We comply with the European General Data Protection Regulation, responsible dealings with your personal data is a matter of course for us.

You have the right to object to processing of your personal data if this is done for the purpose of direct advertising, to preserve legitimate interests or in the public interest.

  1. 1. Who is responsible for data processing and who can I contact?
    • Responsible for the processing of your personal data:
    • MPEP Luxembourg Management S.à r.l.
      26, rue Louvigny
      L-1946 Luxembourg
      Telephone: +352 27 86 17 20

      Managers: Christopher Bär, Liliane Armel, David Schäfer, Horst Güdel
    • In addition, "joint controllers" within the meaning of Art. 4 item 7 GDPR, Art. 26 GDPR are the following entities within the MPE group of companies:

    • MPEP Luxembourg GP S.à r.l.
      26, rue Louvigny
      L-1946 Luxembourg
      Telephone: +352 27 86 17 20

      Members of the Board:: Liliane Armel, Armin Prokscha, Ulrike Scholz

    • Munich Private Equity AG
      Keltenring 5
      82041 Oberhaching
      Telephone: +49 89 66 66 94-500

      Members of the Board: Norman Lemke

    • Munich Private Equity Partners GmbH
      Keltenring 5
      82041 Oberhaching
      Telephone: +49 89 66 66 94-372

      Managing Directors: Christopher Bär, Norman Lemke, David Schäfer, Hans-Christian Moritz

    • RWB PrivateCapital Emissionshaus AG
      Keltenring 5
      82041 Oberhaching
      Telephone: +49 89 66 66 94-0

      Members of the Board: Norman Lemke, Armin Prokscha

    • RWB Partners GmbH
      Keltenring 5
      82041 Oberhaching
      Telephone: +49 89 66 66 94-0

      Managing Directors: Norman Lemke, Nico Auel

    • Walnut GmbH
      Keltenring 12
      82041 Oberhaching
      Telephone: +49 89 66 66 94-600

      Managing Directors: Norman Lemke, Lars Gentz

    • You can contact our data protection coordinators as follows:

    • MPEP Luxembourg Management S.à r.l.
      data privacy
      26, rue Louvigny
      L-1946 Luxembourg
      Telephone: +352 27 86 17 20

      Managers: Christopher Bär, Liliane Armel, David Schäfer, Horst Güdel
    • If offers from other providers ("third-party offers") are accessible from our online offer (internet presence, applications), our data protection notice does not apply to these third-party offers. In such a case, we are not responsible for the processing of your personal data within the framework of such third-party offers within the meaning of Art. 4 item 7 GDPR.

  2. 2. Which sources and data do we use?
    1. 2.1 Direct Transmission
      • If you contact us (e.g. application via mail or e-mail, interest in our products, etc.), you will transmit personal data to us. This data is processed by us in the context of the respective contact.
        In addition we may ask you to provide us with certain personal data required by the context (e.g. contract management) and you will transmit that data accordingly.

    2. 2.2 Transmission by sales partners
      • In case you get into contact with one of our sales partners and are interested in our products, you may request this sales partner to provide us with your personal data.

    3. 2.3 Visit of our internet presence
      • As a matter of principle, you can visit our internet presence without telling us who you are. Then, we merely find out
      • your IP address (person-related data, because it is possible under certain preconditions to learn of the identity of the owner of the internet access which has been used through information from the internet provider in question)
      • the name of the internet site accessed or the file accessed and the time of access and closing,
      • the quantity of data transmitted and
      • whether the access or closing was successful.
      • The data are exclusively used for administration and optimisation of the internet offer.
      • Your IP address is only evaluated by us in the event of attacks on our internet infrastructure. Your IP address is deleted as soon as we can rule out that an attack on our internet infrastructure has been made by it. This is done regularly.

    4. 2.4 Use of cookies
      • Cookies are also used within our online offer. Cookies are small data packages which are placed on your computer's hard disk via the browser. They serve to control the online offer during your visit or in the event of a later visit. We make your visit more comfortable as a result.
      • Some browsers permit cookies in their basic settings. If you do not want them, you can change your browser's settings. Please consult the information from the browser manufacturer to see how you can go about this. If you decide against cookies, it may be possible that parts of our online offer cannot be used.

    5. 2.5 Google Maps
      • Our online offer uses Google Maps to show maps and to produce directions. Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043. If you use the further-reaching functions of Google, for example by clicking on the displayed map, you use a Google service outside our sphere of influence. In this case, the requirements and references stated by Google in this context apply.
      • On the website accessible at, you will find further information on
      • the Google conditions of use ("general terms and conditions"),
      • additional use conditions for Google Map/Google Earth ("additional terms and conditions for Google Map/Google Earth"),
      • the Google data protection declaration, in which you will find information about the data which are recorded for which purpose and what Google does with these data.

