Amsterdam, Oct 15th, 2018
More precise, this Policy addresses:
- what personal data we collect and how;
- for what purposes and on what grounds we process your personal data;
- for how long we keep your personal data;
- with whom we share your personal data;
- the rights you have as data subject; and,
- how your personal data is protected.
This Policy applies to all persons who visit our websites and of whom Cyber Capital processes personal data, such as clients, prospects, persons who have subscribed to newsletters or events, and persons who have applied for a job at Cyber Capital.
What are personal data?
Personal data is any information relating to an identified or identifiable natural person. Personal data that we process may include:
- Basic information, such as your first and last name, prefix, title;
- Contact details, such as your e-mail address, postal address and phone number;
- Personal data you provide us for the purpose of becoming our client, such as your nationality, date of birth, country of birth, residence address, TIN-number, bank account number;
- Personal data you provide us for the purpose of attending events or meetings, such as access and dietary requirements;
- Personal data you may provide us for the purpose of a job application, such as your full name, date of birth, address, phone number, nationality, marital status and any other personal data set out in your application;
- Any other personal data relating to you which you may provide us or that we may obtain in relation to the purposes and based on grounds set out below;
We collect this personal data because you provided this data to us. For example, you may provide data when entering into an agreement with us, by entering your data on our website (www.cyber.capital), by giving us your business card or by applying for a job. We may also collect your personal data from other sources, such as from local counsel, counterparties, the Trade Register, the Land Registry or by using publicly available sources. If you are a mere visitor of our website, we will not collect any personal data.
Purposes and legal basis for the processing of personal data
Cyber Capital may process your personal data for the following purposes:
- To identify and accept you as a client;
- To provide our services;
- To comply with our legal and regulatory obligations;
- For marketing and business development activities, such as news updates, invitations for our events and other marketing communications that may be of interest to you;
- To handle your job application or subscription to any of our recruitment services and events.
We will process your personal data using one or more of the following legal grounds:
- Performance of a contract;
- Compliance with a legal obligation;
- Legitimate interest;
- Your consent.
Sharing of personal data
In some cases we may also share your personal data with third parties. This may include, but is not limited to:
- Third parties relevant to the investment services that we provide, such as the fund administrator, regulatory authorities, tax office and governmental institutions.
- Third parties that we engage with, such as supervisory authorities and other bodies, in order to comply with legal obligations.
- Third party suppliers in connection with the processing of your personal data for the purposes described in this Policy, such as IT providers, communication service providers or other suppliers to whom we outsource certain support services.
We will only share your personal data with these third parties for the purposes and on the legal grounds stated in this Policy.
Third parties to whom we transfer your personal data are themselves responsible for compliance with privacy legislation. Cyber Capital is neither responsible nor liable for the processing of your personal data by these third parties. To the extent that a third party processes your personal data as a data processor of Cyber Capital, Cyber Capital will conclude a processor agreement with such party that meets the requirements set out in the GDPR.
To be able to provide our services, it may be necessary for us to transfer your personal data to a recipient in a country outside of the European Economic Area. In that case, Cyber Capital will ensure that the data transfer is compliant with the applicable law.
How long do we keep your data?
Your personal data is kept in accordance with the GDPR.
Your personal data is processed up until the moment that you inform Cyber Capital that you no longer wish to receive any digital notices and/or Cyber Capital stops sending you newsletters, white papers, invitations to events or other digital mailings.
Your personal data will be erased if:
- it appears that your email address is no longer in use (for example when error messages are received);
- the consent based on which your personal data is processed and/or stored is withdrawn by you;
- the aforementioned legal grounds on which your personal data is processed, expires because for example if your company ceases to exist, or you have had any contact with Cyber Capital for a period of 5 years (notwithstanding possible legal obligations).
Our websites only use necessary cookies to optimize their performance. Necessary cookies are cookies that are necessary for the delivery of the functionalities of our websites or services. This allows you, for example, to stay logged in if needed. On each website you will be asked to accept the usage of cookies.
Necessary cookies can be subdivided into:
(i) Session cookies
With the help of a session cookie you can keep track of which web pages you visit and which options you use. A session cookie is only saved for the duration of your internet visit, i.e. one internet session. When you close your internet browser, the session ends, and the cookie is deleted.
(ii) Permanent cookies
With the help of a permanent cookie, our websites can recognize you and your favorites pages on a subsequent visit. A permanent cookie is stored longer than a single session.
What are cookies?
Cookies are small text files that are placed on your computer when you visit one of our websites. Cookies may collect data associated with the use of our websites, such as web pages you have visited and the duration of a user session. When you visit one of our websites, the cookie sends information back to us or to a third party on behalf of whom we have placed the cookie.
If you do not wish to receive any cookies at all, you can adjust the settings of your internet browser to completely block the placement of cookies. You may however not be able to make optimum use of all parts of our websites.
At the end of each digital mailing that you receive from Cyber Capital, you can always change your mailing preferences via the ‘unsubscribe’ or ‘subscribe’ link. Therefore, you can always withdraw your consent.
In addition, you are entitled to request Cyber Capital to allow you to inspect your personal data and/or to correct it, to make additions, to erase it or to hide it, and/or to restrict it, and/or to provide your personal data in a structured, standard and machine-readable format.
In so far as your personal data is processed on the basis of a legitimate interest, you are entitled to object to this processing. You can address any request in that regard to Cyber Capital B.V., Herengracht 416, 1017 BZ Amsterdam, or per email to email@example.com.
Finally, you are entitled to submit a complaint to the Dutch Data Protection Authority.
Security of your data
We want your personal data to remain as secure as possible and accordingly strive to provide secure data transmission between your computer and our servers. Cyber Capital has taken appropriate technical and organizational measures in accordance with the GDPR to protect personal data against loss or any form of unlawful processing.
Cyber Capital may amend this Policy from time to time. On our website, you can always view the latest version of this Policy. We would advise you to check the statement regularly and, in any event, whenever you provide us with personal data.
If you have any questions or comments about our Policy or the processing of your personal data, please send a request in that regard to Cyber Capital B.V., Herengracht 416, 1017 BZ Amsterdam, or per email to firstname.lastname@example.org.
If you want to know more about this subject or have a complaint about abuse of your personal data, please contact the Dutch Data Protection Authority (DAP).