1 INTRODUCTION
HVA Capital (HVA Capital Management B.V.) and its affiliated entities are committed to safeguarding your privacy and keeping your personal data secure. We adhere to the General Data Protection Regulation (GDPR) and protect your personal information in line with its principles. This Privacy Policy provides a clear overview of the personal data we collect, how we use it, our commitment to protecting it, and your rights and options to manage your personal data and privacy.
2 WHEN DOES THIS PRIVACY POLICY APPLY?
This Privacy Policy applies to HVA Capital's processing of all personal data related to management teams, investors, business partners, suppliers, experts, and other individuals ("Relations" and each a "Relation").
3 WHAT IS PERSONAL DATA AND WHAT DOES PROCESSING MEAN?
Within HVA Capital, we define personal data as any information that relates to you and identifies you personally, whether on its own or in combination with other information available to us. Processing personal data encompasses any activity involving this information, such as gathering, storing, combining, transferring, or deleting it.
4 HOW DO WE COLLECT PERSONAL DATA?
We collect your personal data from various sources, including directly from you, such as when you opted in for our mailings, contacted us, or provided your business card. We may also collect data from others, such as your co-founder, partner, colleague, or through mutual connections in our network. Additionally, we gather information from publicly available sources, such as LinkedIn or your company’s website, and during our due diligence process. More specifically, we collect personal data when you subscribe to our newsletter, apply or express interest in a job or internship, or register for an event or indicate interest in receiving event notifications.
5 WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?
Name and contact details are collected when you subscribe to our newsletter, apply for a job or internship, sign an employment agreement, or contact us. This includes your name, title, profession, and contact information such as address, telephone number, Teams / Zoom account, social media accounts, and email address.
When you submit an application for an employment or internship position, we may record your name, Curriculum Vitae, motivation letter, contact details, and any other information you share with us. Contact information may include your address, telephone number, Teams / Zoom account, social media accounts, and email address. If testing is part of the application process, additional information may be collected, and you will be informed in advance.
For contracts requiring notarization or compliance with anti-money laundering procedures, you may be required to provide legal identification. In such cases, we will first request your consent before sharing this information with other parties, such as a notary.
When you communicate with us via email, we register your correspondence. If you contact us by phone, we may record your questions or queries in our database.
If you participate in one of our events, you may enter an area where photography, audio, and video recording occur, and your image or voice may be captured. Similarly, if you are part of the management team of one of our portfolio companies or are an employee or intern, your photo or video may be used for publicity purposes. Additionally, we may record information about you if you are involved as an investor, an expert in a specific field, or if your organization enters into a partnership with us.
6. FOR WHAT PURPOSES DO WE COLLECT AND USE YOUR PERSONAL DATA?
We use your personal data for various purposes, as outlined below. This includes data you explicitly provide to us as well as information we collect independently. Some data is required by law or necessary for delivering our services or products, while other information is collected based on your consent. If you choose not to share all requested information, we may be unable to deliver certain services effectively.
When considering an investment in your company, we may request personal data such as your passport copy, conduct a due diligence assessment, and perform a management scan. This data will be retained for two years after the end of the calendar year in which our relationship ends.
We may use your personal data to send you newsletters. If you sign up for our newsletter, register for an event, share your contact details with us to stay in touch, or have received updates from us in the past, we will provide regular updates about HVA Capital via email, regular mail, or social media. You can unsubscribe at any time by using the "unsubscribe" button in the newsletter. This processing is based on your consent if you subscribed, or on our legitimate business interests to communicate effectively, improve our services, and better understand how people engage with us.
We process your personal data to comply with legal and regulatory obligations, such as tax or business conduct requirements. This may involve disclosing your data to government institutions or supervisory authorities.
If we are entering or have entered into a contractual relationship with you (including employment agreements), we process your personal information as necessary to perform or establish the contract.
When interacting with you, we use personal information such as your name and contact history to address your requests and provide optimal service.
For publicity purposes, if you participate in our events, are part of the management team of a portfolio company, or have signed an employment or internship contract, your image or voice may be recorded and used for promotional activities. If you prefer not to be recorded, please inform the photographer or cameraman or notify us directly.
7 WHEN YOU ENTER INTO A BUSINESS RELATIONSHIP WITH US
You may provide personal information to HVA Capital as part of a contract, a broader business relationship, or during the preparatory stages of entering into a contract. This section outlines how we may process such personal data.