    6. 2.6 Register request
      • In case of contract initiation and contract management we generally have to send a request to public or private registers in order to comply with our anti-money laundering dutys.

    7. 3. What do we process your data for and on which legal foundation?
      • We process your personal data in harmony with the European General Data Protection Regulation (GDPR) and the law of 1 august 2018.

      • 3.1 For performance of contractual and pre-contractual duties (Art. 6, subsection 1 b, GDPR)

        • Your personal data are in particular processed in order to enable fulfilment of our contractual duties towards you (e.g. holding contracts, employment contracts) and also, if applicable, to take pre-contractual measures if inquired by you.
          The details about this can be seen from the contracts/agreements in question.

      • 3.2 Within the framework of a balancing of interests (Art. 6, subsection 1 f, GDPR)

        • To the extent necessary, we process your data to attend to our legitimate interests or those of a third party (e.g. advertising, to the extent that you have not objected to the use of your data, measures for business control and further development of services and products, establishment of legal claims and defence in legal disputes).

      • 3.3 On the basis of your consent (Art. 6, subsection 1 a, GDPR)

        • If you have given us consent for the processing of personal data for specific purposes, processing is done on the basis of your consent. Consent granted can be withdrawn at any time. This also applies to consent granted before 25 May 2018. Please remember that the withdrawal only has an effect for the future. Processing done before receipt of the withdrawal is not affected.

      • 3.4 To fulfil a legal obligation (Art. 6, subsection 1 c, GDPR) or in the public interest (Art. 6, subsection 1 e, GDPR)

        • We are subject to various (legal) duties or statutory requirements, for example concerned with examination of identity, prevention of money laundering and control of risks, as well as fiscal control and reporting duties. We therefore process your data for these purposes, amongst others.

    8. 4. Who gets your data?
      • We only forward your data in extremely restricted cases, as described below.

      • 4.1 Service providers: Like many other enterprises, we also outsource activities for data processing to an extremely restricted extent to trustworthy external service providers who fulfil certain tasks and render services for us, e.g. payroll services.

      • 4.2 Business partners: Business partners: We forward your data to trustworthy business partners, so that they can render the services required by you for you, e.g. depositary bank.

      • 4.3 Public and state authorities: To the extent prescribed by law or necessary to protect our rights, we forward your data to agencies legally responsible for us under supervisory law or in any other way.

      • 4.4 Professional consultants and others: We forward your data to an extremely restricted extent to other parties, for example to professional consultants such as auditors.

    9. 5. How long do we store you data?
      • We erase your data when the purpose of the processing has been fulfilled or settled and we are not entitled or obliged to keep them stored for any other reason (e.g. statutory obligations).

    10. 6. Are my data forwarded to third countries?
      • We only forward your data to third countries if this is absolutely necessary or prescribed by law or you have granted us your consent.

    11. 7. Which data protection rights do you have?
      • 7.1 Each data subject has the right to:
        • information according to Art. 15 GDPR,
        • correction according to Art. 16 GDPR,
        • erasure according to Art. 17 GDPR,
        • restriction of the processing according to Art. 18 GDPR,
        • data portability according to Art. 20 GDPR.
        • In addition, a right to complain to a data protection supervisory authority exists (Art. 77, GDPR)

      • 7.2 Claiming all the aforementioned rights is free of charge for you as a matter of principle.
        • In the event of obviously unsubstantiated or - in particular in the event of frequent recurrence - excessive applications, we can however, according to the provisions of Art. 12 subsection 5, GDPR, either
          a) demand a suitable payment, in which the administrative costs for the notification or the performance of the measure applied for are taken into due account, or
          b) reject becoming active on the basis of the application.

      • 7.3 To exercise your rights, please get in touch with our aforementioned data protection coordinator. There, you will also receive further information on data protection.

    12. 8. Can this data protection declaration be changed?
      • From time to time, updating of this data protection declaration may become necessary, for example due to new statutory or official requirements and new offers in our online offer. In general, we recommend that you access this data protection declaration regularly in order to check whether there have been any changes. You can see whether changes have been made, amongst other things, if the date stated at the very bottom of this document has been updated.

    13. 9. Can I print or store this data protection declaration?
      • You can print or store this data protection declaration directly, for example via the print or save functions in your browser.

    14. Date: January 2022

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Information contained in this Website should not be considered an offer to sell or a solicitation of an offer to buy or subscribe for an interest in any investment vehicle or any other securities, to or from any person in any jurisdiction where (by reason of that person’s nationality, tax residence or otherwise) the publication or availability of the Website is prohibited. Any offer to invest based on the content of this Website will not be capable of acceptance. Persons who visit this web site should comply with these restrictions. Any failure to comply with these restrictions may constitute a violation of distribution and securities law in any applicable jurisdiction and persons in respect of whom such prohibitions apply must not access the Website and should disconnect from this Website immediately.

