Introduction
At Nemos Regulatory Solutions GmbH ("Nemos"), safeguarding the information entrusted to us is of utmost importance. This Privacy Notice outlines how we handle personal data in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679), as well as other applicable data protection laws.
This Notice explains how Nemos collects, processes, stores, transfers, and protects your personal data, and it outlines your rights in relation to that data.
This Privacy Notice applies to all operations conducted by Nemos Regulatory Solutions GmbH.
Nemos is headquartered in Germany and offers a range of regulatory and compliance services to clients across the financial services industry, including asset managers, fund management companies, and institutional investors. In the course of delivering these services, we process personal data relating to our clients and, where relevant, individuals connected to them — such as employees, legal representatives, consultants, investors, or service providers.
You can learn more about our company at www.nemos-rs.com
Definitions
For clarity, the following terms are used throughout this document:
- Application: Any proprietary web-based software developed and managed by Nemos.
- Authorised User: An individual such as an employee or representative of a client or partner, authorised to access Nemos systems.
- Client: Any individual or organisation that has entered into an agreement with Nemos to receive services.
- Counterparty: A third party engaged in a business relationship with Nemos or a client, such as fund administrators, distributors, or advisory firms and liability umbrella for tied agent.
- Data Controller: The party responsible for determining the purposes and methods of processing personal data.
- Data Processor: The party that processes data on behalf of the Data Controller.
- Personal Data: Any information relating to an identifiable individual, such as names, identification numbers, contact information, or online identifiers.
- Data Processing: Any action taken with respect to personal data, including collection, usage, storage, or deletion.
How Nemos Uses Personal Data
Nemos collects and processes personal data from clients, prospects, and individuals related to these entities for the following reasons:
- To establish and manage client relationships
- To meet legal and regulatory requirements (e.g., anti-money laundering, KYC, tax compliance)
- For communication purposes, including event invitations and updates on our services
- To maintain operational records and comply with internal governance
- To improve and personalise service delivery, monitor quality, and support client needs
As part of the onboarding process, Nemos may request data such as name, date of birth, identification documents, contact information, professional background, and ownership details.
Employees, Candidates & Platform Users
We maintain specific privacy notices for:
- Employees and job applicants: Accessible through our internal systems and provided at the application stage.
Website and Marketing Interactions
Nemos use cookies and similar tracking technologies to understand how users interact with our website. Information collected may include your IP address, browser type, access times, and browsing behaviour. Please refer to our [Cookie Notice] for more details.
Nemos may also collect information when a visitor of the website register for events, webinars, or download content. The visitor is responsible for ensuring that any personal data shared with us on behalf of third parties has been shared with their knowledge and consent.
Legal Basis for Processing
Nemos relies on several legal bases for processing personal data, including:
- Contractual necessity: To deliver services as outlined in our agreements
- Legal obligations: For compliance with AML, tax, regulatory and corporate governance duties
- Legitimate interests: To conduct business analysis, improve services, and communicate relevant updates
- Consent: For activities such as marketing, where required
- Vital interest/public interest: In rare cases, to protect life or in the context of legal authority
Failure to provide requested data may result in our inability to provide certain services.
Sharing of Data
Nemos may share personal data with:
- Service providers involved in delivering or supporting our services (e.g. IT vendors, consultants, legal advisors).
- Counterparties and client-appointed third parties.
- Regulatory authorities, courts, and public bodies as required by law.
- Other entities within the Nemos network, where relevant.
- In the context of corporate transactions such as mergers or acquisitions.
Nemos ensures that all third-party processing is governed by appropriate contractual safeguards.
Cross-Border Data Transfers
While the data infrastructure is primarily located within the EEA (e.g. Germany), certain data may be transferred to jurisdictions outside the EEA, such as the United States. In such cases, Nemos implement legally recognized mechanisms, such as:
- Standard Contractual Clauses (SCCs)
- Transfers under the EU-U.S. Data Privacy Framework
- Binding Corporate Rules (if applicable)
Further information about these safeguards is available upon request.
Data Security & Retention
Nemos implements robust technical and organisational measures to protect personal data, including encryption, access control, and monitoring. Data is only retained for as long as necessary to fulfil its original purpose and comply with applicable laws and internal governance. Typically, personal data will not be retained for longer than ten years post engagement.
Your Rights
As a data subject, you are entitled to exercise the following rights in relation to your personal data:
- Access – to receive a copy of the data Nemos holds
- Rectification – to correct inaccurate or incomplete data
- Erasure – to request deletion of data where legally permissible
- Restriction – to limit the way Nemos processes your data
- Portability – to transfer your data to another controller
- Objection – to object to processing based on legitimate interests or direct marketing
- Automated decision-making – to challenge decisions made solely on automated processing
You may exercise these rights by contacting us using the details below.
Complaints
If you believe your data rights have been infringed, you may contact Nemos directly or lodge a complaint with the German Federal Commissioner for Data Protection and Freedom of Information (BfDI) or your local supervisory authority.
Contact Us
To raise a concern, ask a question, or exercise your rights, please contact:
Nemos Regulatory Solutions GmbH
Email: contact@nemos-rs.com
Changes to This Notice
Nemos may update this Privacy Notice from time to time. Updates will be posted on our website with the relevant “last modified” date.
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