Last modified: January 2020
This website is owned by the Microfinance Enhancement Fund S.A. SICAV SIF, a public limited liability company (société anonyme) qualifying as a specialised investment fund (fonds d’investissement spécialisé) organised as an investment company with variable capital (société d’investissement à capital variable), having its registered office at 5, rue Jean Monnet L-2180 Luxembourg, registered with the Luxembourg trade and companies register (registre de commerce et des sociétés) under number B 144.746 (the “Fund” or “MEF”), and is jointly controlled by the Fund and Innpact S.à r.l., a private limited liability company (société à responsabilité limitée) incorporated under the laws of the Grand Duchy of Luxembourg, having its registered address at 5, rue Jean Bertels, L-1230 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg trade and companies register under number B 134935 (“Innpact S.à r.l.”), (together referred to as “we”, “our”, “us”).
By accessing this Website, you agree to use the Website only for lawful purposes and to be bound by the terms and conditions for use of this Website as set out hereunder, which may be amended from time to time by us without notice. The terms and conditions hereunder are subject to the laws of the Grand Duchy of Luxembourg and the exclusive jurisdiction of the Tribunal d’Arrondissement of Luxembourg city.
The information on this Website are provided by us for informational purposes only and on an “as is” and “as available” basis, without any express or implied warranties as to the accuracy or completeness of the information provided and which may be changed by us without notice. The information contained on this Website should not be considered as an offer or solicitation, to deal in any of the investments or funds mentioned herein. Nothing contained in the information on this Website constitutes legal, tax, investment or other advice, nor to be relied upon in making any decision.
You are encouraged to confirm the information contained herein, and you should not construe any information herein as a warranty or guarantee of the quality or availability of services or financial products. Any reliance on information provided on this Website is at your own risk and in no event will we or our service providers be liable for any loss or damage of any kind arising out of or in connection with your access, use, or browsing of this Website.
Any links to other websites or to materials provided by other parties are provided by us for your convenience only and do not imply endorsement of such websites or materials by MEF or Innpact. These sites and materials are not owned by or under the control of MEF or Innpact, and we disclaim all liability with regard to your access to and use of such linked websites or materials from other parties.
The contents of this Website are protected by copyright and may not be downloaded, extracted, reproduced, distributed, transmitted, or published, in whole or in part, for public or commercial purposes without our prior written consent, or in case of third-party materials, the owner of that content. You may not alter or remove any logo, trademark, copyright or other notice from copies of content on this Website.
All pictures used in this Website are copyrighted © KFW Entwicklungsbank.
You may review, download, save, and/or print out a hard copy of individual pages and/or sections of the Website for your personal, non-commercial, non-political use.
You agree not to license, distribute, create derivative works from, transfer, sell or re-sell any content obtained from this Website, nor to modify, deface content on this Website, or reproduce content on this Website separate and out of context from the original accompanying materials. You are not permitted to use the materials on this Website except as expressly set forth herein.
We understand the importance of keeping your personal data safe. This privacy notice (“Notice“) describes how we treat the information that the Website collects when you access and use the Website or when you provide personal data to the Fund during the course of the Fund’s activities, how it is stored, processed, secured and what are your rights in relation to these data.
In case of any questions about this Not or your data rights, please contact us by using the contact form, or alternatively:
Microfinance Enhancement Fund S.A. SICAV-SIF
C/o Innpact S.à r.l.
5 rue Jean Bertels
L 1230 Luxembourg
Grand Duchy of Luxembourg
If you do not wish to accept these cookies onto your computer, you can disable cookies via the settings on your browser.
The main categories of personal data processed which can be used to identify natural persons are (inter alia):
- With respect to persons to whom we are required or have a legitimate interest to perform Know-Your-Client or other due diligence checks:
- name, address, e-mail address, phone number, any other contact details,
- CVs, date and place of birth,
- nationality, gender, copies of identity documents,
- nationality, gender, copies of identity documents,
- results of the checks obtained from Worldcheck.
- With respect to persons to whom we are contractually required or otherwise have a legitimate interest to provide information to:
- name, address, e-mail address, phone number, any other preferred contact details;
- With respect to website users only:
- IP addresses.
Any personal data provided to us is processed based on the legal grounds enumerated in Art. 6, Par. 1 of the General Data Protection Rules (the “GDPR”).
Most of our data processing arises from regulatory or contractual requirements, without which we would not be able to operate or be in compliance with applicable laws.
If you are a website user, your data is processed for statistics purposes, to communicate with you and to answer your requests.
