PRIVACY POLICY

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.

Personal data must be processed lawfully, fairly and in a transparent manner according to EU General Data Protection Regulation (GDPR). In line with the GDPR, we have published our Privacy Policy (this document) so you can better understand why and how we collect, process and destroy your data. We are committed to protecting and respecting your privacy. This Privacy Policy sets out the legal basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. Furthermore, this Privacy Policy includes important information regarding your rights with respect to the processing of your personal data. Therefore, we encourage you to read this Privacy Policy carefully. 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. Check this page to ensure that you are up-to-date on our Privacy Policy

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’);

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

This site uses Cookies. Cookies are text files placed on your computer to collect standard internet information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

You can set your browser not to accept cookies and can also remove cookies from your browser. However, if you do, some features on our website may not function as a result.

You can find out more information about cookies and how to remove cookies by visiting allaboutcookies.org or cookiecentral.com



Contact

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, please feel free to contact your direct contact person at Sail Ventures or contact us via E: info@sailventures.com or  T: +31 (0)20 2400 2200