This Privacy Notice sets out how SAFFELBERG INVESTMENTS NV and all its affiliated or associated companies (hereinafter jointly referred to as the “Saffelberg Group” or “we”/”us”), collect, process, protect, use or disclose Personal Data on individuals (including: clients, partners, investors, beneficial owners, intermediaries, job applicants or other third parties that the Saffelberg Group deals with, or any individual who is connected to those parties). This Privacy Notice also sets out the rights of those individuals in respect of the Personal Data we process about them.
Saffelberg Investments reserves the right to amend this Privacy Notice from time to time. We will post a notice on our website to notify you of significant changes to our Privacy Notice. The latest updated version can be consulted on the website of Saffelberg Investments: http://www.saffelberg.com. We recommend that you carefully read this Privacy Notice, before providing any Personal Data to us.
If you have any questions or requests with regard to this Privacy Notice, feel free to get in touch with us via one of the methods set out in the “How to contact us” section below.
What does this Notice apply to?
This Privacy Notice applies to our processing of Personal Data (as described below) we collect when you visit one of our websites, Personal Data you provide to us, as well as Personal Data which we acquire through our day-to-day business or obtain from a third party.
What Personal Data we collect about you?
For the purposes set out in this Privacy Notice, we may ask you to provide us with, or we may collect the following Personal Data:
- Identification data: such as your name (including name prefix or title), address, place and date of birth.
- Contact information: such as email address, business or personal address, fax number or phone number.
- Information necessary for the execution of our contractual obligations and rights: such as payment details, details with regard to the company you represent or its business.
- Information related to your use of our website(s): such as IP address, date and time of your visit to our website, type of internet browser and computer operating system used to access our website, referral source, length of your visit, pages viewed and website navigation paths.
- Information you submit in connection with a career opportunity: such as information in your resume and details about your current employment;
Saffelberg Group may gather such Personal Data from a variety of sources, including:
- Personal Data that is provided to us either by you, your representatives or a third party connected to you (for example, from recruitment agents of potential job candidates);
- Personal Data collected by us in the ordinary course of our relationship with you or in connection with your activities on the website of an entity of the Saffelberg Group;
- Personal Data obtained after it has been made publicly available, including via the internet and subscription databases and other open-source materials; or
- Personal Data created by us about you, such as records of your interactions with us, details of your accounts and transactions, telephone calls etc, subject to applicable law.
How do we use your Personal Data?
Depending on your relationship with us, we use your Personal Data for one or more of the following purposes:
- To conduct our business and pursue legitimate (business) interest of Saffelberg Investments or a company of the Saffelberg Group (such as: fund related activities for investors or potential investors; reviewing potential fund portfolio companies for acquisition; monitoring portfolio companies; working with management teams; maintaining existing or potential business relationships with external parties; or when considering job applicants), in relation to an actual or potential business or contractual relationship with you, and if any, to fulfil our contractual obligations or take steps related to the execution thereof, including:
- to identify and contact you;
- to verify certain information with regard to an actual (or potential) business or contractual relationship with you (or the business you represent);
- to assess and respond to your enquiries and requests (if any);
- to process and administer details associated with your investment and service your requests from time to time;
- to provide you with information about our funds and our other services from time to time;
- to conduct market research and to understand how our service may be improved for you;
- to offer and improve our services;
- to perform our contractual obligations or execute our rights;
- to prevent imminent and serious harm to a person or property;
- to protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
- For “client onboarding” purposes, i.e. taking on of new clients, serviced entities and their underlying principals, investors and shareholders; and
- to assess job applications and manage the employee onboarding process for successful candidates.
- Where you give your explicit consent:
- to notify you of new opportunities or services from Saffelberg Group;
- to place certain type of cookies and similar technologies; and
- for any other use where we explicitly asked and obtained your consent.
- For purposes that are required by law (such as anti-money laundering obligations and know your customer due diligence):
- to comply with any relevant law, regulation or other requirements; or
- to respond to any request by the government, a governmental authority or law enforcing authority.
With whom do we share your Personal Data?
For the purpose of legitimate (business) interests, we may share your Personal Data with, and where appropriate transfer it to any company of the Saffelberg Group.
We also may share Personal Data with service providers who perform services on our behalf based on our instructions such as those providing IT-services, web-design, technical, human resource services, marketing and analytical services.
Furthermore, we may disclose Personal Data to third parties, including regulators, law enforcement authorities, other government authorities or others, where we are required to do so by law or legal process.
Advisers, service providers, and agents acting for us may also have access to your Personal Data in the course of our day-to-day business subject to agreement by them of confidentiality and security provisions.
We also reserve the right to transfer Personal Data we have about you in the event we sell or transfer all or a portion of the business or assets from Saffelberg Investments or a company of the Saffelberg Group (including in the event of a reorganization, spin-off, dissolution or liquidation).
Our website might contain links to other websites (such as websites of portfolio companies of Saffelberg Group) and apps, which are not hosted or operated by us. We are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps. The information collected through these websites or apps is subject to the privacy policies or notices of the relevant providers’ website, which we strongly suggest you review.
Once we have received your Personal Data, we may store it in hard copy paper form and/or electronically. Your Personal Data may be transferred to, and stored at, a destination outside the European Economic Area which may not always have data protection laws providing equivalent protection. In such case, we will take steps to ensure that your information is protected by appropriate organisational and security measures, in accordance with the applicable data protection regulations.
How do we protect your Personal Data?
We will use a variety of reasonable technical and organizational security measures and technologies to help protect your Personal Data from unauthorised access, use, disclosure, alteration, loss or destruction, consistent with applicable privacy and data security laws. Although we exercise adequate care and security, there remains a risk that information, including Personal Data, transmitted over the internet and stored digitally or in hard copy, may be intercepted or accessed by an unauthorised third party.
How long do we keep your Personal Data?
We keep your Personal Data for as long as we need it for the purpose it is being processed for. For example, Personal Data processed for the performance of a contract with you, will be kept for as long as necessary to provide you with our services and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns with regard to the execution or termination of such contract. The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any information or marketing materials which would benefit you. We will also keep your Personal Data where we need to do so in connection with legal action or an investigation involving Saffelberg Group.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal or business need for it to be retained.
What are your rights with regard to your Personal Data?
In accordance with and subject to the terms and conditions set out in the General Data Protection Regulation (“GDPR”), you have the right to request access to and rectification or erasure of your Personal Data, restriction of the processing of your Personal Data, or to object to the processing of your Personal Data, as well as the right to data portability.
You also have the right to lodge a complaint with the competent supervisory authority, in Belgium or the member state of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of your Personal Data carried out by Saffelberg Group infringes applicable data protection law. Where you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.
If you would like more information about your rights or have any concerns about Saffelberg Group’s processing of your Personal Data, please let us know by getting in touch with us using the details in the ‘Contact” section on our website or the “How to contact us” section below .
How to contact us?
If you have any questions or requests regarding this Privacy Notice or the Personal Data that we hold about you, or need additional information, please contact us via:
Saffelberg Investments NV
Attn. Compliance Officer
Tel.: +32 2 793 25 50
Fax : +32 2 793 25 59
The following company is the data controller and is responsible for the collection, use, disclosure, retention and protection of your Personal Data in accordance with our privacy standards as well as any applicable national laws.
Saffelberg Investments NV
Registered office: 1755 Gooik, Oplombeekstraat 6 (Belgium)
Company registration number : 0892.301.812
 The text of this GDPR can be found on the following website: https://eur-lex.europa.eu/homepage.html