1. Introduction

In the context of our activities, Laton Ventures GP B.V. (hereinafter: Laton Ventures or we) Laton Ventures may collect, store, transfer or otherwise process personal data. Based on applicable data protection and privacy law and, in particular, the General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (UAVG), we qualify as the Data Controller with respect to the processing of your personal data.

In case that we act as a fund manager of an investment fund, in the context of our activities, the administrators of such investment fund, PraxisIFM Netherlands B.V. and Bunch Capital B.V. (the Administrators), qualify as the processors, and will at all times act in accordance with and pursuant to the provisions of the Data Protection Laws as applicable to them.

2. Who are we?

We are Laton Ventures GP B.V. with our registered office in Amstelplein 1, 24th Floor, 1096HA Amsterdam, the Netherlands. We are registered with the Dutch Chamber of Commerce (Kamer van Koophandel) under number 91187427.

By using our services and/or our website and by providing your personal data to us and the Administrators, you acknowledge that your personal data will be processed in accordance with this privacy statement. The aforementioned data includes, but is not restricted to, data such as your name, residential address, email address, place of birth, date of birth, bank account details and details relating to your investment activity. In our use of this personal data, we will be characterised as a “data controller” under the GDPR. Our affiliates and delegates, including but not limited to the Administrators, may act as “data processors” under the GDPR

3. What does this policy cover and to whom is it relevant?

This privacy statement is relevant for our investors or prospective investors, as well as for employees of our (future) investors, participations, our partners or service providers and relations, persons that contact us or who want to be kept up-to-date of our services, as well as for job applicants (hereinafter: you).

This privacy statement explains how we collect your personal data, on what legal basis, how and for which purposes we process your personal data and to which parties your personal data may be transferred. Additionally, this privacy statement contains important information about your rights in relation to the processing of your data.

4. What personal data do the we collect and in what manner?

We may collect your personal data in different ways:

• When you voluntarily share your personal data with us, for example if you communicate with us via email or by other means, or when you apply for a job with us;
• Directly from you, when you are an investor/entrepreneur/relation;
• From your employer, if you are employed by one of our investors, participations, relations or advisers;
• From other third parties, for instance if you are employed by one of our service providers or by a third party with which we conduct business, or if you apply for a position via a recruitment agency, via references, (previous) employer(s), educational institutions or research agencies (in case of precedential investigations);
• Through public registers, such as trade registers or through the Chamber of Commerce;
• From third parties, for instance if they lawfully transfer your data to us, in order for us to contact you and provide our services to you.

We collect and process (part of) the following personal data:

• Name, address and place of birth;
• Contact details, including addresses, phone numbers and email addresses;
• Bank details and other financial data, such as: (annual) financial statements and accounting data;
• Information on your participations, investments, income, profits and losses;
• Business contact details, company name and job title;
• CV, educational and professional experience, references, statement of conduct or outcomes of precedential investigations, answers to questions during job interviews, test results, professional certificates;
• Copies of your passport, ID-card and/or other identification data;
• Information from public registers, such as extractions from the Chamber of Commerce;
• Information from external sources (search engines, sector specific news articles, social media) which we combine with the data that we collect from you ourselves, in order to construct a more comprehensive and accurate set of information on you;
• Information relating to anti-money laundering and anti-abuse legislation, such as identification data and (where relevant) additional information if you are a regarded as a ‘politically exposed person’.

5. Legal bases for processing

We process your personal data based on one of the following legal grounds:

• If the processing is necessary for the performance of a contract to which you are party (or in order to take the necessary steps prior to entering into a contract with you), as described below under (a);
• If the processing is necessary to comply with our legal obligations, such as described below under (b);
• If the processing is necessary for the purposes of the legitimate interests pursued by us, such as described below under (c) to (h);
• If the processing is based on your consent as described below under (i).

6. Purposes for processing

We process your personal data for the following purposes:

(a) to (be able to) provide our services to you and/or to comply with our contractual obligations;

(b) to comply with the legal obligations to which we are subject in relation to tax legislation, anti-abuse and anti-money laundering, KYC obligations, obligations of the Dutch Act of Financial Supervision (Wet op het financieel toezicht) and other legal obligations;

(c) to assess whether you are suitable for the position for which you apply and to possibly enter into an employment contract with you, as well as to prevent the reassessment of applicants;

(d) to keep administrative records, for instance of our investors, debtor and creditor administration, and relationship management;

(e) for communication purposes, such as the processing of and responding to your requests, inquiries and complaints, the maintenance of business relations (if you are employed by our investors, participations, service providers or advisors);

(f) to establish, exercise, or defend our legal position and rights;

(g) for marketing purposes which in our view may be relevant for you, to and to inform you of new investment opportunities;

(h) for analytics and research purposes, for instance in relation to the prevention of fraud and abuse, but also to improve our services

(i) for sending newsletters and press releases to you following your consent.

Insofar as we process your personal data based on your consent, for instance for the purpose of sending newsletters or marketing material if you are not yet one of our investors or participators, or for the purpose of placing cookies when visiting our website, we hereby inform you that you have the right to withdraw your consent, at any time, by using the ‘unsubscribe’ function in our newsletter or by contacting us directly, without affecting the lawfulness of processing based on consent before its withdrawal.

7. With whom do we share your personal data?

You understand that in certain circumstances we and/or our authorised delegates may be legally obliged to share your data and other financial information with respect to your interest in the Partnership with the Dutch tax authorities and they, in turn, may exchange this information with foreign tax authorities, including tax authorities located outside the European Economic Area (EEA).

We anticipate disclosing your personal data to the Administrators and their affiliates and this may include certain entities located outside the EEA. 

8. How do we protect your personal data?

We have taken technical and organisational security measures to protect your personal data as adequately as possible against destruction, loss, alteration and unauthorised access, storage or other processing operations. If you have the impression that your data is not properly secured or there are indications of misuse, you can contact us via our contact details as mentioned in paragraph 11.

Also, we strive to keep your data accurate and up to date. In that context, we request you to actively inform us about any changes of your personal data (such as a change of address).

9. Your rights

You understand that you have certain rights regarding our use of your personal data such as:

• the right to access your personal data (in an easily readable form);
• the right to examine and correct your personal data;
• the right to restrict the use of your personal data;
• the right to withdraw any consent given to the processing of your personal data (where applicable);
• the right to receive information regarding any entities we disclose your personal data to; and
• the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

You also have the right to object to the processing of your data where we have considered this to be necessary for the purposes of our legitimate interests.

Please note that the right for your data to be erased (the “right to be forgotten“) that applies in some contexts under the GDPR is not likely to be applicable to most, if not all, of the personal data you provide to us, given the specific nature of the purposes for which we use the data, as described above.

10. Contact

If you have any questions, remarks or complaints about how Laton Ventures processes your personal data, if you want to exercise your rights or if you have any questions about the contents of this privacy statement, please contact Gorkem Turk, email: [email protected].