Privacy Statement

To provide our services we use a lot of data, including your personal data. We are aware of the risks of this, and are extremely careful about protecting your data. We are in full compliance with EU General Data Protection Regulation (GDPR). We also encourage you to read our Privacy Policy carefully, so you can better understand why and how we collect, process and destroy your data. Should anything be unclear, we are happy to answer your questions about how your data is used.

From time to time, we may need to change this Privacy Policy. The most recent version of this Privacy Policy is available on our website. In case of important changes of our Privacy Policy, we will inform you of these changes.

1. What personal data do we collect?

We may control, process and use your personal data, which may include names, postal addresses, email addresses, telephone numbers or any other personal data that you provide to us. We may also, in appropriate cases and to the extent permitted by law, control, process and use certain special categories of personal data which are more sensitive in nature. Also in order to send you our updates and newsflashes and to invite you for events regarding matters of your particular interest (the Mailings) we could process your personal data.

2. How do we collect your personal data and why?

We may collect information about you:

  • directly from you;
  • from other sources, such as your (former) employer or colleagues;
  • from publicly available sources such as LinkedIn or the corporate website of the organization you are working for; and
  • by means of cookies.

Where we act as data controller, we rely on the following legal basis for processing your personal data:

Consent: if you are a recipient of our online direct marketing;

Legitimate interests: if you are our client or prospect client, business affiliate, employee or potential employee, or our website visitor;

Performance of contract: if you are our client, supplier, employee, akin to employee or business affiliate or our website visitor;

Legal obligation: if we process personal data according to requirements of domestic legislation.

Where we act as data processor, we process personal data on behalf of data controller and we act on their written instructions.

Below we have set out for what purposes we could collect your personal data:

  • provision of our services and administration thereof;
  • promotion of ideas and events relating to services we provide;
  • accuracy of client records;
  • maintenance of records of communications and management of your relationship with us;
  • to respond to your enquiries;
  • to comply with any present or future law, rule, regulation, guidance, decision or directive (including those concerning anti-terrorism, fraud, AML and anticorruption);
  • to carry out, in appropriate cases, KYC checks and other procedures that we undertake prior to you becoming an investor, investee or counterparty of ours; and
  • Prevention and detection of fraud and other illegal activity or misconduct.

3. With whom do we share your personal data?

In the context of the purposes as listed above, we may share your personal data with third parties. On an occasional basis we could be required, by law, to pass on some of the personal data to:

  • law enforcement agencies; financial regulators and other relevant regulatory authorities; government bodies; tax authorities; courts tribunals and complaints/dispute resolution bodies;
  • other bodies as required by law or regulation; or
  • financial institutions such as trustees, custodians and sub-custodians; insurers; fraud protection agencies; and/or similar suppliers or service providers.

To fulfil our contract with you, we may also provide information to:

  • IT services including client relationship management platforms; and
  • intra group to related affiliates also working on providing you with related services.

We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party. For example, we have entered or will enter into data processing agreements with relevant parties (providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data).

When we share your personal data as set out above with other parties located in countries outside the European Union, these countries may offer a lower level of data protection than in the Netherlands. In such case, it shall be ensured that adequate measures are taken to ensure adequate protection of your personal data in accordance with applicable data protection legislation on the basis of agreements made by the European Legislator or on the basis of your consent.

4. How long do we store your personal data? 

We will keep your personal data for no longer than reasonably necessary. We will retain your personal information in accordance with legal and regulatory requirements. If you no longer wish to receive our Mailings, we cease the sending of the relevant Mailings, or when it appears that your email address is no longer in use (for example when we receive a filed delivery notification).

5. What are your rights and how you can exercise them?

Please note that you can always unsubscribe from our Mailings. Further, you have the right to:

  • information about and access to your personal data;
  • rectify your personal data;
  • erasure of your personal data (‘right to be forgotten’);
  • restriction of processing of your personal data;
  • object to the processing of your personal data;
  • receive your personal data in a structured, commonly used and machine readable format and to (have) transmit(ted) your personal data to another organization.

To exercise your rights, please contact us. You will find the contact details at the bottom of this Privacy Policy. Finally, you have the right to lodge a complaint with the relevant Data Protection Authority, such as the Dutch Data Protection Authority.

6. Use of cookies in Mailings or on our website

You should be aware that “cookies” embedded in this website enable Climate Fund Managers to track browsing patterns by users. Any information held about individuals as a result will be subject to the above standards of protection.

If you wish to avoid this tracking, you can unsubscribe from our Mailings or customise the settings of your browser so that it refuses cookies.

Most web browsers automatically accept cookies, but you can usually customize the settings of your browser so that it refuses cookies. You must set your settings for each browser and on each computer you use.

Contact 

We are Climate Fund Managers U.A., located at Korte Vijverberg 4, 2513 AB, The Hague, The Netherlands.

We have no regulatory obligations under the GDPR to appoint a data protection officer. Currently we have not appointed a data protection officer.

If you have any questions, comments or complaints in relation to this Privacy Policy or the processing of your personal data by us in the context of the Mailings, please feel free to contact your relationship manager or contact us via info@climatefundmanagers.com or +31 (0) 70204 52 05.