06.08.2026
Introduction
This Privacy Policy describes how Cipio Partners processes personal data in accordance with General Data Protection Regulation (EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016) (“GDPR”).
Who is the Data Controller?
Cipio Partners acts as the Data Controller for the purposes of this Privacy Policy. The group is composed of two legal entities operating in Germany and Luxembourg:
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Cipio Partners |
Germany |
Cipio Partners GmbH Ottostr. 8 80333 Munich Phone: +49 89 55 06 96 0 |
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Luxembourg |
Cipio Partners S.à r.l. 6D, Route de Trèves 2633 Senningerberg |
Both entities jointly determine the purposes and means of processing personal data in the context of Cipio Partners' operations.
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, you are welcome to contact us at info@cipiopartners.com.
Why do we process your personal information?
Cipio Partners as Data Controller may process personal data for the following purposes:
Management and development of its business relationships
If you have interacted with Cipio Partners we may collect, and store limited personal data about you. This may include:
- Name
- Job title and professional role
- Employer or affiliated organization
- Contact details (e.g., email address, phone number)
We process this information for the following business purposes:
- To maintain a record of professional contacts and communications
- To provide you with business updates or reports
- To invite you to events, presentations, or meetings with Cipio Partners representatives
- To facilitate ongoing or potential business collaboration
Management of the portfolio companies
If you are involved in a current or potential transaction with Cipio Partners or its managed/advised funds, we may collect personal data including:
- Name, job title, qualifications, and contact details
- CV, employment history, and professional background
- Financial information and dealings
- Nationality and identity documents (e.g., passport)
- References and due diligence results
We process this data to:
- Assess and manage potential and actual transactions
- Maintain investment records
- Verify identity and assess suitability
- Comply with legal and regulatory obligations
- Protect our legal rights and interests
- Seeking advice from professional advisors
- Provide business updates
Investors in Cipio Partners’ Funds
We collect and maintain personal data from investors who hold direct or nominee participation in our funds. This may include:
- Name and contact details
- Investment details and account information
- Tax identification
- Other data required according to anti-money laundering and other applicable laws
We use this data to:
- Comply with legal and regulatory obligations
- Communicate with investors (e.g., reports, meeting notices, corporate actions)
- Facilitate capital calls, distributions, and related transactions
- Fulfilling reporting requirements (e.g., AML, CRS, FATCA)
- Complete tax filings
Newsletter and promotional communications
Subject to your explicit consent, we may send newsletters and other promotional communications using various communication channels, including post, email or other electronic communication channels.
For this purpose, we collect and maintain the following personal data:
- Name
- Job title and professional role
- Employer or affiliated organization
- Contact details (e.g., email address, phone number)
You may withdraw your consent at any time by clicking the unsubscribe link or contacting us.
Management of information requests, complaints, and data subject rights
The processing of information requests, complaints, suggestions, and the exercise of data-protection rights, etc. Your data will be processed to fulfill the request by any means necessary, including telephone calls and/or electronic means.
Recruitment
As part of the recruitment process, Cipio Partners collects and processes personal data provided by job applicants. This may include, but is not limited to:
- Curriculum Vitae (CV): including personal details such as name, contact information, education history, and professional qualifications.
- Personal data of referees includes but not limited to names and contact details.
- Reference letters and/or feedback provided by former employers or academic institutions.
- This information is used solely for the purpose of evaluating a candidate’s suitability for employment opportunities within Cipio Partners and is handled in accordance with applicable data protection laws.
Cookies
Cipio Partners uses cookies and similar tracking technologies on our website to enhance your browsing experience, analyze site traffic, and support certain functionalities.
For more information, please refer to our [Cookies Policy].
What is the legal basis for your personal data processing?
Cipio Partners processes personal data only where it has a lawful basis to do so, such as under Article 6 of the GDPR. The applicable legal basis depends on the purpose for which the personal data is processed and the nature of our relationship with you.
Depending on the relevant processing activity, we may rely on one or more of the following legal basis:
- Consent, where you have freely given your consent for a specific purpose, such as receiving marketing communications or the use of non-essential cookies.
- Performance of a contract, where processing is necessary to enter or perform a contract with you or with the organisation you represent.
- Compliance with a legal obligation, where processing is required to comply with applicable legal or regulatory obligations, including anti-money laundering (AML), tax, accounting and other regulatory requirements.
- Legitimate interests, where processing is necessary for our legitimate business interests, provided that these interests are not overridden by your interests or fundamental rights and freedoms.
The table below summarises the legal basis generally applicable to each of the processing activities described in this Privacy Policy. Depending on the specific circumstances, more than one legal basis may apply to a particular processing activity.