The information herein is directed at “Well-Informed Investors” as defined under article 2 of the Luxembourg law of 13 February 2007 on specialised investment funds, as amended. If you are not a Well-Informed Investor, the material referred to herein is not suitable for you. We have had no prior contact with you and had no opportunity to verify if you are eligible for visiting this Website. By continuing to visit our pages, you agree to the foregoing.

By clicking the button to access the information on this Website, each User herewith confirms that he qualifies as a "Well-Informed Investor" as described above and that the access to the information contained on this Website is permitted in his country of residence.


Information concerning voting rights policy

Goal of voting rights policy

For us as an AIFM the highest priority is to preserve and handle the interests of our investors. In this context, the AIFM considers it as its duty exercising the voting rights attached to the managed assets.

The goal of our voting rights policy is to describe how and according to which principles the AIFM exercises its voting rights associated with the investments of our managed AIFs at the general meetings. Particular attention is paid to ensure that the exercise of voting rights is in line with investors’ interests and the Fund’s investment policy.

Based on the low percentage of voting rights held an AIF has little influence to the target funds and their management. Typically the quota is far from holding blocking minorities as well as exceeding relevant thresholds
(3 %, 5 %) for securities markets. Moreover in general meetings nearly all voting rights are present. The scope of decisions to be taken is anyhow limited. Instead most relevant aspects are dealt within the target funds constitutional documents.

In very unusual cases, an AIF managed by us may hold shares in operating companies, in particular after a “distribution in kind” from a target fund. It is not intended to hold such investments for a longer term.

Principles of voting rights policy

The AIFM supports all sustainable measures of an active corporate governance policy which increase the long-term value of our investments in the interest of our investors.

In general the AIFM exercises voting rights attached to the managed assets in particular if it seems to be necessary to preserve investors’ interests or to be in line with Fund’s investment policy and always taking into account the resulting costs. Depending on the place of meeting the AIFM exercises voting rights itself or through a representative.

In the event that voting rights are exercised, the AIFM acts independently of the interests of third parties and exclusively in the best interests of the AIF and its investors as well as in consideration of the integrity of the market.

As part of its responsibility for managed client funds, the AIFM fulfills this obligation according to the following criteria:

Investor interests

Each interest should basically have the same voting right.

Quality of management

Members of board (executive board, supervisory board, board of directors) should be competent and largely independent and not subject to conflicts of interest.


The remuneration of members of board should be transparent and linked to the long-term success of the company.

Impartiality of auditor

The auditor, which is engaged for the review of the annual financial statements, should be independent and impartial. Remuneration should be in line with the market standard.


Reporting should ensure the maximum transparency regarding business situation and development.

Regarding equity investments

Dividend policy

The dividend policy should be in line with the financial result of the company, the long-term corporate strategy and adequate to industry.

Capital measures and repurchase of shares

Capital measures should increase long-term value of the company. Each investor should have the same right regarding share buybacks.

Complaints Handling

MPEP Luxembourg Management S.à r.l. has implemented procedures for managing customer complaints which complies with the requirements of CSSF Circular 17/671 and CSSF Regulation 16-07 relating to the out-of-court resolution of complaints.

Any complaint concerning the funds or the management company may, together with a brief subscription of your contractual relationship with us, the problem that caused the complaint and supporting documents, be sent to:

MPEP Luxembourg Management S.à r.l.
To the attention of the Compliance Officer
26, route Louvigny
L-1946 Luxembourg
Grand-Duchy of Luxembourg

or via e-mail to

We will treat your complaint as follows:

  • An acknowledgement letter or email will be sent to you within ten business days as of the receipt of the complaint if the complaint cannot be closed before this timeline.
  • An update letter or email will be sent to you every four weeks to inform you of the progress of your complaint.
  • A final letter will be sent to you to inform you on the outcome of our investigation and the actions taken to resolve the complaint.

Where, in the first instance, you obtained no or a dissatisfactory answer, you may refer to our management board, including the information as above and a detailed and chronological statement of the steps already taken, to:

MPEP Luxembourg Management S.à r.l. To the attention of the Board of Directors 26, route Louvigny L-1946 Luxembourg Grand-Duchy of Luxembourg or via e-mail to

Please be aware that there is an out-of-court dispute settlement procedure with the Commission de Surveillance du Secteur Financier (“the CSSF”), the Luxembourg financial services regulator.

Where a customer did not receive a response or satisfactory response within one month of a complaint being submitted to us, you may refer your complaint to the CSSF by the following means:

either by mail addressed to:

Commission de Surveillance du Secteur Financier
283, route d’Arlon
L-1150 Luxembourg

or by e.mail at the following address: