Last reviewed: 25 June 2018
Table of contents
- About us
- What is personal data?
- The use of personal data
- How we share your personal data
- Processing personal data of children
- Your legal rights
- Retention of your personal data
- Changes to this privacy statement
- Contact information
1. About us
HFDP B.V., trading under the name Quore Capital, Joh. Vermeerstraat 9.3, 1071 DK, Amsterdam, Chamber of Commerce registration number 34310622 0000, (hereinafter referred to as “Quore Capital”) is responsible for the processing of personal data we collect of you (‘you’, ‘your’, ‘participant’) in the framework of your visit to and use of our website. Our registered office is located within the European Union, and therefore we process your personal data in accordance with applicable European data protection legislation and other statutory provisions.
2. What is personal data?
Personal data is information relating to a directly or indirectly identified or identifiable individual. Indirect identification means combined with other information, e.g. your name, address, email address, and telephone number or unique extension number.
3. The use of personal data
We process your personal data for the purposes and based on the principles set out below. We never collect or process more or other types of data than necessary for these purposes. We collect and process your data, because you have subscribed to our correspondence by email or because you have consented otherwise to us. We only use your personal data in the manner set out in this privacy statement, unless you have given us your explicit consent for other use of your personal data. If we intend to use your personal data for other purposes, we shall inform you of this in advance, and, if the processing of your personal data is performed based on your consent, we shall not use your personal data for any other purposes without your prior consent.
Profile data and direct communication
For some of our services we collect your personal data, including: name, address, telephone number and email address (‘Profile data’). We use your profile data to communicate with you and to inform you about our policy.
Legal obligations and defense
We may be asked to use and retain your personal data for legal and compliance reasons, for instance to prevent, trace, or investigate an offence, to prevent loss, fraud, or any other misuse of our services and IT systems. We can also use your personal data to meet our internal and external monitoring requirements, information security purposes, or to protect, exercise or safeguard our rights, privacy, safety or property or that of others.
4. How we share your personal data
If necessary, we have other companies and individuals perform certain tasks on our behalf, tasks that contribute to our services within the framework of data processing contracts. We may, for example, disclose personal data to fiduciaries, contract parties or partners to host databases and applications. We only share and provide access to such data with and for external service providers in sofar as this is required for the respective purpose. They shall not use these data for any other purposes, in particular their own purposes or those of third parties. The external service providers of Quore Capital are under a contractual obligation to respect the confidentiality of your personal data.
- In the event of a reorganization, restructuring, merger, sale, or other transfer of assets (jointly ‘business take-over’), we may transfer any and all data, including personal data, in a reasonable format and insofar as necessary for the business takeover, and under the condition that the receiving party agrees to respect your personal data in a way that meets applicable data protection legislation. We shall continue to guarantee the confidentiality of personal data and inform users concerned before the personal data shall be subject to another privacy statement.
- We shall only disclose your personal data to government agencies if so required by law. Quore Capital, for example, responds to requests of law courts and law enforcement agencies, regulatory authorities, and any other governmental bodies, including any authorities in countries other than your country of residence.
International transfer of personal data
- Under specified circumstances Quore Capital may be required to transfer your personal data to countries outside the European Union/European Economic Area (EEA), so-called ‘third countries’. Such transfers to third countries may relate to any of the processing activities described in part 3 of this privacy statement.
5. Processing personal data of children
Quore Capital shall not collect or process personal data of children under the age of 13 without the consent of their parents, in compliance with applicable local legislation. If we learn that personal data of a child under the age of 13 is collected unintentionally, we shall immediately remove these data.
Quore Capital attaches great importance to data security. We maintain an appropriate level of data security for which we have implemented physical, electronic, as well as administrative procedures, in order to protect the data we collect against unintentional or illegal destruction, loss, alteration, unauthorized disclosure of or access to personal data that are sent, stored, or processed otherwise. Our information security policy and information security procedures meet and correspond with generally accepted international standards, and are reassessed and updated on a regular basis if necessary to meet our professional requirements, technological changes, and statutory requirements. Access to your personal data is provided only to staff, service providers or subsidiary companies of Quore Capital, for legitimate business reasons only or if so required for the performance of their duties.
In the event of a data breach involving personal data, Quore Capital shall follow-up on any applicable statutory reporting obligations with regard to data breaches involving personal data.