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Purpose |
Legal Basis |
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Management and development of its business relationships |
Legitimate interest in maintaining and promoting our business relationships; Performance of a contract, where applicable. |
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Management of the portfolio companies |
Legitimate interest in evaluating and managing investments. Where applicable, it is also necessary for the performance of contractual obligations and compliance with legal requirements. |
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Investors in Cipio Partners’ Funds |
Performance of a contract. Compliance with our legal obligations, including AML/KYC, tax and regulatory obligations; and, where appropriate, legitimate interests. |
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Newsletter and Promotional Communications |
Consent of the Data Subject. |
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Management of Information Requests, Complaints, and Data Subject Rights |
Compliance with legal obligations. Consent of the Data Subject and/or the legitimate interests pursued by the Data Controller. |
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Recruitment |
Processing is based on the legitimate interest pursued by the Data Controller. |
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Cookies |
Consent for non-essential cookies. Strictly necessary cookies are processed based on our legitimate interests in ensuring the proper functioning and security of our website. |
How long will we store your personal information?
In general, your data will be kept only for the length of time strictly necessary for the purpose for which said data were collected.
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Purpose |
Retention of personal information |
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Management and development of its business relationships |
Up to 15 years after the end of the business relationship, in line with commercial and tax law requirements in Germany and Luxembourg. |
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Management of the portfolio companies |
Typically retained for up to 10 years after the end of the investment or contractual relationship, to comply with legal obligations and for defense against legal claims. |
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Investors in Cipio Partners’ Funds |
10 years from the date of dissolution of the respective Cipio Partners fund. |
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Newsletter and Promotional Communications |
Retained until the Data Subject withdraws its consent or unsubscribes. |
| Management of Information Requests, Complaints, and Data Subject Rights | Retained for up to 10 years from the resolution of the request or complaint. |
| Recruitment | Retained for up to 6 months after rejection.
Retained for up to 2 years where legal claims are anticipated or pending. 10 years since the termination of employment and 5 years for trainees. |
| Cookies | For more information, please refer to our [Cookies Policy]. |
Who will receive your personal information?
Cipio Partners may share personal data with the following recipients, strictly for the purposes outlined in this Privacy Policy:
- Service providers acting on our behalf, including IT service providers, cloud service providers, communication and telephony providers, legal counsel, auditors, and any other consultants and other professional advisers, where access to personal data is necessary for the provision of their services to Cipio Partners and subject to appropriate contractual and confidentiality obligations. Marketing and communication partners responsible for managing the website and handling cookies.
- Regulatory authorities or other public bodies were required by applicable law or in response to lawful requests.
- Financial institutions, insurance companies, and similar entities, where the disclosure of personal data is necessary for the execution of Cipio Partners’ business activities, including banking operations, insurance coverage, and financial transactions.
- Other third parties, in the context of corporate transactions, such as mergers, acquisitions, or asset sales, where personal data may be transferred as part of the transaction.
All recipients are contractually bound to protect the confidentiality and security of the personal data and to use it only for the specified purposes.
Where might your personal data be transferred internationally?
Cipio Partners operates in Germany and Luxembourg. As part of our business activities, your personal data may be accessed or processed within these jurisdictions and, where necessary, may also be transferred to service providers, professional advisers, business partners or other recipients located outside the European Economic Area ("EEA").
Where personal data is transferred to a country that has not been recognised by the European Commission as providing an adequate level of data protection, Cipio Partners will ensure that appropriate safeguards are implemented in accordance with Chapter V of the GDPR. These safeguards may include, where applicable:
- reliance on an adequacy decision adopted by the European Commission under Article 45 GDPR; or
- the European Commission's Standard Contractual Clauses ("SCCs") adopted under Article 46 GDPR, together with any supplementary measures where required by applicable law.
What are your rights regarding your personal data?
Under the GDPR, you have several rights in relation to the personal data that Cipio Partners processes about you.
You have the right to request access to your personal data, to request the correction of any inaccurate or incomplete information, and to request the erasure of your data when, among other reasons, it is no longer necessary for the purposes for which it was collected.
In certain circumstances, you may also request a restriction of the processing of your personal data. In such cases, we will retain the data solely for the establishment, exercise, or defense of legal claims.
Additionally, you have the right to object to the processing of your data based on reasons related to your particular situation, as well as the right to data portability, allowing you to receive your data in a structured, commonly used, and machine-readable format.
Where processing is based on your consent, you may withdraw that consent at any time, without affecting the lawfulness of processing carried out prior to your withdrawal.
Cipio Partners does not carry out automated decision-making, including profiling, that produces legal effects or similarly significant effects on individuals.
If you wish to exercise any of these rights, please contact us at info@cipiopartners.com. You can also lodge a complaint about our processing of your personal information with the national supervisory authorities in Luxembourg (https://cnpd.public.lu/de.html) or Germany (https://www.lda.bayern.de).
Updates to this Privacy Policy
Cipio Partners may update this Privacy Policy from time to time to reflect changes in legal requirements, our data processing practices, or the services we provide.
An updated version of this Privacy Policy will be published on our website and will become effective from the date of publication, unless otherwise stated. Where required by applicable law, we will notify you of material changes through appropriate means.
We encourage you to review this Privacy Policy periodically to remain informed about how we collect, use and protect your personal data.