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Spectrum Fund

Privacy Statement

This privacy statement explains how we handle your personal data.

 

Personal Data

Personal data refers to information that identifies you or can be linked to you in any way. Examples include your name, phone number, and/or email address. It encompasses all data from which we can deduce your identity.

 

Collection of Personal Data

We primarily receive personal data directly from you when you become or express interest in becoming a client or contact us. Additionally, we may process data obtained from other parties, such as Google, LinkedIn, or the Chamber of Commerce, if necessary for our services.

 

Use of Personal Data

We may request your personal data to provide our services or if you express interest in them. This allows us to:

  • Contact you;
  • Record your data in our systems;
  • Update your information if changes occur;
  • Draft agreements;
  • Perform marketing activities, including sending mailings and invitations;
  • Fulfill legal obligations, such as:
    • Identification requirements;
    • Providing information to tax authorities, government agencies, and regulators;
    • Complying with international laws on money laundering and terrorism financing.

 

We process the personal data of our clients, representatives of our (business) clients, suppliers, and stakeholders.

 

Types of Personal Data

The personal data we may process includes:

  • Your name, address, phone number, and email address, as well as that of your company or foundation;
  • Information on your identity document;
  • Your role concerning an agreement (e.g., authorized representative, legal representative, director, or Ultimate Beneficial Owner (UBO));
  • Payment details, bank account, and/or designated accounts;
  • Contact history, including topics discussed, dates, and communication methods;
  • Information related to security and fraud prevention;
  • Details regarding your financial situation.

 

Special Categories of Personal Data

Special categories of personal data include, for example, criminal records or your citizen service number (BSN). The processing of these data is subject to strict rules.

 

The only special category of personal data we routinely record is your BSN when entering into a personal agreement with us. We require this to fulfill our legal obligation to verify your identity and provide information to the tax authorities.

 

We may also record fraud-related data to assess whether we can or wish to maintain a relationship with you. mWe do not use or process other types of special personal data.

 

Sharing Personal Data

We will only share personal data with third parties when necessary for the optimal performance of our services, to meet a legal obligation, or with your explicit consent. If we share personal data to execute an agreement, we ensure a processing agreement is in place with the relevant third party, guaranteeing the same level of security and confidentiality as we uphold. We remain responsible for this.

 

In cases where we must meet a legal obligation, we may share your data with government agencies, regulatory bodies, tax authorities, or judicial authorities. These entities must comply with the applicable legal requirements for using the data. We ensure that third parties have access only to the personal data necessary for their specific tasks.

 

Accessing, Modifying, or Deleting Data

You can request access to, correction, transfer, restriction of use, or deletion of your personal data at any time or object to its use. Additionally, you may request a copy of your data, for example, for use by another service provider. To do so, please contact our Data Protection Officer using the contact details provided at the end of this Privacy Statement.

 

For your safety, the Data Protection Officer may ask you to verify your identity before addressing your request. When assessing your request, we will weigh your interests against ours and provide a response as soon as possible, within four weeks at the latest.

 

Cookies

Cookies are small files placed on your computer or mobile phone, primarily used to remember user preferences. The cookies used by our website are active only during your session and are deleted once you log out.

 

Securing Personal Data

We consider the security of your data a top priority and invest in protecting the systems that store personal data, as well as in training our staff. We ensure that only authorized personnel can access and process your data.

 

The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) supervises our processing of personal data. For general information about privacy regulations or to file a complaint, you can contact:

 

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ Den Haag

 

Questions and Contact

If you have any questions about our privacy policy, please contact our Data Protection Officer via:

 

Spectrum Fund
Attn: Data Protection Officer
Lisdoddelaan 123
1087 KB Amsterdam
privacy@spectrumfund.nl