This is the Privacy Statement of United Momentum Holding B.V. and the parties that it actively manages or is responsible for managing, with their registered offices at Cruquiusweg 111R in Amsterdam, the Netherlands hereafter referred to as “Momentum Capital” or “we”).
We are a Dutch organization that processes personal data. Processing includes, but is not limited to, using the personal data. Momentum Capital processes your personal data because you use Momentum Capital’s services, or because you gave permission for us to do so for a certain processing.
As Momentum Capital is committed to using personal data responsibly, Momentum Capital handles your personal data carefully. Momentum Capital respects the privacy of all people who are in any way involved with it or use its services.
Momentum Capital processes your personal data in accordance with the current privacy legislation. For example, that means that your personal data are processed for the processes as described in this Privacy Statement. In all other circumstances, Momentum Capital processes your personal data if you have given consent for Momentum Capital to do so.
This Privacy Statement explains which data Momentum Capital uses for which purposes and what we do to protect your privacy. If you have any questions related to privacy, please contact us by sending an e-mail to: firstname.lastname@example.org.
We ensure that there is a legitimate interest (which means a reason) for every processing of personal data. If processing would be unlawful, Momentum Capital will not process your personal data. Our processing of personal data is legitimate if:
- we have your explicit permission to do so. If we require your permission, we will request it from you, for example by asking you to fill in a consent form.
- it is necessary for us to implement an agreement or multiple agreements. Naturally, we need to know who we are entering into an agreement with.
- it is a requirement to be able to send relevant or commercial information, electronic or otherwise, on current events and developments at Momentum Capital.
- it serves to approach you in a targeted manner for your participation in Momentum Capital’s meetings and activities.
- we must do so in order to comply with Momentum Capital’s legal obligations. As an example, if the Wet ter voorkoming van witwassen en financieren van terrorisme (Wwft; Money Laundering and Terrorist Financing [Prevention] Act) applies to us, we must perform a customer investigation, and in some cases even an in-depth customer investigation.
- Momentum Capital has legitimate interests in processing the data. An example of this is when we perform or commission a customer investigation for the purposes of preventing fraud, ensuring orderly business management, streamlining internal processes (assessing and accepting customers), and to prevent money laundering and terrorist financing even if the Money Laundering and Terrorist Financing (Prevention) Act does not apply. Other examples of legitimate interests include processing data for the commercial goals of direct marketing purposes, forwarding personal data within or between parts of the same organization, and processing data to ensure network security.
Momentum Capital only processes data that are required for the pursuit of commercial and business activities. This means that Momentum Capital does not process any data that reveals religious beliefs, ethnicity, or political opinions.
Types of personal data
If we perform a customer investigation, we will process at least the data listed below. This depends on whether you are a natural person, a sole proprietorship, or a legal entity such as a private limited company or a public limited company.
If the involved party is a natural person or a sole proprietorship, then we will process the following personal data to perform a customer investigation.
- First name(s) in full
- Address (including country)
- Date of birth
- Place and country of birth
- Proof of identity
- Type of proof of identity
- Document number of proof of identity
- Date of issue of proof of identity
- City and country where proof of identity was issued
- Transaction data including IBAN data, amount(s), name on which the account(s) is/are registered, number and type of instrument(s)
- The register and registration number if it concerns a sole proprietorship
If the involved party is a legal person, partnership, company, or type of business other than a sole proprietorship, then we will process the following personal data to perform a customer investigation.
- First name(s) (in full) of the manager(s)
- Surname(s) of the manager(s)
- Date of birth(s) of the manager(s)
- First name(s) (in full) of the ultimate stakeholder(s)
- Surname(s) of the ultimate stakeholder(s)
- Proof of identity of the ultimate stakeholder(s)
- Type(s) of proof of identity of the ultimate stakeholder(s)
- Nature and size of the stake each ultimate stakeholder has
- Ownership and input structure
We also identify the purpose and intended nature of the business relationship and process information regarding the source of the means used.
Proof of identity
If a proof of identity document expires, we may ask you to send us a new copy of a valid proof of identity.
In-depth customer investigation
In certain cases, we must perform an in-depth customer investigation. In those cases, we will request supplementary information (including personal data) from you, such as proof that you reside at the address you have submitted, a statement from you or another party (such as a civil-law notary or an accountant) regarding your transactions or your assets.
Other personal data
Furthermore, we may process the following personal data:
- contact details such as phone numbers (cell phone or otherwise) and e-mail address;
- date of birth;
- sex, marital status, family composition;
- payment details such as billing address, bank account number, and – if applicable – credit card details;
- work-related details such as the name of your company, employer, position, and income details;
- origin of the assets;
- technical data on the use of Momentum Capital’s website;
- data on hobbies and interests;
- data for compliance with Momentum Capital’s legal obligations.
Momentum Capital may also, in certain circumstances, process sensitive personal data such as health data or data on crime and criminal justice. These will only be requested if Momentum Capital has a legitimate interest in doing so or if Momentum Capital has received your consent to do so.
The aforementioned personal data may be combined to provide targeted and personalized information.
