Privacy Policy

This Privacy Policy explains how 3Pine Capital S.à r.l. (“3Pine”, “we”, “us” or “our”) collects, uses, discloses and protects personal data when you visit this website or interact with our services. We are committed to processing your personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Luxembourg data protection law.

1. Who we are

The data controller is 3Pine Capital S.à r.l., a company incorporated in Luxembourg (Reg. No. B307143), with its registered office at 1, Rue Jean Piret, L-2350 Luxembourg. For any privacy-related questions you can contact us at info@3pine.lu.

2. Information we collect

We may collect and process the following categories of data:

• Information you provide — such as your name, email address, company, and any details you submit through our contact or invitation-request forms.
• Investor onboarding data — where you apply to invest, information required for investor classification, KYC/AML and suitability checks.
• Technical data — IP address, device and browser type, and usage data collected automatically through cookies and similar technologies.

3. How we use your information

We process your personal data for the following purposes:

• To respond to your enquiries and manage invitation requests;
• To assess eligibility, perform investor classification and meet regulatory obligations (including KYC/AML);
• To operate, maintain and improve our website and services;
• To send you communications you have requested or that are relevant to our services, where permitted by law;
• To comply with legal and regulatory requirements.

4. Legal bases for processing

We rely on one or more of the following legal bases: your consent; the performance of a contract with you; compliance with a legal obligation; and our legitimate interests in operating and promoting our business, provided these are not overridden by your rights.

5. Sharing your information

We may share personal data with service providers acting on our behalf (such as hosting, analytics and KYC/AML providers), with professional advisers, and with regulators or authorities where required by law. We do not sell your personal data.

6. International transfers

Where personal data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, such as the European Commission’s Standard Contractual Clauses.

7. Data retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy and to comply with our legal, regulatory and accounting obligations.

8. Your rights

Subject to applicable law, you have the right to access, rectify or erase your personal data, to restrict or object to processing, to data portability, and to withdraw consent at any time. To exercise these rights, contact us at info@3pine.lu. You also have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD).

9. Cookies

We use cookies and similar technologies as described in our Cookie Policy.

10. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss or misuse.

11. Changes to this Policy

We may update this Privacy Policy from time to time. The latest version will always be available on this page with the date it was last updated.

12. Contact

3Pine Capital S.à r.l., 1, Rue Jean Piret, L-2350 Luxembourg. Email: info@3pine.lu.