PROCESSING OF PERSONAL DATA

Last modified: November 24, 2020

The Sustainable Dividends Value Fund (“the Fund”) is managed by Sustainable Dividends BV, located at Spaarnzichtlaan 8, 2101 ZM Heemstede.
Sustainable Dividends BV is responsible as manager for the processing of personal data as shown in this privacy statement.

1. WHAT PERSONAL DATA DO WE PROCESS?
Sustainable Dividends BV (“the Manager”) processes your personal data if a) you have registered via the sustainabledividends.nl website via an email to the Manager for further information, b) if you have registered to receive the newsletter of the Fund, or c) if you register as a participant in the Fund.

a. Registration for the newsletter
The registration for the newsletter takes place via MailChimp, where interested parties enter their details themselves. When you click on the 'Newsletter' button, you will be redirected to MailChimp where you enter the following data, which the Administrator then processes:
• Name (first and last name)
• E-mail address
Mailchimp uses cookies. The Administrator has no influence or control over Mailchimp's use of cookies.

 

b. Further information via an email to info@sustainabledividends.nl
If you send a request for further information to the Manager via info@sustainabledividends.com, the Manager will process your name and email address (and if applicable: your telephone number).
The Manager uses cookies on its website (click here for an explanation).

 

c. Registration as a participant in the fund
See under 8 of this Privacy Statement

 
2. WHY WE NEED THE DATA
The Administrator processes your personal data for the following purposes:
1. General information about the Fund
2. Sending newsletters and other reporting about the Fund.
3. To be able to call or e-mail you if this is necessary to perform the services of the Administrator.
4. Allowing you to create an account on the Fund's website
5. Invite interested parties to investment seminars related to the Fund.
6. Registering for the meetings mentioned under point 5.
7. Creating lists of participants for the meetings mentioned under point 5. These participant lists are only produced for the organization of the event by the Administrator itself.
The Manager also analyzes (anonymous) generic data for the analysis of the use of the website. See under the relevant paragraph 5.

 

3. HOW LONG WE KEEP THE DATA
The Administrator stores your data from the moment you have registered with your email address. When you ask us to delete your data, your data will be deleted as soon as possible. The Fund itself has a legal obligation to keep data for a certain period.

 

4. SHARING WITH THIRD PARTIES
The Manager only shares your personal data with various third parties if this is necessary for the performance of the services after subscription to the Fund (see point 8.) and to comply with any legal obligation. The Administrator concludes a processing agreement with companies, as mentioned under point 8, that process your data on behalf of the Administrator to ensure the same level of security and confidentiality of your data. The Administrator remains responsible for these processing operations.

 

5. WEB VISIT ANALYSIS
The administrator uses Google Analytics to analyze website visits. This service is used to keep track of how often and how visitors use the website. We have not allowed Google to use the obtained Analytics information for other Google services. The Administrator does not collect IP addresses. The information that Google collects is anonymized as much as possible. Google may provide information to third parties if required to do so by law.

 

6. VIEW DATA. MODIFY OR REMOVE
You have the right to view, correct or delete your personal data. You can do this by sending a request by e-mail to info@sustainabledividends.com.
If you want to make use of your right to object and/or right to data portability or if you have other questions/comments about data processing, please send a specified request to info@sustainabledividends.com. To ensure that the request for inspection has been made by you, we ask you to enclose a copy of your proof of identity with the request. Make your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and citizen service number (BSN) black in this copy. This is to protect your privacy.
The Manager will respond to your request as soon as possible, but in any case within 2 working days.

 

7. SECURITY
The Administrator takes the protection of your data very seriously and has taken appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized changes. MailChimp (which is used to register and record email addresses) has its own security system.

 

8. SPECIAL AND/OR SENSITIVE PERSONAL DATA THAT WE PROCESS

 

a. DATA PROCESSING DURING PARTICIPATION IN THE FUND
If you are going to invest in the Fund, register via the registration form 'Private Persons' or the registration form 'Legal Entities'.
The data you provide will then be processed by the Fund's administrator, AssetCare BV. The Manager has concluded a management agreement with AssetCare BV.

AssetCare BV is located at WTC Tower B, 14th floor, Strawinskylaan 1425, 1077 XX Amsterdam.

AssetCare BV has its own privacy policy that you can request from the Data Protection Officer of AssetCare BV He can be reached via +31(0)20 4703550 or via the following email address: bram.writer@assetcare.nl

 

b. MINIMUM AGE
Our website is aimed at professional and non-professional investors. For the latter category, an initial investment in the Fund must amount to at least €100,000. The Administrator therefore does not intend to collect data about website visitors who are younger than 16 years. Apart from providing a (business) e-mail address, we cannot check whether a visitor is older than 16. If you are convinced that we have collected data about a minor without the consent of the parents (or legal representatives), please contact us by e-mail and we will delete this information.

 
9. CHANGES TO THIS PRIVACY STATEMENT
The Manager reserves the right to make changes to this statement if new circumstances make this necessary. You can inform yourself of these changes by consulting the Statement on a regular basis. The date of the last change is stated at the top and bottom of this Privacy Statement.

 

10. QUESTIONS OR COMPLAINTS?
If you have any questions, or if you have the impression that your data is not properly secured and there are indications of abuse, you can contact the Administrator:
• Mail : compliance@sustainabledividends.com
• Call: +31 (0)20 244 36 54
• Writing : Sustainable Dividends BV, Spaarnzichtlaan 8 , 2101 ZM Heemstede

The Administrator would also like to point out that you have the option of submitting a complaint to the national supervisory authority, the Dutch Data Protection Authority. (https://autoriteitpersoonsgegevens.nl/)

 

CONTACT DETAILS OF THE DATA PROCESSING CONTROLLER

Sustainable Dividend BV
Chamber of Commerce number: 69701121
The tasks of the Data Protection Officer of Sustainable Dividends BV are performed by the compliance officer. He can be reached via compliance@sustainabledividends.com or via 06-30110171.

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Last modified: November 24, 2020