For other persons of which we collect data, your data is processed in order to communicate with you, to manage the Fund and carry out our activities (from an administrative and operational perspective), to perform Know-Your-Client or other due diligence check and for accounting purposes. We do not use your data for marketing purpose without your consent.
Certain data, such as business cards and photographs we may have of you from events or IP address (for website users), is processed based on consent or to pursue legitimate interest, such as internal communication, business administration. For the processing of data that are based on your consent, you have the right to withdraw your consent and request that we stop processing and to delete such data at any time.
MEF does not use data profiling or automated decision-making as per Art. 22 and recital 71.
Any and all personal data will not be retained for longer than necessary in order to fulfil our obligations arising from contract or applicable laws.
We retain such data for the duration required by applicable law or contractual obligations, taking into account any required retention period to meet any legal procedural requirements in case of any need to provide information with integrity to competent authorities.
In order to fulfil our obligations arising from contract or applicable laws, certain personal data may be transmitted to other service providers such as the Structuring Agent, the Investment Advisors, the Placement Agent, the Custodian, the Administrative Agent, the data room service provider, the Fund’s website service provider, the Hedging Advisor and hedging counterparties, the Fund’s insurer, the General Secretary, the introducer, the Auditor, tax agent(s), local service of process agent(s), Legal Advisers, investees, or regulatory authorities.
In particular, please note that any queries addressed to the Fund at its registered office, via the contact form on this Website or by e-mail to firstname.lastname@example.org, may be processed on behalf of the Fund by Innpact, in coordination with Credit Suisse Fund Services (Luxembourg) S.A. acting as the Fund’s administrative agent, and other service providers of the Fund if needed. In relation to any complaints addressed to the Fund via the contact form on this Website, please note that the information provided may primarily be processed on behalf of the Fund by Innpact, in coordination with the competent Fund officer, as well as the other service providers of the Fund if necessary and to the extent permitted by the complaints policy of the Fund.
To the extent practicable, we avoid transferring your data to non-EU countries or to countries without EU equivalent data protection. To the extent required for the working relationships between service providers and between us and our investees, some data may be transferred outside of the EU, such as to affiliates of service providers, providers of IT cloud solutions and to investees. In such cases, prior due diligence is performed to ensure that service providers only transfer data to their affiliates which are compliant with GDPR, that the IT cloud solutions chosen have implemented GDPR compliant security measures, and that the data is transferred in a secure way to investees.
Our data systems are maintained and backed-up by an external IT service provider which are located within the EU, in jurisdictions deemed to have an EU-equivalent level of protection, or are otherwise bound contractually to comply with GDPR requirements.
In the case of a data security incident affecting your personal data, we shall notify such breach as maybe required to the Luxembourg data protection authority within 72 hours after coming aware of such data security incident, and or the data subjects concerned, unless it is unlikely to result in a risk to the rights of data subjects. Each service provider of the Fund, acting as data processor, shall also in turn notify to the Fund without undue delay in the event of such a data security incident.
Please note that the Fund has a zero-tolerance policy towards any form of retaliation towards complainants, and you have the right to remain anonymous when submitting claims pursuant to the Fund’s complaints policy. If you choose to remain anonymous, please understand that we will not be able to provide you with any follow-up reporting regarding the status of investigations or handling and resolution of the matter. Any and all claims received on an anonymous basis will nonetheless be treated seriously and handled in accordance the general steps outlined in our complaints policy.
Please find below the rights you have as data subjects.
- Right to access and rectification
You have the right to see what personal data we have of you in our files, obtain a copy, request update or rectification of inaccurate data.
- Right of erasure
Any of your personal data we have in our files will be deleted upon request, unless we have an overriding obligation to maintain the data such as arising from contract or applicable laws.
- Right to restriction of processing
We will limit the ways and purposes your personal data is processed upon request, unless there are overriding obligations arising out of contract or applicable laws.
- Right to data portability
You have the right to request that your personal data is transferred from to another recipient of your choosing, in a structured, commonly used and machine-readable format.
- Right to object
You have the right to object to the processing of your data by the Fund and to request us to stop processing your data. In such case we will stop processing your data unless there are overriding obligations such as those arising from contract or applicable laws.
Please note that we do not send any newsletters and do not pass on your contact details to any third parties for their own marketing purposes without your explicit consent.
- Right to complain
You have the right at all times to lodge a complaint regarding the processing of your data, whether to MEF by using the contact form on this Website or directly to a national data protection authority of a European Union Member State, such as the Luxembourg data protection authority.