Privacy Policy

Last updated on 18 Nov 2025

This Privacy Policy is designed to help you understand how we collect, use, disclose and safeguard your personal data when you use this website and when you interact with DCY BTC Yield Fund SCSp (the “Fund”) and its related services

1. Who we are and scope of this Policy

This Privacy Policy applies to the processing of personal data carried out in the context of:

  • The operation of this website; and

  • The provision of services and activities related to the DCY BTC Yield Fund SCSp, an alternative investment fund (AIF) established in Luxembourg and managed by OWL Inclusive S.A., a duly authorised alternative investment fund manager (AIFM). 

For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the data controller will typically be:

  • DCY BTC Yield Fund SCSp, and, where applicable, 

  • OWL Inclusive S.A. in its capacity as AIFM of the Fund. 

In this Policy, “we”, “us” or “our” refer to the Fund and, where relevant, its AIFM.

Contact details for privacy matters:

  • Email: support.btcyield@dcy.fund

  • Address: 54, rue Charles Martel, L-2134 Luxembourg, Grand Duchy of Luxembourg

2. Categories of personal data we collect

Depending on your relationship with us (website visitor, prospective investor, investor, representative of a legal entity, counterparty, service provider), we may collect the following categories of personal data:

  1. Identification and contact data

    • Name, title, nationality, date and place of birth

    • Address, email address, telephone number

    • Copies of ID documents, KYC forms and signatures

  2. Professional and financial data

    • Employment details, position, professional contact information

    • Bank account details, subscription and redemption information

    • Information on your investment profile (investor category, well-informed / professional status, eligibility, risk tolerance where applicable)

  3. Regulatory and compliance data

    • Information required for AML/CTF checks, sanctions screening and other regulatory obligations 

    • Information obtained from public sources or third-party databases (e.g. sanctions lists, adverse media)

  4. Technical and website usage data

    • IP address, device identifiers, browser type, operating system, time and duration of visits

    • Pages viewed, clickstream data, preferences and choices made on the website

    • Data collected via cookies and similar technologies (for more details, please refer to our Cookie Policy)   

  5. Communication and interaction data

    • Content of emails, messages, forms and any other communication with us

    • Records of meetings, calls or written exchanges when relevant.

We generally obtain this data directly from you (or from your advisers), and, where necessary, from public sources or specialised third-party providers (e.g. KYC/AML service providers, banks, distributors).

3. Purposes of processing and legal bases

We process your personal data for the following purposes and on the corresponding legal bases:

  1. Management of your relationship with the Fund and its AIFM

    • Processing subscription and redemption requests, maintaining the register of investors, communicating with you and your advisers, handling queries.

    • Legal bases:

      • Performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR);

      • Compliance with legal obligations (Art. 6(1)(c) GDPR);

      • Legitimate interests (efficient / secure management of the Fund) (Art. 6(1)(f) GDPR).

  2. Compliance with legal and regulatory obligations

    • AML/CTF checks, identification and verification of investors, sanctions screening, reporting to competent authorities (including the CSSF), tax reporting (e.g. FATCA/CRS, where applicable), maintenance of statutory records. 

    • Legal bases:

      • Compliance with legal obligations under Luxembourg and EU law (Art. 6(1)(c) GDPR);

      • Where applicable, performance of a contract (Art. 6(1)(b) GDPR).

  3. Website operation and improvement

    • Operating and securing the website, troubleshooting, generating statistics and analytics to improve our online presence and services.

    • Legal bases:

      • Legitimate interests (proper functioning, security and improvement of the website) (Art. 6(1)(f) GDPR);

      • Consent for non-essential cookies / analytics tools (Art. 6(1)(a) GDPR).

  4. Marketing and investor relations

    • Sending you information about the Fund, newsletters, updates and event invitations that may be relevant to you as a professional or well-informed investor.

    • Legal bases:

      • Legitimate interests (informing existing/prospective professional investors about our products) (Art. 6(1)(f) GDPR);

      • Consent where required by applicable law (Art. 6(1)(a) GDPR).

    • You may opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us.   