7. Your legal rights
As a person concerned you have specific legal rights with regard to the personal data we collect of you. This applies to all processing activities included in part 3 of this privacy statement. Quore Capital respects your individual rights and shall deal with your concerns appropriately.
The list below includes information on your legal rights arising from applicable data protection legislation:
- The right to withdraw consent:
If the processing of personal data is based on your permission to do so, you have the right to withdraw this consent at any time by following the procedures in the respective consent form. We guarantee that your consent can be withdrawn in the same fashion as it was given, for example electronically.
- The right of rectification:
You may request that we rectify your personal data. We shall make reasonable efforts to keep the personal data, that we own or manage and are used continuously, accurate, complete, up-to-date and relevant based on the most recent information available to us.
- The right to restriction of processing:
We will grant you restriction of the processing of your personal data, if:
- you contest the accuracy of your personal data for the period we need to verify the accuracy,
- the processing is unlawful and you request restriction of processing of your personal data, instead of erasure thereof;
- we no longer need your personal data, but you need them for the establishment, exercise or defence of legal claims; or
- you object to the processing of your personal data while we check if our justified reasons take precedence over yours.
- The right of access:
You may request information from us regarding the personal data we keep of you, including information about what category of personal data we own or control, what the data are used for, where we collected the data if not directly from you, and to whom we have disclosed the data in the recent past , if applicable. You may request from us a free copy of personal data we own of you. We retain the right to ask a reasonable fee for any second copy you request from us.
- The right to portability:
At your request we shall transfer your personal data to another data processing controller, if technically possible, provided that the processing of the data is based on your consent or is required for the perfomance of a contract. Instead of receiving a copy of your personal data, you may request that we directly transfer the data to a different data processing controller to be appointed by you.
- The right to request the erasure of data:
We shall erase your personal data at your request, if
- the personal data are no longer required in connection with the purposes for which they were collected or processed;
- you have the right to object to further processing of your personal data (see below) and you exercise this right to object to this processing;
- the processing is based on your consent, you withdraw your consent and no other legal reason for the processing of your data remains;
- the personal data were illegally obtained; unless the processing of your data is required
- to meet a legal obligation for which we have to process your data;
- in particular for any statutory obligation for data retention;
- for the establishment, exercise or defence of a legal claim.
- The right to object:
You may at all times object to the processing of your personal data as a result of your specific situation, provided that this processing is not based on your consent but our legitimate interests or those of a third party. In this case we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and a higher interest for the processing of the data or for the establishment, exercise or defence of a legal claim. If you object to the processing of your personal data, please mention that you object or that you wish your personal data to be erased or that we restrict the processing of your data.
- The right to lodge a complaint:
In the event of a suspected infringement or applicable data protection legislation, you can lodge a comlaint with the appropriate supervisory authority in the field of data protection, in the country you reside in or the country where the suspected infringement occurred.
We shall try to honour your request within 30 days. This period may, however, be extended for specific reasons relating to the specific right or the complexity of your request.
- Limitation of access:
In certain situations we may not be able to provide you access to all or some of your personal data due to statutory regulations. If we reject your request for access, we shall inform you of the reason of our rejection.
- No identification:
In certain situations we may not be able to look up your personal data due to the means of identification you used in your request. Two examples of personal data we cannot look up if you provide us with your name and email address:
- data collected through cookies in browsers;
- data collected from public social media sites where you posted comments using a nickame we do not know of.
In such situations in which we cannot identify you as a person concerned, we shall not be able to meet your request to exercise your legal rights as described in this section, unless you provide us with extra information that enables us to identify you.
- Exercising your legal rights:
To exercise your legal rights, please contact us in writing or electronically, e.g. by letter or email.
8. Retention of your personal data
In general we erase the personal data we collected from you as soon as the data are no longer required for the purposes we originally collected them for. It may, however, be necessary that we keep your personal data for a longer period, due to statutory provisions.
Furthermore, we shall not erase all your personal data if you requested that we do not contact you in the future. For this purpose Quore Capital keeps a record with information about persons who do not want us to contact them in the future. We consider your request a consent for the retention of your personal data for our records unless you instruct us otherwise.
9. Changes to this privacy statement
We reserve the right to change or update our privacy practices at all times, and at our discretion. We therefore encourage you to read this privacy statement on a regular basis. This privacy statement was updated on the ‘last reviewed’ date stated at the top of this page. We shall treat your personal data in accordance with the privacy statement under which they are collected, unless we have your permission to treat them otherwise.