To provide our services we use data, this sometimes includes your personal data. Protecting it and controlling it is essential for us. We are happy to answer your questions about how your data is used.
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. Furthermore, we could process your personal data in order to send you our updates and newsflashes and to invite you for events regarding matters of your particular interest.
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, our technical assistance providers, investors, or clients; and
• from publicly available sources such as LinkedIn or the corporate website of the organization you are working for;
Where we act as data controller, we rely on the following legal basis for processing your personal data:
Consent: if you are a relevant stakeholder who is engaged during our business operations;
Legitimate interests: if you are our client or prospective 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 the 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 enquires;
• to comply with any present or future law, rule, regulation, guidance, decision or directive (including those concerning anti-terrorism, fraud, anti-money laundering and anticorruption);
• to carry out, in appropriate cases, Know-Your_Client (“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. What does Pseudonymisation of personal data mean?
Sail Ventures collects information on various stakeholders while performing services relating to projects and mandates or performing its business operations. This could occur for instance when documenting engagement with indigenous groups. In such situations, pseudonymisation will be applied where possible to your personal data. ‘Pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separate and is subject to measures ensuring that this personal data is not attributed to an identified or identifiable natural person.
4. With whom do we share 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
• 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. 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.
5. What are your rights and how you can exercise them?
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’);
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