We process your personal data to evaluate your application for funding. This includes information directly related to your company and is necessary to manage your request, verify your identity and credentials, and assess any other information you have provided as part of the application process.
For the assessment and acceptance of business partners, we use personal data to confirm and verify identity, conduct due diligence, and screen against publicly available government or law enforcement sanctions lists. This ensures compliance and supports administrative processes.
To conclude and execute agreements with business partners, we process personal data for administrative tasks such as sending invoices, making payments, and managing the delivery or receipt of services or products. This includes handling communications and carrying out agreements effectively.
For business process execution, we use personal data to manage and organize our operations. This includes internal and portfolio management, audits, investigations, business controls, and maintaining directories. Personal data is also processed for finance, accounting, archiving, insurance, legal and business consulting, and dispute resolution purposes. Centralized processing facilities help us operate more efficiently.
8 WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
HVA Capital is responsible for processing all personal data covered by this Privacy Statement. While HVA Capital may share your personal data with third parties, it remains accountable for the data unless it is required to disclose it due to a court order or other legal obligation.
9 WHO HAS ACCESS TO YOUR PERSONAL DATA?
Access to your personal data within HVA Capital
Personal data collected by HVA Capital may be transferred within the organization if there is a legitimate business interest to do so. This data may be shared internally for administrative purposes, such as creating a comprehensive overview of contacts and contracts. HVA Capital employees are authorized to access personal data only to the extent necessary for fulfilling specific purposes and performing their job responsibilities.
Access to your personal data by third parties
Certain third parties may access your personal data as relevant to their provision of products or services to HVA Capital or to you. These third parties may include:
- Service providers relevant to our operations, such as due diligence providers, business partners, investors, and experts.
- Bank payment operators and credit card companies for payment processing.
- Insurance companies.
- IT suppliers and technology service providers hosting our websites.
- Marketing support providers, including digital agencies and mailing houses.
- Debt collectors.
- Fraud bureaus or organizations investigating or preventing misconduct.
- Regulatory bodies, government agencies, and law enforcement authorities.
- Financial advisors, legal advisors, and auditors.
- Other parties legally required to access your personal data.
We may also disclose personal data outside HVA Capital where required or authorized by law, where a public duty necessitates it, where you have expressly consented or where consent can be reasonably inferred, or as otherwise permitted under applicable privacy laws.
When granting third parties access to your personal data, HVA Capital ensures that contractual, technical, and organizational measures are in place to restrict data processing to the necessary scope or as per your consent. These third parties must process your data in compliance with applicable laws. HVA Capital will not sell, distribute, or lease your personal information to third parties beyond the specified circumstances without your consent or unless required by law.
The use of your personal data by data processors
When third parties process your personal data on behalf of HVA Capital, we enter into agreements specifying the conditions under which processing is allowed. These agreements ensure that data processors use your personal data exclusively to provide services to HVA Capital, in compliance with applicable laws and regulations.
10 HOW IS MY PERSONAL DATA SECURED?
HVA Capital has implemented adequate safeguards to ensure the confidentiality and security of your personal data. We have adopted appropriate technical, physical, and organizational measures to protect personal data against accidental or unlawful destruction, loss, damage, alteration, unauthorized disclosure, or access, as well as any other forms of unlawful processing, including unnecessary collection or further processing. These measures include internal Privacy and Information Security policies that all staff must adhere to, regular staff training, and the use of secure servers.
10 TLS (formerly SSL)
We process and transmit your data through a secure internet connection, identifiable by "https" and the padlock icon in the address bar.
11 HOW LONG DO YOU RETAIN MY PERSONAL DATA
Your personal data will be retained for as long as necessary to fulfill the purposes outlined in this Privacy Statement or to comply with legal obligations and resolve any disputes.
12 HOW CAN I EXERCISE MY RIGHTS?
You can request access, correction, restriction, portability, or removal of the personal data processed by HVA Capital at any time, or address any questions regarding our processing of your data, by sending a request to info@hvacapital.com. If you prefer to contact us by mail, please send your request to:
HVA Capital Management B.V.
Mauritskade 63, 1092AD
Amsterdam, The Netherlands.
We are committed to working with you to resolve any complaints or concerns regarding the processing of your personal data. If you feel we have not adequately addressed your concerns or have not complied with applicable privacy regulations, you have the right to lodge a complaint with the data protection authority via their website.
13 WHEN WAS THIS PRIVACY POLICY LAST AMENDED
This Privacy Policy was last updated in December 2024.