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Initium Group privacy policy

Privacy policy

The following is meant for Initium Corporate Services SA (« ICS ») to explain the rules that apply further to the European regulation governing the processing and protection of personal data (EU Regulation 2016/679, hereinafter the « Regulation »).

ICS collects and processes your personal data, and as part of the Regulation, we must define the personal data that we collect and use, for what purposes and to whom your personal data may be transmitted.

In addition, the following will also inform you about your rights regarding the processing of your personal data.

In the future, we may change this privacy policy; those changes will be reflected on our website and as far as possible, we will inform you of such changes being published.

ICS manages your personal data with confidentiality and in compliance with the applicable rules and regulations in force.

ICS may use the personal information you provide either with your consent or in the following cases:

  • the processing of your data is necessary for the performance of services as provided for in an agreement concluded with you;
  • the processing of your data is necessary in the context of the legitimate interest of the controller (ICS) or those of a third party, unless there is a higher reason to protect your  personal data;
  • a legal obligation imposes a specific treatment of your personal data;
  • a vital interest is involved and the processing of your personal data is required to protect an individual’s life;
  • the processing is necessary for ICS to perform a task in the public interest or for official functions to the extent that the task or function has a clear legal basis.

In any case, ICS will not disclose your personal data without your permission, unless such disclosure is required either by the Regulation or by a judicial deed or request.

Whenever the processing of your data is based on your consent, you may withdraw such consent at any time without a change in the service provided unless the data for which your consent was required and withdrawn is needed for such service to be rendered. Also, the withdrawal of your consent will not affect the legality of the processing of your personal data performed prior to the withdrawal of your consent.

ICS may communicate your personal data to third parties such as an administration, a bank, or a notary (without this list being exhaustive), and will then ensure that there are – in compliance with the Regulation – guarantees for ensure the protection of your personal data.

Your personal data will be kept in our files for the period necessary for the purposes for which it was collected, increased by the applicable legal delay if any; the deletion of your data will then take place within a maximum of 6 months after the longest of these two deadlines. This 6-month period is the one we need for the intra-annual review of maturities, and the implementation of the deletion of the data held in our files.

You have the right to request a copy of your personal data held by ICS, and in case you notice any error or inaccuracy, you may have them corrected upon simple request. You also have the right to ask ICS to erase your personal data (« Right to be forgotten »), provided that your personal data does not have to remain in the records of ICS for legal reasons or a provision in the Regulation.

Last but not least, you have the right to object to the processing of your personal data, provided that the processing of your personal data to which you wish to object is not required by law or provided for in the Regulation.

If you find an offense on our part, you have the right to contact the data protection authority, i.e. the National Commission for Data Protection (CNPD), to inform them of your complaint. The link is as follows, i.e.:

However, and before doing so, or in case of questions and / or comments regarding our privacy policy or the processing of your personal data, you may contact our company by e-mail at in order to address the issue.

As to the Regulation, you will be able to read them at the following link:


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This publication has been prepared as a general guide and for information purposes only. It is not a substitution for professional advice. One must not rely on it without receiving independent advice based on the particular facts of his/her own case.  No responsibility can be accepted by the author or the publishers for any loss occasioned by acting or refraining from acting on the basis of this publication.