Luxembourg:
GDPR - Transfers Of Personal Data In The UCI World After Schrems II
02 April 2021
ELVINGER HOSS PRUSSEN, société anonyme
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Undertakings for Collective Investments
("UCIs") process personal data about
investors who are either natural persons or legal persons
represented by natural persons. Most of the time, processing
operations by UCIs based in Luxembourg include transfers of
personal data from Luxembourg to countries outside of the EEA.
These transfers are governed by the GDPR and impacted by the
so-called "Schrems II" ruling of 16 July
2020 from the Court of Justice of the European Union in case
C-311/18. Although the ruling particularly deals with transfers to
the US, it's effects are not limited to transfers to the
US.
Key takeaways about the impact of Schrems II for UCIs
are available here.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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