Notice to Reporting Insiders (PDMRs)

This page is addressed specifically to individuals whose market transactions are published by financial regulators (PDMRs — Persons Discharging Managerial Responsibilities — and persons closely associated with them) and whose information is aggregated on InsiderLens. This notice discharges our Article 14 GDPR obligation.

Who We Are

Nexlens Holding Limited (in incorporation), a Private Limited Company under the laws of Malta, registered at 26, The Forum Office, Triq L-Uqija, Swieqi, SWQ 2335, Malta.

What Data We Process About You

  • Full name
  • Role / position with the issuer
  • Unique identifiers (issuer LEI, SEC CIK, AMF number, etc.)
  • Transactions : date, type (buy / sell / grant / exercise / …), quantity, price, instrument, currency, venue
  • MAR Article 19(7) annotations (10b5-1 plan, savings plan) where applicable

We process no sensitive data (political opinions, health data, etc.) and do not perform automated profiling of reporting insiders.

Source

All information comes from public sources, freely available online, published by the following regulators under their transparency obligations (EU MAR Article 19, US Section 16 of the Securities Exchange Act, and local equivalents) :

  • SEC EDGAR (United States)
  • FCA NSM — National Storage Mechanism (United Kingdom)
  • AMF BDIF — Base des Déclarations des Dirigeants (France)
  • BaFin DealingsInfo (Germany)
  • Finansinspektionen (Sweden)
  • AFM Transacties leidinggevenden (Netherlands)
  • HKEX Disclosure of Interests (Hong Kong)
  • SGX SFA Part VII (Singapore)
  • ASX Appendix 3Y/3X (Australia)

Why We Process These Data

Lawful basis : legitimate interest (Art. 6(1)(f) GDPR), with a balancing test that favours us given :

  • The public nature of the information (legally mandated regulator publication)
  • The market transparency purpose recognised by EU law (MAR Regulation)
  • The benefit to retail investors — our audience — who often lack direct access to aggregated data
  • The fact that the data concern your professional public activity, not your private sphere

Recipients

Data are displayed publicly on https://app.insiderlens.com in issuer and insider pages. They also feed email alerts to our subscribed users.

Our infrastructure processors (hosting, CDN, email) handle the data incidentally without separate logical access. Full list in our privacy policy.

Retention

Data are retained indefinitely in aggregated form for historical analysis and market transparency. Regulators themselves retain these data without time limit (notable exception : BaFin archives at 12 months, in which case we maintain our own snapshot).

Your Rights

You have the following rights :

  • Right of access — obtain a copy of your data
  • Right to rectification — correct an error (name, role, misattributed transaction)
  • Right to object — Art. 21(1) GDPR, on grounds relating to your particular situation. We will weigh your interest against the public interest in transparency
  • Right to erasure — may be limited by our legitimate interest and by the data's original public nature

How to Exercise Your Rights

Write to privacy@insiderlens.com with :

  • Your full name
  • The issuer concerned (name + LEI or CIK if possible)
  • The transaction identifier(s) (SEC accession number, FCA disclosure id, etc.)
  • Your specific request (access / rectification / motivated objection / erasure)

We reply within 30 days. If you feel your rights are not respected, you may lodge a complaint with Office of the Information and Data Protection Commissioner (IDPC) (Malta) or the data protection authority of your country of residence.

Regulator-Originated Error

If you believe one of our entries contains an error that originates from the regulator's original publication, please contact that regulator first to request correction at source. We automatically replicate regulator corrections through our ingestion pipeline (bitemporal architecture : every correction is traced, the old value is closed rather than overwritten).