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, hereafter referred to as “Momentum Capital”, is 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. 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 will only use your personal data in accordance with the current privacy legislation. Your personal data will be used for purposes as described in this Privacy Statement. In all other circumstances, Momentum Capital will only use 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 Momentum Capital does 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.
Types of data
Data subjects’ data can be divided into the following categories and is used for the following purposes:
- Name and address;
- Contact details such as phone numbers (cell phone or otherwise) and e-mail address;
- Date of birth;
- Sex and 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;
- 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, use sensitive personal data such as health data or data on crime and criminal justice. This 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 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.
Furthermore, Momentum Capital also acquires 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. 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.
The personal data will be processed if it is necessary for the implementation of the agreement that was made with the data subject. Additionally, certain circumstances may require Momentum Capital to process data in order to comply with its legal obligations. In all other cases, Momentum Capital will ask the data subjects for their consent to process data.
Momentum Capital ensures that justification is provided whenever personal data must be processed. If processing would be unlawful, Momentum Capital will not process your personal data.
Momentum Capital’s processing of personal data is lawful under the following circumstances:
- with your explicit consent, which you can give to Momentum Capital by filling in the consent form or giving written consent in another manner;
- to implement an agreement;
- to send relevant or commercial information, electronic or otherwise, on current events and developments at Momentum Capital;
- to approach you in a targeted manner for your participation in Momentum Capital’s meetings and activities;
- in order to comply with Momentum Capital’s legal obligations;
- because Momentum Capital has legitimate interests in processing the data, such as processing data for direct marketing purposes, forwarding personal data within or between parts of the same organization, and processing data to ensure network security.
Momentum Capital will fulfill its obligation to ensure that the processing is not contrary to the interests or fundamental rights and freedoms of the data subject.
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.
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. These third parties are given access to your personal data. 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 standards. These agreements are documented in processing agreements.
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 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 data that Momentum Capital has collected on you at any time. You have the right to:
(1) publicly inspect the data known to Momentum Capital;
(2) access information on which processing is applied to your data;
(3) correct or modify data known to Momentum Capital;
(4) remove the data (the right to be forgotten);
(5) limit the processing of your data;
(6) 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. 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 when 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 the 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: May 2018
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