Lucid Capital

Imprint

Lucid Capital Management GmbH
Neue Schönhauser Straße 2
10178 Berlin, Germany

Registration Court: Amtsgericht Berlin (Charlottenburg)
Registration No.: HRB 252507 B
VAT-ID: USt-ID: DE366053858
Managing Directors: Srecko Dzeko, Johann Nordhus gen. Westarp

Supervisory Authority

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin)
Graurheindorfer Str. 108
53117 Bonn, Germany

Privacy Policy

Date of Publication: 20 Jan 2025

Controller

The controller of your data processed is:

Lucid Capital Management GmbH, Neue Schönhauser Straße 2, 10178 Berlin; Registration Court: Amtsgericht Berlin (Charlottenburg); Registration No.: HRB 252507 B; Managing Directors: Srecko Dzeko, Johann Nordhus gen. Westarp; Email: info@lucidcap.co

Data Processing

We process personal data only to the extent necessary and for the purpose of providing a functional and user-friendly internet presence, including its contents and the services offered there. We also process your personal data for communication and recruiting purposes as well as for purposes set out in this Privacy Policy.

"Processing" of data means any operation or set of operations carried out with or without the aid of automated processes relating to personal data, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or integration, limitation, erasure or destruction.

The legal basis for data protection can be found, in particular, in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC ("General Data Protection Regulation", GDPR), the German Data Protection Act (BDSG) and Telemedia Act (TMG).

Scope and Location of Data Processing

We as well as our external service partners process your data for the purpose of providing the services, including providing hard- and software through such external service partners. You provide data if this is necessary for the aforementioned purposes.

The data categories affected are contact information, user behavior or other information that constitutes personal data provided to us.

We process your personal data for the following purposes:

  • Communication in order to establish, implement and/or process a contractual relationship (also orally) with you (legal basis: Art. 6 para. 1 lit. b. GDPR)
  • Compliance with legal obligations, e.g. commercial, tax and social security detention obligations (legal basis: Art. 6 para. 1 lit. c. GDPR)
  • Enforcement, exercise and defence of legal claims (legal basis: Art. 6 para. 1 lit. f. GDPR), with our legitimate interest that may be, for example, in the assertion of legal claims and defence in legal disputes
  • Your consent to data processing for the purpose named there (legal basis: Art. 6 para. 1 lit. a. GDPR); or
  • As otherwise described in this Privacy Policy or information provided to you

In the event you refrain from providing such data you may face legal disadvantages, for example, no answer to your email send to us.

In general, we process your personal data in the EU/EEA. The non-careers related parts of our website are hosted by the hosting provider Host Europe GmbH, Cologne/Germany (more information: https://www.hosteurope.de/AGB/Datenschutzerklaerung/) in the EU/EEA. If we process personal data outside the EU/EEA, data protection standards applicable in the EU are ensured and we will inform you accordingly in this Privacy Policy or otherwise.

Furthermore, we have implemented technical and organisational measures to ensure that the data protection regulations are observed both by us and by external service providers. The website is operated through a safe SSL-connection. If an SSL-connection is activated third parties are prevented from reading any data that are transferred by you to us.

Your Rights

You have the following rights:

  • the right to access
  • the right to rectification or erasure
  • the right to restriction of processing
  • the right to data portability
  • the right to withdraw your consent

You further have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on point e or f of Art. 6 para. 1 GDPR, including profiling based on those provisions.

To act according to your rights set forth above you may contact us at info@lucidcap.co. You also have the right to lodge a complaint with a supervisory authority about our processing of your personal data (for example for Berlin at the Berliner Beauftragte für Datenschutz und Informationsfreiheit, email: mailbox@datenschutz-berlin.de).

Storing and Deleting Data

The data are deleted if you withdraw your consent and/or such data are no longer necessary for the purpose of processing. We or the engaged third party services delete your data according to the following criteria: Time and completion of requests, settings provided by third party providers etc. Furthermore, we store your data if we are obliged to do so in accordance with legal retention periods (e.g. German Commercial Code (HGB) or German Fiscal Code (AO)).

Visiting the Website

We (or the web space provider) collect data on each visit to our website (so-called server log files), which include: name of the website visited, file, date and time of the visit, data amount transferred, information on a successful call, browser type as well as version, operating system of the user, referrer URL (the page visited before), IP address and the requesting provider as well as the following, if a mobile end device is being used: country code, language, name of device, name of operating system and version.