  5. Risk management, fraud prevention and dispute handling

    • Monitoring, preventing and investigating fraud, unlawful or abusive activities; managing and defending legal claims.

    • Legal bases:

      • Legitimate interests (protecting our business, investors and assets) (Art. 6(1)(f) GDPR);

      • Compliance with legal obligations (Art. 6(1)(c) GDPR).

Where we rely on consent, you may withdraw your consent at any time, without affecting the lawfulness of processing carried out before such withdrawal.

4. Recipients of your personal data

We may share your personal data, on a need-to-know basis, with the following categories of recipients:

  • Service providers involved in the administration, management and operation of the Fund and the website (e.g. AIFM, administrator, depositary/custodian, paying agent, auditors, IT and cloud providers, KYC/AML service providers, legal and tax advisers). 

  • Regulatory and supervisory authorities, tax authorities and other public bodies where required by law (including the CSSF and other competent regulators). 

  • Banks, brokers, trading venues and counterparties involved in executing the Fund’s investment strategies. 

  • Professional advisers and external consultants (lawyers, auditors, consultants) where necessary for the protection of our rights and interests. 

We do not sell your personal data to third parties.

5. International data transfers

Some of the recipients mentioned above may be located in countries outside the European Economic Area (EEA) which may not provide the same level of data protection as within the EEA.

In such cases, we ensure that appropriate safeguards are implemented in accordance with the GDPR, such as:

  • An adequacy decision by the European Commission; or 

  • Standard Contractual Clauses or other appropriate contractual safeguards. 

You may contact us at support.btcyield@dcy.fund

for further information on the safeguards applicable to specific transfers.

6. Data retention

We retain your personal data only for as long as necessary to achieve the purposes described in this Policy and to comply with applicable legal and regulatory obligations, in particular:

  • For investors and their representatives: for the duration of the investment and for a period thereafter as required by Luxembourg commercial, financial and AML laws (often several years after the end of the relationship).

  • For website visitors and prospects: for the period necessary to respond to your requests, manage our relationship with you and, where applicable, for a limited period for marketing activities, unless you object or withdraw your consent.

  • For cookies: in accordance with the retention periods specified in our Cookie Policy or in the cookie settings panel. 

When data is no longer needed, it is securely deleted or anonymised.

7. Security measures

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, including:

  • Access controls and authentication mechanisms;

  • Encryption and secure communication channels where appropriate;

  • Segregation of duties and restricted access on a need-to-know basis;

  • Regular reviews and updates of our security measures and procedures.

While we strive to protect your personal data, no system can be completely secure and we cannot guarantee absolute security.

8. Your rights under GDPR

Subject to the conditions and limitations set out in the GDPR and applicable law, you have the following rights regarding your personal data:

  • Right of access – to obtain confirmation as to whether we process your personal data and to receive a copy of such data. 

  • Right to rectification – to have inaccurate or incomplete data corrected. 

  • Right to erasure (“right to be forgotten”) – to request the deletion of your data in certain circumstances. 

  • Right to restriction of processing – to request that we limit the processing of your data in certain situations. 

  • Right to data portability – to receive your data in a structured, commonly used and machine-readable format and to transmit it to another controller where technically feasible. 

  • Right to object –

    • to processing based on our legitimate interests, on grounds relating to your particular situation;

    • at any time, to the processing of your data for direct marketing purposes.

  • Right to withdraw consent – where processing is based on your consent, you may withdraw it at any time. 

To exercise your rights, please contact us at:

  • Email: support.btcyield@dcy.fund

  • Address: 54, rue Charles Martel, L-2134 Luxembourg 

Please note that we may need to verify your identity before responding to your request, and that legal or regulatory obligations may prevent us from fully complying with certain requests (in particular regarding AML/CTF and statutory record-keeping).

You also have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (CNPD), the Luxembourg data protection authority, or with your local supervisory authority.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect changes in our processing activities, in applicable law or in guidance from supervisory authorities. Any updates will be published on this website with an updated “last updated” date.

We encourage you to review this Privacy Policy regularly to stay informed about how we process your personal data.