TRANSPARENCY. SECURITY. RESPONSIBILITY.

Privacy Policy

Updated: February 2026

For silent partnerships in Novaro Estates Treuunternehmen.

The protection of your personal data is of the utmost importance to Novaro Estates. We process personal data exclusively in accordance with the Liechtenstein Data Protection Act (DSG), the EU General Data Protection Regulation (GDPR), the relevant due diligence regulations (SPG/SPV), and all other applicable supervisory and tax law requirements.

1. Controller

Novaro Estates Treuunternehmen
Auring 52
9490 Vaduz, Liechtenstein
HR FL 2.586.058-2

Email: [email protected]

The Controller processes personal data exclusively in accordance with the provisions of the Liechtenstein Data Protection Act (DSG), the EU General Data Protection Regulation (GDPR), the relevant due diligence regulations (SPG/SPV), and all other applicable supervisory and tax law requirements.

2. Categories of Personal Data

The following data is processed within the scope of concluding and managing the silent partnership:

Master Data:

Name, address, date of birth, nationality, contact details (email, phone), and identification data (ID number, ID image).

Contract Data:

Contribution amount, term, participation quota, participation confirmations, payment information, and withdrawal declarations/consents.

KYC/AML Data:

Identity documents, ultimate beneficial owner (UBO), PEP status, risk profile, screening results, and monitoring results.

Financial & Tax Data:

Bank details, payment flows, and tax-relevant information (AIA/FATCA).

Portal Data (Backoffice):

3. Purpose of Processing

The processing is carried out for the following purposes:

Contractual Fulfillment:

Identification, administration of the silent partnership, and payout of profit shares.

Regulatory Compliance:

Fulfillment of due diligence obligations (AML/KYC), tax reporting obligations (AIA/FATCA), and company law requirements.

Operation of the Customer Portal:

Providing documents and communication.

4. Legal Basis

The legal basis for processing consists of:

Art. 6 (1) (b) GDPR:

Fulfillment of the contract.

Art. 6 (1) (c) GDPR:

Fulfillment of legal obligations (SPG/SPV, PGR, tax laws).

Art. 6 (1) (f) GDPR:

Legitimate interests of the company (security, fraud prevention).

5. Recipients of the Data

Data may be disclosed to the following categories of recipients if necessary:

Internal:

Management and authorized departments.

Processors:

IT service providers, hosting providers, and KYC/AML screening providers.

Authorities:

Financial Intelligence Unit (FIU), Tax Administration, and the Office of Justice.

Banks:

For the processing of payments.

Advisors:

Tax advisors and lawyers.

6. Storage Period

The data will be stored:

For the duration of the participation.

In accordance with the statutory retention periods (regularly 10 years after the end of the contract pursuant to PGR/due diligence law).

7. Rights of the Data Subject

Pursuant to the GDPR, data subjects have the right to:

Access (Art. 15).

Rectification (Art. 16).

Erasure (Art. 17).

Restriction of processing (Art. 18).

Data portability (Art. 20).

Object (Art. 21).

Withdraw consent (Art. 7).

8. Automated Decision-Making / Profiling

No profiling takes place, except for legally required:

Automated AML screening.

PEP checks.

Risk classification according to SPG/SPV.

9. Security Measures

The company protects all personal data through:

Encryption (transport & storage).

Access restrictions based on the "Need-to-Know" principle.

Logging of all portal accesses.

Two-factor authentication in the customer portal.

10. Electronic Communication & Deemed Service

(1) Documents are served via the customer portal or by email.

(2) A document is deemed served as soon as it is accessible in the portal or sent to the stored email address.

(3) The data subject is obliged to check the portal and email regularly.

11. Contact Point & Right of Complaint

For data protection inquiries: Novaro Estates Treuunternehmen, Auring 52, 9490 Vaduz, FL. Complaint office: Liechtenstein Data Protection Office, Städtle 38, 9490 Vaduz, www.datenschutzstelle.li.