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Privacy & Cookie Policies

Last updated: 3 November 2025

Controller: Stanley Group
Address: 29, rue Alphonse München, L-2172 Luxembourg

Email: office@stanleygroup.lu
Data Protection Officer (DPO): Not applicable

1. Introduction

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Stanley Group (“we”, “us”, “our”) is committed to protecting the privacy and confidentiality of personal data entrusted to us in the course of our professional activities.

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This Privacy & Cookie Policy explains how we collect, use, disclose, store, and protect personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Luxembourg Law of 1 August 2018, and the EU ePrivacy Directive (2002/58/EC).

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By using our website www.stanleygroup.lu or interacting with us, you acknowledge that you have read and understood this Policy.
 


2. Scope & Applicability

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This Policy applies to all personal data processed by Stanley Group in its capacity as data controller, including data collected:

  • Through our website and online forms,

  • During client onboarding and service delivery,

  • Via communication channels such as email, phone, or meetings.

It covers clients, suppliers, business partners, website visitors, and any individual whose personal data we process in the context of our operations.


3. What is Personal Data

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Personal data refers to any information that can directly or indirectly identify an individual. Examples include:

  • Name, surname, date of birth, nationality;

  • Contact details such as address, telephone number, and email;

  • Company and position information;

  • Financial or identification data (where relevant);

  • IP address, browser data, or device identifiers.​

 

4. Purposes of Processing & Legal Bases​

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If processing is based on legitimate interests, we ensure that these interests are balanced against your fundamental rights and freedoms. You have the right to object to such processing at any time.

Purpose
Legal Basis under GDPR
To send newsletters or marketing communications
Consent
To operate and improve our website and user experience
Legitimate interests
To comply with regulatory, accounting, and AML obligations
Legal obligation
To communicate with clients, partners, or suppliers
Legitimate interests
To establish, manage, and perform client and service relationships (corporate, investment fund, maritime, and private wealth services)
Performance of a contract; legitimate interests

If processing is based on legitimate interests, we ensure that these interests are balanced against your fundamental rights and freedoms. You have the right to object to such processing at any time.

5. Data Collected

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Depending on your interaction with us, we may collect:

  • Identity data: name, title, nationality, identification numbers.

  • Contact data: address, email, phone number.

  • Professional data: company name, role, sector.

  • Financial and transactional data: billing, payment details (where relevant).

  • Website usage data: IP address, browser type, cookies, pages visited.

  • Regulatory data: KYC/AML documentation, only where legally required.


6. Data Sharing & Disclosure

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We may share your personal data with:

  • Trusted third-party service providers (e.g. IT hosting, analytics, professional advisors);

  • Other companies within the Stanley Group for administrative or compliance purposes;

  • Public authorities, regulators, auditors, or courts when legally required;

  • Business partners involved in a transaction with your consent.

All processors are bound by confidentiality and data processing agreements compliant with GDPR Article 28.


7. International Data Transfers

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If personal data is transferred outside the European Economic Area (EEA), we ensure adequate safeguards such as:

  • EU Standard Contractual Clauses (SCCs), or

  • Transfers to countries with an EU adequacy decision.

Information on these safeguards can be requested at office@stanleygroup.lu.

 

8. Data Retention

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We retain personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by law.

Typical retention periods include:

  • Client files: 10 years after the end of the relationship (per AML and accounting laws).

  • Website analytics data: up to 26 months.

  • Marketing and contact data: until consent is withdrawn.

When data is no longer needed, it is securely deleted or anonymised.

 

9. Security Measures
 

We maintain appropriate technical and organisational measures to protect data against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Measures include:

  • Access control and authentication,

  • Encrypted data storage and secure communications,

  • Regular system audits and staff confidentiality obligations.

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10. Your Data Protection Rights
 

Under Articles 12–22 of the GDPR, you have the following rights:

  • Access: request a copy of your data.

  • Rectification: correct inaccurate data.

  • Erasure: request deletion of your data.

  • Restriction: limit how we use your data.

  • Portability: receive your data in a structured, machine-readable format.

  • Objection: object to processing based on legitimate interests.

  • Withdrawal of consent: withdraw consent at any time for processing based on consent.

To exercise these rights, contact us at office@stanleygroup.lu. We will respond within one month of receipt, as required by law.

 
 

11. Cookies and Tracking Technologies

11.1 What Are Cookies

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Cookies are small text files placed on your device when visiting our website. They help the site function properly, remember preferences, and improve performance.

Cookies may be:

  • Session cookies: deleted when you close your browser.

  • Persistent cookies: stored on your device for a defined period.

  • First-party cookies: set by our website.

  • Third-party cookies: set by external services such as Google Analytics.

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11.2 Types of Cookies We Use

 
 
 
Type
Purpose
Examples
Legal Basis
Retention
Analytics
Measure usage, performance, and user behaviour.
Session ID, load balancing cookies.
Legitimate interest.
Session duration.
Functional
Remember language and consent preferences.
cookie_consent, preferred_language.
Consent.
Up to 12 months.
Strictly Necessary
Enable essential site operations and security.
Google Analytics (_ga, _gid).
Consent.
Up to 26 months.

11.3 Google Analytics

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We use Google Analytics 4 (GA4) to collect anonymised statistics on website usage. This helps us understand traffic patterns and improve user experience.

  • IP anonymisation is enabled by default.

  • Data is stored on Google servers in the EU and the US under appropriate safeguards.

  • You can opt out at any time using:

See Google’s Privacy Policy for more details.

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11.4 Managing Cookies

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You can manage your preferences by:

  • Adjusting cookie choices in the cookie banner shown on first visit, or

  • Changing your browser settings to block or delete cookies.

Guides for major browsers:

If you disable cookies, some parts of the website may not function properly.

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12. Consent and Withdrawal

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You may withdraw your cookie consent at any time by revisiting the “Cookie Settings” link in the website footer.
Withdrawal of consent does not affect prior lawful processing.

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13. Complaints & Supervisory Authority

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If you believe your personal data has been misused, you may contact us or lodge a complaint with:

Commission Nationale pour la Protection des Données (CNPD)
1, Avenue du Rock’n’Roll
L-4361 Esch-sur-Alzette, Luxembourg
Website: https://cnpd.public.lu

We encourage you to contact us first at office@stanleygroup.lu so we can address your concern directly.

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14. Updates to This Policy

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We may update this Policy periodically to reflect legal or operational changes. The revised version will be posted here with the new “Last updated” date.

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15. Contact Us

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For questions about this Policy or how we process personal data, please contact:

Stanley Group
29, rue Alphonse München
L-2172 Luxembourg
Email: office@stanleygroup.lu

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