This memorandum is intended to inform you about the processing of your personal application data. It explains why and how we collect information about you, how we protect it and how long we keep it. It also informs you of your rights.
Please read the following carefully. By submitting your application by post, email or via the online form available on the Adepa website, you acknowledge that you have read and understood the contents of this memorandum.

1 Who is the controller

We, ADEPA Asset Management SA (“ADEPA”), having our registered office at 6A, rue Gabriel Lippmann L-5365 MUNSBACH and registered with the Trade and Companies Register of Luxembourg under number B114721, process the personal data provided to or collected by us.
We act as the controller insofar as we take the decisions within the Group on the purposes and means of the processing of personal data.

2 What personal data we collect

The personal data referred to in this memorandum relates to job applicants.
In general, we will collect, receive, store and process the following information:

  • Identification data, such as name, contact details.
  • Electronic identification data, such as IP addresses, cookies, traffic data.
  • Qualifications and occupation, such as employer, function, title, place of work, work history.
  • Handwritten notes taken by us during the job interview.

Please note that to determine if your profile matches the one we are looking for, you have to send us your curriculum vitae and cover letter.

3 Are sensitive data collected

In general, we will not collect, process or store data considered as sensitive as follows:

  • Racial or ethnic origin;
  • Political opinions;
  • Religious or philosophical beliefs;
  • Trade union membership;
  • Data concerning health or sex life and sexual orientation; and
  • Biometric data.

Please note that if you decide to voluntarily disclose unsolicited sensitive data from us, you consent to the processing of such data by us for recruitment proposes.

4 What are purposes of the personal data processing

Personal data may only be processed for recruitment proposes, namely:

  • For registering the job application
  • For assessing the job applicant’s profile
  • For contacting the job applicant
  • For drafting an employment contract

Thus, we have a legitimate interest in being able to assess the job applications submitted to them.
If the application is not successful, we have a legitimate interest in keeping the data of certain candidates for a specified period referred to in point 6 in order to be able to contact in the future candidates whose profile corresponds to that sought for new job offers.

5 What are the recipients of your personal data

We may disclose personal data only internally to the persons in charge of recruitment, namely:

  • Human Resources Department.
  • Department managers concerned.
  • Members of the Executive Committee.

6 How long we may keep Personal Data

All personal data must be stored by us only for the time necessary for the achievement of the purposes referred to under point 4.
The personal data of successful job applicant are kept in their personal file as a member of our staff for 5 years after the end of their employment contract.
The personal data of rejected job applicant are deleted, with the exception of certain profiles retained by us for future opportunities. For the latter, the data are kept for a maximum period of 2 years, unless the job applicant objects.

7 What are your rights

In accordance with the applicable data protection regulation, you have the following rights:

  • Right of access to your personal data and to information concerning the processing of your personal data by us;
  • Right of rectification of your inaccurate personal data;
  • Right of erasure (‘right to be forgotten’);
  • Right to restrict processing for legitimate reasons;
  • Right of data portability in order to transmit your personal data to another controller;
  • Right to object to processing of your personal data for legitimate reasons.

For any request for information concerning the processing of personal data by us or if you wish to exercise your rights, you can contact the Chief Compliance officer of ADEPA by post at the following address : 6A, rue Gabriel Lippmann, L-5365 Munsbach or by Fax: (+352) 26898051.

8 What is the competent data protection authority

After contacting us, if you believe that your data protection rights have been infringed by ADEPA, you have the right to complain to the competent data protection authority in Luxembourg, “Commission Nationale pour la Protection des Données” (CNPD) at

9 How we update or change this memorandum

We may change or update parts of this memorandum in order to maintain our compliance with applicable law and regulations, or following an update of our internal practices. When we change this memorandum, we will publish the updated version on our website. Please check this memorandum regularly.