We use these server log files only for statistical evaluations for the purpose of optimizing our services and in order to guarantee the stability and operational security of the website. When personal data (such as the IP-address) are stored the legal basis for this is Art. 6 para. 1 lit. c. GDPR based on our legal obligation for data safety or Art. 6 para. 1 lit. f. GDPR based on our legitimate interest of quality assurance.

Contacting Us; Emails

If you send us any requests via email or otherwise contact us your details in this request, including the contact data, name, email address and other data provided respectively, are processed by us in order to deal with your inquiry or to be able to contact you at a later time for follow up questions. These data are processed only on the basis of your consent (legal basis Art. 6 para. 1 lit. a. GDPR) or on the basis of an initiating or existing business relationship with us (legal basis Art. 6 para. 1 lit. b. GDPR).

Data Processing for Recruitment

In the event you apply for a job with us or for recruitment purposes, we will process certain data. Such data include name, email, address and telephone number, gender, your career history, qualifications, country of residence, language skills and any other personal information you include in your interactions with us. We may also ask for additional information to assist us with our recruitment process and in the event you are offered a job an example would be date of birth, work documents.

You may also share details of other people with us; for example, if somebody else referred the job to you. In those circumstances, you will need to check with that person that they are happy for you to share their personal information with us, and for us to use it in accordance with this Privacy Policy.

We process your personal data for fulfilling our contractual or pre-contractual obligations (based on Art. 6 para. 1 lit. b. GDPR) or – as applicable – for the purpose of the employment relationship with you (Section 26 BDSG), in particular, we use your data:

  • To get in touch with you, communicate with you, update you and to facilitate your application
  • To offer an online-application system that is linked to our website
  • To respond to your questions or concerns
  • To carry out vetting of staff members (where required); this may involve our collection and use of sensitive personal information including information obtained from criminal background checks about offences or alleged offences and information relating to any proceedings for offences committed or allegedly committed
  • To verify your identity and get agreements signed with you, this may involve our collection and use of sensitive personal information such as your biometric data
  • When necessary and for the purposes of our legitimate interests to maintain adequate records, we may collect and handle information related to medical information, ethnic origin or criminal records
  • To assist in any disputes, claims or investigations relating to your application, or
  • To comply with our legal, regulatory and professional obligations

We may also use your non-sensitive and sensitive data with your explicit consent (based on Art. 6 para. 1 lit. a. GDPR, Art. 9 para. 1 lit. a. GDPR or Section 26 BDSG).

Dispute Resolution

We do not take part in online dispute resolutions at consumer arbitration boards.

SFDR Disclosures

Date of Publication: 09 June 2023

The following information is given in light of the consideration of sustainability-related aspects in accordance with the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27th of November 2019 on sustainability disclosure requirements in the financial services sector ("SFDR").

Art. 6 SFDR – Transparency of the Integration of Sustainability Risks

Lucid Capital Management GmbH ("Lucid Capital") addresses sustainability risks in its investment decision-making process insofar as relevant. Sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

During the due diligence on potential investments, the Lucid Capital conducts a careful analysis of the investment's exposure to environmental, social, and governance risks that could impact its value. When identifying a sustainability risk during the due diligence on potential investments, Lucid Capital decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk. Lucid Capital regularly reviews its policies to ensure that they address new and emerging risks as well as investors' concerns.

Art. 7 SFDR – No Consideration of Principal Adverse Impacts

Lucid Capital does not consider principal adverse impacts of investment decisions on sustainability factors. Sustainability factors mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. Lucid Capital does not use sustainability indicators.

Considering the numerous legal uncertainties currently related to the application of the provisions of the SFDR and the Regulatory Technical Standards (RTS) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, Lucid Capital is not in a position to commit to such standard in light of its fiduciary duty to its Fund and its investors. Lucid Capital will constantly monitor and review the evolution around such regulations and standards and considers changing its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to Lucid Capital.

Transparency of Remuneration Policies

As a registered alternative investment fund manager (AIFM) under the German Investment Code (Kapitalanlagegesetzbuch, "KAGB"), Lucid Capital does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. Therefore, Lucid Capital does not consider sustainability risks when determining remuneration, as defined by Article 5 of the SFDR.