01Controller and scope
This policy explains how NAVICELLA INVESTMENT TRUST (“the Trust”, “we”) processes personal data in connection with this website. It applies to this website only; it does not govern the separate contractual arrangements that apply to mandate relationships.
Liechtenstein is a member of the European Economic Area. Processing is therefore carried out under the EU General Data Protection Regulation (GDPR) as incorporated into Liechtenstein law, together with the Liechtenstein Data Protection Act (Datenschutzgesetz, DSG).
02Data we collect
Data you provide
The enquiry form on this website collects a name, an email address, an optional organisation, a subject and your message. When you submit the form, this information is transmitted to Navicella and used solely to read and respond to your enquiry. It is not sold, rented or shared with third parties for marketing, and it is retained only for as long as necessary to handle your enquiry and any resulting correspondence.
Data collected automatically
Like any website, the hosting server may record technical connection data in its logs.
- IP address of the requesting device
- Date and time of the request
- Requested resource and HTTP status code
- Referrer and user agent reported by your browser
This data is necessary to deliver the site and to maintain its security and stability. It is not combined with other data and is not used to build profiles.
03Purposes and legal bases
Where you contact us directly by email or in writing, we process the data you send for the sole purpose of answering you and, where a mandate follows, for the administration of that mandate.
05Third parties and recipients
We do not sell personal data and we do not share it for advertising purposes. Personal data may be accessible to the following categories of recipient, each bound by confidentiality:
- the hosting provider operating the server that delivers this site
- professional advisers (legal, audit, compliance) where strictly necessary
- public authorities, where disclosure is required by law
Web fonts
Typefaces on this site are requested from Google Fonts (fonts.googleapis.com and fonts.gstatic.com). Loading them transmits your IP address and browser information to Google, which may process it outside the EEA under the applicable standard contractual clauses. If you prefer to avoid this, the fonts can be blocked by your browser and the site will fall back to local typefaces without loss of function.
06International transfers
Personal data is processed within Liechtenstein, Switzerland and the EEA. Where a transfer to a third country occurs — as with the web-font request described above — it is made on the basis of an adequacy decision or of standard contractual clauses adopted by the European Commission.
07Retention
Server log data is retained only for as long as required for security and diagnostic purposes and is deleted or aggregated thereafter. Correspondence is retained for the duration of the exchange and, where a mandate arises, for the statutory retention periods applicable to fiduciary records under Liechtenstein law. Data no longer required is deleted.
08Your rights
Subject to the conditions set out in the GDPR, you have the right to:
- access the personal data we hold about you
- obtain rectification of inaccurate data
- obtain erasure of data we no longer have grounds to process
- obtain restriction of processing
- receive your data in a portable format (data portability)
- object to processing based on our legitimate interests
- withdraw consent at any time, without affecting prior processing
Requests may be addressed to the Trust at its registered office in Vaduz. You also have the right to lodge a complaint with the Liechtenstein Data Protection Authority (Datenschutzstelle, Vaduz) or with the supervisory authority of your habitual residence.
09Security
We apply technical and organisational measures appropriate to the risk, including transport encryption where the site is served over HTTPS, restricted access to systems, and the separation of duties that governs the Trust's wider administration. No transmission over the internet can be guaranteed to be entirely secure; please do not send confidential mandate information through unencrypted channels.
10Changes to this policy
This policy may be amended to reflect changes in the site, in our practices or in the law. The version number and date at the head of this page indicate the current edition. Material changes will be signalled on this page.
11Contact
Questions about this policy or about the processing of your data may be directed to the Trust at its registered office: