Last updated: 14 April 2025

1. Data Protection at a Glance

Who is responsible for data collection on this website?
The website epiphany.lu is operated by Circle Securitization S.à r.l. (hereinafter “Epiphany”, “we”, or “us”). We are the responsible legal entity for the collection, processing, and use of your personal data in accordance with applicable data protection regulations in Luxembourg and the EU.

How is your data collected?
Some data is provided by you directly — for example, when you fill in a contact or application form. Other data is automatically collected by our systems when you visit our website (e.g. technical data such as browser, operating system, or access times).

Why do we collect your data?

• To ensure proper functionality and security of our site

• To analyze visitor behavior (anonymous and aggregate)

• To process your application or inquiries
  
  

What are your rights?
You have the right to request information, correction, deletion, or restriction of your personal data. You may also object to processing, request data portability, and, where applicable, withdraw consent at any time. You can reach us via the contact details listed in the imprint.

2. General Information

Data security
We treat your personal data confidentially and in accordance with the applicable legal data protection provisions. Please note that data transmission on the Internet (e.g. email communication) may have security gaps.

Contact details of the data controller
Circle Securitization S.à r.l.
Rue d’Arlon 68
L-8399 Windhof (Koerich)
Luxembourg
R.C.S. Luxembourg: B260605
Email: info@epiphany.lu
Phone: +49 170 5592806

3. Data Collection on Our Website

Cookies
Our website uses cookies to improve functionality and analyze traffic. Most cookies are “session cookies” which are deleted after your visit. You can control cookie settings via your browser.

Server log files
We collect and store technical data automatically through server logs. This includes:

• Browser type and version

• Operating system

• Referrer URL

• IP address (anonymized)

• Date and time of access
  This data is used solely for security, diagnostics, and analytics, and not merged with other data sources.

  
  

  
  

Contact and Application Forms
If you contact us or apply to join Epiphany via a form, your submitted data will be processed solely for the purpose of handling your request. This data is not shared with third parties unless legally required.

4. Analytics
We use third-party analytics tools (e.g. Google Analytics) to understand how users interact with our website. These tools may use cookies and anonymized IP addresses to generate reports and metrics. You can opt out of such tracking via your browser settings or opt-out links provided by the service providers.

5. SSL Encryption
For security, our website uses SSL encryption. You can recognize an encrypted connection by the URL prefix “https://” and the padlock symbol in your browser.

6. Your Rights
Under applicable data protection laws, you have the right to:

• Access your personal data

• Request correction or deletion

• Object to processing

• Withdraw consent (if processing is based on it)

• File a complaint with a supervisory authority
  To exercise any of these rights, contact us at info@epiphany.lu.

7. Updates to This Policy
We reserve the right to amend this privacy policy to reflect changes in legal requirements or our data practices. The current version is always available at https://epiphany.lu.