Momentum Capital acquires personal data from data subjects by asking for it. Additionally, data subjects always have the choice to submit this data to Momentum Capital and can contact Momentum Capital to withdraw their consent for us to process their personal data. We cannot offer, provide, or make available certain services, wholly or in part, if we do not have your personal data.
Furthermore, Momentum Capital also acquires personal data from public sources. This can include information that has been made publicly available, such as which businesses are registered with the Chamber of Commerce and the personal data of contact persons of that business. Momentum Capital approaches each of these persons or legal entities to engage in Momentum Capital’s business and commercial activities. When Momentum Capital first establishes contact with these persons or legal entities, Momentum Capital asks for consent to process personal data.
Momentum Capital always communicates in a transparent manner regarding how the personal data was acquired.
Processing your data
Momentum Capital will process your personal data to enter into agreements and to pursue the goals and corporate interests of Momentum Capital, including engaging in activities, commercial or otherwise, that increase Momentum Capital’s client database, and assessing and accepting customers in relation to fraud prevention and adhering to the applicable laws and regulations.
If you fill in a contact or registration form on Momentum Capital’s website or send Momentum Capital an e-mail, the information you have sent will be saved for as long as is necessary to fully respond to and deal with it based on the nature of the form or the contents of your e-mail. This data will never be used for further unsolicited approaches that are not in line with the interests, question, or request that you indicated.
Momentum Capital uses the personal data that you voluntarily provided to communicate with you and update you on matters that are important to Momentum Capital’s services.
A fixed criterion or retention period does not apply to the categories of personal data that are processed by Momentum Capital. This data will be retained for as long as is necessary.
The personal data will be retained for at least the period during which the data subjects use Momentum Capital’s services, as well as in the following period. This is because Momentum Capital maintains close contact with its customers as well as the fact that many data subjects invest in Momentum Capital for longer periods of time.
In exception to the aforementioned, Momentum Capital must retain certain data for longer periods of time to comply with legal requirements. An example of this is that payment details must be retained for the Dutch Tax and Customs Administration for seven years in accordance with the Algemene wet inzake rijksbelastingen (State Taxes Act).
The exchange of data
Your personal data may be exchanged and combined at Momentum Capital.
To process your personal data, Momentum Capital sometimes employs third parties that are given access to your personal data, including banks and administrative offices that are relevant to our service provision, external service providers connected to the processing of your personal data such as ICT service companies, accountants, or other parties to which we outsource some supporting services. Where possible, Momentum Capital obligates these parties to act in their capacity as processors, which means that Momentum Capital determines the goal and means in advance and that the processor works in accordance with Momentum Capital’s instructions and safety requirements. These agreements are documented in processing agreements.
As an example, Momentum Capital has an administrative agreement with SGG Financial Services B.V. (hereafter referred to as “SGG”) to have Momentum Capital’s participant administration conducted by SGG. Therefore, Momentum Capital signed a Processor Agreement with SGG for that purpose. The personal data of involved parties listed in this Privacy Statement can be processed by SGG based on this Processor Agreement. For the processing of these personal data, SGG can make use of its sub-processors SGG Holdings S.A. and companies affiliated to it.
It is possible that some processors are located outside of the EU, where different laws and rules apply. In such cases, supplementary agreements will be made in which Momentum Capital ensures that the same level of privacy protection can be guaranteed for Momentum Capital’s data subjects.
Momentum Capital makes the utmost effort to take appropriate technical and organizational measures to prevent the loss of personal data or unauthorized access. Momentum Capital works with vendors active in software and IT security that have sufficient resources and management procedures to secure the personal data Momentum Capital processes to prevent unauthorized access or publication while guaranteeing the accuracy and correct use of the data.
Rights of data subjects
You can request access to the personal data that Momentum Capital has collected on you at any time. You have the right to:
- publicly inspect the personal data known to Momentum Capital;
- access information on which processing is applied to your personal data;
- correct or modify personal data known to Momentum Capital;
- remove the personal data (the right to be forgotten);
- limit the processing of your personal data;
- transfer your data to other parties if possible (data portability).
Momentum Capital hereby informs you that you have the right to submit a complaint to the Dutch Personal Data Protection Authority. As Momentum Capital makes the utmost effort to ensure you are satisfied with Momentum Capital’s services and handling of your personal data, Momentum Capital would prefer to first review the options for an appropriate solution with you.
If you wish to exercise the right to be forgotten, this may conflict with Momentum Capital’s ability to provide services or comply with regulations such as Momentum Capital’s legal obligations. Together with you, Momentum Capital will ensure that an appropriate solution is found for you to best exercise your right.
You can also revoke any previously granted consent to process your personal data.
You can submit a request as specified above, if Momentum Capital processes your personal data. This application must be submitted in writing by mail or by e-mail.
Momentum Capital reserves the right to change this Privacy Statement. In that case, the review date will be updated. You can find the most recent version on Momentum Capital’s home page.
Published: March 2019
Momentum Capital greatly values your privacy. A Data Privacy Officer has been appointed to ensure that your interests are represented. If you have any questions, you can contact:
Data Privacy Officer
Phone number: +31 (0)20 – 5600 800
Cruquiusweg 111 R
1019 AG Amsterdam