Privacy policy

Last updated 2 September 2026.

1. What this site does not do

We prefer to begin with what is absent, because it determines most of what follows. This website carries no audience measurement or web analytics tool, no advertising or social network tracker, and no profiling. It sets no cookie, which is why you are not asked to consent to any. Nothing you do on these pages is used to build a profile, and nothing is sold or shared for marketing purposes.

2. Data collected when you browse

Consulting the site requires no account and no form. Our hosting provider records technical data in its server logs, as any web server does, for the sole purpose of delivering pages, ensuring the security and stability of the service, and detecting abuse:

• the IP address of the connection, the date and time of access, and the page requested
• the referring page where applicable, and the type of browser and operating system
• the volume of data transferred and the response status

These logs are held by our host for a short period and are not cross-referenced with any other source. Legal basis: our legitimate interest in operating a secure and available website, within the meaning of Article 6(1)(f) of the GDPR.

3. The contact form

If you write to us through the form, we process the name, company, email address and message you provide. These data are used for one purpose only: to read your message and to reply to it.

Legal basis: the steps taken at your request prior to entering into a relationship, and our legitimate interest in answering enquiries addressed to us. Providing these data is optional, but without them we cannot reply.

Retention: messages are kept for as long as needed to handle the exchange and, where a business relationship follows, for the duration of that relationship. Otherwise they are deleted within twelve months.

4. Recipients and processors

Your data are accessible only to the members of Aplan Equity Partners who need them, and to two technical providers acting on our instructions:

• Cloudflare, which hosts and delivers the website
• Resend, which routes the messages sent through the contact form to our mailbox

These providers are bound by contract to process the data solely on our behalf. Beyond them, no data are transmitted to third parties, except where we are legally required to do so.

5. Transfers outside the European Union

Our providers operate global infrastructure, so some data may be processed outside the European Economic Area. Such transfers are governed by the European Commission's standard contractual clauses, together with the additional safeguards those clauses require.

6. Cookies

This site places no cookie, neither its own nor a third party's. No consent banner is therefore displayed, and no preference needs to be managed. Should this ever change, this policy would be updated beforehand and your consent obtained where required.

7. Your rights

Under the GDPR you have the right to access your data, to have them rectified or erased, to obtain restriction of their processing, to their portability, and to object to processing based on our legitimate interest.

These rights are exercised by writing to contact@aplanep.com. We reply within one month. We may ask you for evidence of identity where there is reasonable doubt, and for that sole purpose.

8. Security

We apply technical and organisational measures appropriate to the risk: encrypted connections throughout, access limited to those who need it, and providers selected for their security guarantees. These measures are reviewed as practices and threats evolve.

9. Complaints

If you consider that the processing of your data does not comply with the regulation, you may lodge a complaint with the Luxembourg supervisory authority, the Commission nationale pour la protection des données (CNPD), 15 boulevard du Jazz, L-4370 Belvaux, or with the supervisory authority of your country of residence.

10. Changes to this policy

This policy may be amended to reflect changes to the site or to the applicable rules. The date at the top of the page indicates the version in force.