Privacy Policy

1. Data Controller

Data Protection Officer (if designated): [Name and contact details, or a statement that none is appointed if not legally required]

2. Data We Process

We process personal data you provide to us directly, in particular when you contact our Investment Desk by email. This may include:

• Full name and, where applicable, corporate entity name
• Corporate email address and phone number
• Your stated legal role in a given transaction (e.g. owner or mandated agent)
• Commercial and transactional details you choose to share (e.g. commodity type, estimated transaction value)
• Any documents, attachments, or asset information you submit by email

When you visit this website, our hosting provider's server automatically processes standard technical data (e.g. IP address, browser type, date and time of access, referring page) to ensure the technical operation and security of the site.

3. Purpose and Legal Basis of Processing

• Initiating and conducting due diligence / pre-contractual measures (submissions to our Investment Desk) — Art. 6(1)(b) GDPR.
• Compliance with legal obligations, including anti-money-laundering (AML) and know-your-customer (KYC) requirements where applicable — Art. 6(1)(c) GDPR.
• Technical provision and security of this website (server logs) — Art. 6(1)(f) GDPR, based on our legitimate interest in ensuring a functioning and secure website.

4. Email Submissions

This website does not operate a web-based upload form. Documentation and personal data are submitted exclusively by email to info@spadpinv.com. Please note that standard email transmission over the internet is generally not end-to-end encrypted, and confidentiality in transit cannot be fully guaranteed unless additional encryption measures (e.g. PGP/S-MIME) are used. Please do not include sensitive personal data beyond what is necessary for the initial assessment of your submission.

5. Recipients of Data

Personal data submitted to us is accessible only to authorized personnel of the Investment Desk on a need-to-know basis. We may share data with:

• Legal, financial, or compliance advisors engaged to conduct due diligence on a specific transaction, where such disclosure is necessary and legally permitted
• Competent authorities where disclosure is required by law (e.g. AML reporting obligations)

We do not sell personal data to third parties, and we do not use submitted data for advertising or marketing purposes.

6. International Data Transfers

Should data be transferred to recipients outside the European Economic Area (EEA) in connection with a specific transaction, we will ensure an adequate level of protection through appropriate safeguards (e.g. EU Standard Contractual Clauses) pursuant to Art. 44 et seq. GDPR.

7. Retention Period

We retain personal data only for as long as necessary for the purposes described above, or as required by applicable statutory retention obligations (e.g. commercial and tax record-keeping obligations under German law, typically 6–10 years for relevant business correspondence). Data relating to submissions that do not proceed to a transaction will be deleted or anonymized once no longer required for assessment purposes, unless a longer retention period is legally mandated.

8. Your Rights

Under the GDPR, you have the right to:

• Request access to the personal data we hold about you (Art. 15 GDPR)
• Request rectification of inaccurate data (Art. 16 GDPR)
• Request erasure of your data (Art. 17 GDPR), subject to legal retention obligations
• Request restriction of processing (Art. 18 GDPR)
• Object to processing based on legitimate interest (Art. 21 GDPR)
• Request data portability (Art. 20 GDPR)
• Withdraw consent at any time where processing is based on consent (Art. 7(3) GDPR)

To exercise any of these rights, please contact us at info@spadpinv.com.

9. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority for Berlin is:

10. Website Hosting & Cookies

This website, in its current form, does not use tracking cookies, analytics tools, or third-party advertising scripts. If this changes in the future, this Privacy Policy will be updated accordingly and, where required, a consent mechanism will be implemented.