card, driving licence, power of attorney and relevant contact information of your lawyers, accountants, advisers, agents, attorneys or other representatives (including their name, address, telephone number(s) and e-mail address(s));

• due diligence materials (including reports, photographs, valuations and analysis) relating to your art property, transaction structuring, processing and administration/management; and

• Personal Data which you otherwise voluntarily provide, for example when corresponding in writing (including via email or other electronic means), in meetings or during phone conversations.

 

The majority of the Personal Data provided by you is mandatory in order for us to administer the client relationship and perform our obligations under our contract(s) and/or comply with statutory requirements relating to making or receiving payments, tariffs or taxation.

 

Failure to provide mandatory Personal Data may affect our ability to accomplish the purposes stated in this privacy notice and potentially affect your ongoing client relationship with us.

 

Where required by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between Link Management and with law enforcement and regulatory bodies.

The list set out above is not exhaustive, and there may be other Personal Data which Link Management collects, stores and uses in the context of the client relationship.

 

Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions. It includes:

 

• Information you give us;

• information that we receive from third parties, fraud prevention or government agencies and financial institutions (where permitted by law);

• information that we learn about you through our relationships with you;

• information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.

 

How do we use your personal data?

 

Link Management uses Personal Data for in order to perform its obligations under the contracts between you and the company, to comply with legal obligations or otherwise in pursuit of its legitimate business interests:

 

• to facilitate correspondence with you (or your agents, professional advisers, attorneys and representatives appointed to act on your behalf) via email, phone, mail or other means of communication;

• to conduct Know Your Customer and pre-transaction checks necessary to contemplate a client relationship with you;

• to produce legal documentation for transactions;

• to make payments or confirm the source of sums due under legal transaction between us;

• the day to day management of any transactions between us and the achievement of services we provide to you;

• to comply with legal requirements, (reporting to tax authority, compliance with sanctions laws, regulations, rules and requirements of applicable jurisdiction which relate to foreign trade control, export control, trade embargoes or international boycotts or sanctions);

• to address any complaints, investigate, review and conclude any complaints made;

• to prevent fraud against you, third parties or Link Management if a business transfer or change of ownership occurs or is planned.

 

Again, this list is not exhaustive, and we may update this privacy notice from time to time.

 

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 and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Marketing information

 

Unless you have told us that you do not want to hear from us, we will send you relevant marketing information (including newsletter) by mail. If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by contacting us at data@linkmanagement.lu.

  

When do we share client personal data?

 

The Company will share client Personal Data with other parties only in limited circumstances and where this is necessary for the performance of the contract or to comply with a legal obligation, or otherwise in pursuit of its legitimate business interests.

 

as follows:

 

• where we have your permission;

• where required for your product or service;

• where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world; with banks, financial institutions and payment services companies when making payment to or receiving payment from you;

• with background vetting specialists as part of the client on-boarding process and periodically thereafter to ensure Personal Data held is up to date;

• accountants, lawyers, notaries and other professional advisers when considering, structuring, documenting, concluding, terminating, varying, amending or renewing a particular transaction already in place with you;

• financiers, insurers, participants and sub-participants in order to consider and/or obtain funding, risk mitigation, insurance or other financial or risk support in relation to an agreement between you and us;

• with fraud prevention agencies;

• with third-party guarantors or other companies that provide you with benefits or services (such as insurance cover) associated with your product or service;

• where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;

• send you relevant marketing information however we will not share your information with third parties for marketing purposes without your permission

- in anonymised form as part of statistics or other aggregated data shared with third parties; or where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

 

 

How long will Personal data be retained?

 

By entering into a business relationship, we create records that contain your information. Records can be held on electronic or physical formats.

We manage our records in order to optimize our relationship with our clients and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.

Retention periods for records are determined based on the type of record, the nature of the service we provide and the applicable local legal or regulatory requirements.

We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence, if they are needed.

Under some circumstances we may anonymise your Personal Data so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.

Following the termination of your client relationship with Link Management, we will typically retain data for the periods set out below:

 

General correspondence                                                                       6 years

Contractual documentation                                                                 12 years

Legal Deeds relating to transactions between you and us               12 years

Tax and accountancy records relating to your transactions              12 years

Background check results and related information                             6 years

Financial and credit-related information                                              6 years

Personal data in archived e-mails or other electronic files                 6 years

Forms of identification                                                                           6 years

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Retention periods may be changed from time to time based on business or legal and regulatory requirements.

 

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, altered, disclosed, used or accessed in an unauthorised way. Third parties will only process your Personal Data on our instructions and where they have agreed to treat the data confidentially and to keep it secure.

Your rights rights in relation to the personal data

 

• You have a right to get access to the personal information we hold about you.

• If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.

• You have a right to request that we delete your personal information.

• You have a right to request us to restrict the processing of your personal information.

• Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format.

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LIABILITY AND RELIANCE ON INFORMATION POSTED

The information and material on our site are provided for informational purposes only and do not constitute an offer from Link Management Sàrl to provide any service or product. All services and products offered by Link Management Sàrl are subject to individual contractual terms and conditions.

Information and material should not be construed as investment, legal or tax advice to any party. Professional advice should be obtained with respect to any circumstance.

Information and other materials posted on our site are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed by any visitor to the site or anyone who may be informed of any of its contents.
Our site may contain inaccuracies or typographical errors.  Link Management Sàrl shall not be liable for any errors or inaccuracies in our site or for any actions taken in reliance on information or opinion contained on our site. Link Management Sàrl shall not be liable to you for any loss or damage whatsoever, directly or indirectly, resulting from the use of our site, howsoever arising, and including any loss or damage arising from, but not limited to, omissions, errors, mistakes or inaccuracies for this site and its content, regardless of how it was caused.

Our site and its content are the property of Link Management Sàrl and the distribution or reproduction of all or part of our site may not be made without the prior written consent of Link Management Sàrl. The information and disclosures contained in this document shall be governed by and construed in accordance with Luxembourg law