1. Context and introduction

This Privacy Notice (the “Notice”) has been prepared in accordance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council 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”).

All capitalised words used in the Notice shall have the same meaning as they are defined or referred to in the GDPR, unless specifically indicated to the contrary herein.

Directors Solutions, acting through Philippe Burgener (“Directors Solutions”) is the Data Controller of the Personal Data of any Data Subjects with whom Directors Solutions deals in the daily performance of its duties and delivery of services, as further described herein.

Directors Solutions is committed to hold the Personal Data in confidence in strict compliance with the provisions of the Notice, any internal procedures, the GDPR, as well as any applicable Luxembourg law. However, Directors Solutions does not accept any liability with respect to an unauthorised third party receiving knowledge and/or having access to Personal Data provided to Directors Solutions except in case of gross negligence or willful misconduct of Directors Solutions. Furthermore, Directors Solutions will not incur any liability for the processing of Related Personal Data (as defined hereafter) accepted in good faith by Directors Solutions as having been provided in accordance with Section 3 of this Notice.

 addition, any Personal Data (whether Related Personal Data or not) provided to

This Notice contains the information prescribed by article 12 of the GDPR.

2. Identity and contact details of the Data Controllerand the Supervisory Authority

Data Controller:

Directors Solutions

Philippe Burgener

21, rue de la Chapelle

L-8017 Strassen

Grand Duchy of Luxembourg

Email: gdpr@directors-solutions.lu

Supervisory Authority:

Commission Nationale pour la Protection des Données

Service des plaintes

1, avenue du Rock’n’Roll

L-4361 Esch-sur-Alzette

www.cnpd.lu

3. Categories of Personal Data concerned

Directors Solutions will collect and process the following Personal Data provided by or on behalf of a Data Subject, including Personal Data relating to the Data Subject obtained from other sources:

Name(s), Surname, contact information (telephone numbers, email addresses, postal address, website title, function in the Data Subject’s organisation), IP address, the outcome of technical processes (such as cookies, analytics, third party embeds) and other Personal Data that is necessary for the purposes described below collected or obtained from publicly available sources, social media or registers.

Any person providing Personal Data not provided directly by the relevant Data Subject itself (“Related Personal Data”) to Directors Solutions represents and warrants that such person has full authority from the relevant Data Subject (“Related Data Subject”)to provide the Related Personal Data to Directors Solutions and has informed the Related Data Subject of the processing of the Related Personal Data by Directors Solutions in accordance with this Notice. Data Subject shall encompass the term Related Data Subject and Personal Data shall encompass Related Personal Data hereafter.

4. Purpose of the Processing and legal basisof the Processing

Directors Solutions will use Personal Data for the following purposes with the relevant associated legal basis:

1. Compliance with legal obligations:

Ensuring compliance with anti-money laundering/combatting financing of terrorism legislation, including, but not limited to the amended law of 12 November 2004 on the fight against money laundering and terrorist financing (the “2004 Law”) and/or with any applicable fiscal rules and regulations;

1. Performance of a contract with a Data Subject:
2. a) Fulfilling the obligations of Directors Solutions under any agreement that Directors Solutions may have entered into with a Data Subject;
3. b)Fulfilling Directors Solutions’ obligations under any agreement between a Data Subject and a third party, under which Directors Solutions has to fulfil any duties.

1. Consent of the Data Subject:

Directors Solutions may use Personal Data for any other purpose expressly agreed to by the Data Subject, provided that such consent may be withdrawn at any time by the Data Subject, without however affecting any Processing performed by Directors Solutions prior to such withdrawal.

1. Directors Solutions’ legitimate interest:

• Managing and administering the relationship between Directors Solutions and a Data Subject;
• Maintaining a client relationship management database for communication and promoting services offered by Directors Solutions to Data Subjects;
• Monitoring and recording, correspondence, telephone calls and emails in accordance with Directors Solutions’ IT set-up.

Directors Solutions’ legitimate interest results from Directors Solutions’ activities, consisting in the provision of independent directorship services, legal, regulatory and business consulting, interim management and mandates as “responsible du contrôle (RC)” within the meaning of the 2004 Law.

5. Recipients of Personal Data

Directors Solutions may share Personal Data with the following Recipients:

1. Any service providers of Directors Solutions and any service providers of the Data Subjects or the organisation employing the Data Subjects, including Google, Apple and LinkedIn ;
2. Any lawyers, auditors, consultants or other professionals which Directors Solutions may consult to obtain advice or assistance for the performance of its duties;
3. The CSSF or other supervisory authorities, tax authorities, law enforcement agencies or courts of competent jurisdiction in order to allow Directors Solutions to comply with any legal or regulatory obligations and instructions.