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CELLAR by Armagnac Consulting

Data Privacy Notice

Version 2026-05-29

This notice explains how personal data is processed when you use CELLAR, the operational due-diligence platform operated by Armagnac Consulting. Please read it before you continue. It applies to you as a user and to the personal data you and your delegates enter into the platform.

Who is responsible

Your firm is the data controller for the personal data processed through CELLAR. Armagnac Consulting acts as data processor on its behalf, under a written agreement. Where Armagnac Consulting determines the means and purposes itself, for example platform security and audit logging, it acts as a controller for those limited purposes.

What data we process

  • Identification and contact data: names, professional email addresses, job titles.
  • Account and usage data: sign-in events, IP address, and browser information, used for security and audit.
  • Due-diligence content: the questionnaire answers, ratings, comments and documents you and your delegates submit, which may contain personal data of third parties.

Why we process it (lawful basis)

  • Performance of the contract between your firm and Armagnac Consulting.
  • Legitimate interests: securing the platform, maintaining an audit trail, and improving the service.
  • Legal and regulatory obligations, including CSSF Circulars 18/698 and 22/806 record-keeping requirements.

Where data is stored

Data is hosted in the European Union. CELLAR relies on a small number of sub-processors: Netlify (hosting and storage, Frankfurt), Google (document storage), and Resend (transactional email). Each is bound by a data-processing agreement.

How long we keep it

Personal data is retained for the duration of the engagement and for the period required by CSSF record-keeping obligations (up to ten years), after which it is deleted or anonymised.

Your rights

Subject to applicable law, you may request access to, rectification of, or erasure of your personal data, as well as restriction of or objection to processing, and data portability. You may also lodge a complaint with the Luxembourg supervisory authority (CNPD).

Contact

For any privacy question or to exercise your rights, contact Armagnac Consulting at thomas.janneau@armagnac-consulting.com.

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Send DDQ invitations

Add a recipient and click VALIDATE to add them to your authorized recipients. Tick the ones to invite, choose which questionnaire to send, and click Send. Each ticked recipient receives their own activation email.

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Reuse a previous questionnaire

Send a renewal DDQ to a delegate that already responded. The new questionnaire is pre-filled with the previous cycle’s answers and conclusion, so the recipient only edits what changed.

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The reviewer has asked you to provide additional detail on the questions below. Your original answers stay in the record — what you write here is added alongside them.

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What would you like to do?

Run a due diligence
Design questionnaires, send them to your delegates, review, score and monitor them.
Respond to a due diligence
Pre-fill your own DDQ once, attach documents, and send a secure DD pack whenever a counterparty asks.
Passport
Exchange DD packs with other Cellar members: request a counterparty's passport, or approve requests for yours. Approved packs land in your DD Reviews.

If your counterparty already uses Cellar, request their existing DD pack instead of sending a blank questionnaire. Enter their email address and click on submit passport. They approve your request and choose which pack to release; you then ingest it as a reviewable DD (it still passes your own review and validation).

Armagnac DDQ
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Operational Due Diligence Questionnaire
Counterparty profile · risk & control framework · regulatory standing & operational resilience

Before you start

This questionnaire is organised into 12 common sections + up to 8 delegate-specific sections (Fund Administrator, Depositary, Investment Manager, Broker, Distributor, IT Firm, Legal Firm, Corporate Secretary). Plus a checklist of supporting documents. Answer the common sections, then complete only the delegate sections relevant to the services you provide. You can press SAVE at any time, your draft is kept locally in this browser. Press SUBMIT when complete.

What you need to do

  1. Start by reviewing the structure and content of the DDQ
    • Review the list of all required documents
    • Review the structure of all sections
    • Review all questions
  2. Add or remove documents, sections or questions
  3. Allocate a risk dimension (Operational, Legal, Reputational, Financial) to each document and question
  4. Save the DDQ
Customisation mode. You can add questions to any section (+ Add question at the bottom of each section), remove existing questions or sections using the button next to them, and undo any change. Edits save automatically. Respondents see the questionnaire reflecting your latest saved version.
0 / 0 questions answered
0 / 0 documents provided
📄1Required Documents

For each document, please tick YES if the document is being provided alongside this questionnaire, or NO if it is not applicable or not available. All rows must be ticked before the questionnaire can be submitted.

Documents YES NO
Certificate of incorporation (dated ≤ 3 months from request)
Articles of incorporation / association / bylaws
Group or legal entity shareholding chart, signed (≤ 3 months, showing BOs with 25%+)
Valid ID or passport + proof of residence of all UBOs with 25% or plus shareholding
Organisational chart, signed (≤ 3 months — Board, ExCo, functional heads)
IT architecture chart, signed (≤ 6 months)
IDs + CVs of board members and senior management officials
RBE / RBO extract (if applicable)
Proof of regulation (if applicable)
Latest audited annual accounts (≤ 12 months)
Second-most-recent audited annual accounts (≤ 24 months)
Certificate of insurance — PII, D&O, cybersecurity (≤ 12 months)
ISAE 3402 Type II report (if applicable, ≤ 12 months)
Policies
AML / CTF
Risk Management
Conflict of Interest
Outsourcing / Delegation
Code of Conduct
GDPR
ESG
IT
0 / 21 documents acknowledged
🏛1The Firm Identity
🧑‍💼2People & Skills
📊3Risk & Control Environment
4Regulatory Standing & Legal
📋5Compliance
🛡6Financial Crime (AML / CFT / Sanctions)
📂7Onboarding (Clients & Investors)
🔗8Delegation
💻9Technology, Data & Cyber
🔁10Resilience (BCP & DRP)
🔐11GDPR
🌿12ESG
Delegate-Specific Sections Answer the section(s) relevant to the services you provide.
📊13Fund Administrators
🏘14Depositaries
📈15Investment Managers
16Brokers
📢17Distributors
💻18IT Firms
19Legal Firms (incl. outsourced Compliance Services)
📋20Corporate Secretary Services Firms
Supporting Documents (optional — drop or click)