Privacy Policy

In the following, the Capitalmind B.V. (in short: “Capitalmind”, “we” or “us”) informs about the collection of personal data when using this website.

In order to make this information about the processing of personal data more comprehensible, we offer in some places in the highlighted text fields simplified summaries of the respective section. Although we provide you with the summary, it is important and necessary for you to read completely the relevant information about the processing of your personal data.

If you want to read certain sections first, click on the following headings:

1. Scope

2. Responsibilities

3. Hosting

4. Personal Data

5. Your Rights

6. Your Contact with us

7. Service Provider

8. Processing of your Data

9. Retention Duration and Retention Periods

10. Usage of Cookies

11. Receivers and Categories of Receivers

12. Deal rooms – Firmex Cloud Service

13. Newsletter

14. Usage of Google Analytics

15. SSL-Encryption with Cloudflare

16. Data Protection Officer

17. Change of this Information

18. Contact

1. Scope:

This privacy policy applies to the internet offer of Capitalmind and to the personal data collected via this dutch-language website.

Capitalmind B.V. does not act as controller in the following situations:

  • Personal data processed in connection with a contractual relationship or upon entering into a contractual relationship with a specific Capitalmind national company outside the Netherlands. In this case, the person responsible for personal data is the Capitalmind contracting company, which is the company with which you or your employer have entered into or will contract.
  • Personal data collected at the physical location of a Capitalmind country company outside the Netherlands. In this case, this national company is the person responsible for the personal data.

You can access the privacy policy of the national Capitalmind companies via the language switch in the navigation menu.

For websites of other providers to which links are referenced, the privacy and security policies of the owners of the external website apply.

2. Responsibilities:

Responsible for the processing of personal data on these Internet sites within the meaning of the General Data Protection Regulation (in short: “GDPR”) is:

Capitalmind B.V.
Reitscheweg 49
5258 BX ‘s-Hertogenbosch
Netherlands

Represented by the management:
Bart Jonkman

3. Hosting:

The internet service is provided by WebProfit, Edisonweg 30, 4207 HG Gorinchem, Netherland and thus based in the European Union. The technical service provider acts on our behalf and according to our specifications.
WebProfit only provides us with the storage space for operating these internet pages and does not receive any personal data from us. The integration of this service provider is based on our legitimate interest (Article 6 (1) sentence 1 GDPR) for the performance, maintenance and operation of these internet pages.

4. Personal Data:

Personal data is any data personally available to you, e.g. Name, address, e-mail address, user behavior.

Pursuant to Article 4 of the GDPR, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

5. Your Rights:

You can claim all your rights:
– Right of access
– Right of rectification
– Right to erasure (‘right to be forgotten’)
– Right to restriction of processing
– Right to object
– Right of withdrawal
– Right to data portability
– Right to lodge a complaint with a supervisory authority

You can also unsubscribe from a newsletter. To unsubscibe please please follow the link in the newletter or send an email to info@capitalmind.com

As a user of our Internet service, you have different rights according to the GDPR, which arise in particular from Articles 15 to 18, 20, 21, 77 GDPR:

a. Right of access:

You can request information about your personal data processed by us. In your request for information, please specify which data you want to receive information about.

b. Right to rectification:

If the information concerning you is no longer correct, you may request a correction. If your data is incomplete, you can request a completion.

c. Right to erasure (‘right to be forgotten’):

Under the conditions of Art. 17 GDPR you can request the deletion of your personal data. Your claim to deletion depends whether the data concerning you is covered by a retention right or is still needed by us to fulfill our legal obligations.

d. Right to restriction of processing:

Within the framework of the provisions of Art. 18 GDPR you have the right to demand a limitation of the processing of the data concerning you.

e. Right to object:

You have the right, at any time, to object to processing of your data for reasons that arise from your particular situation. This applies in particular if we process your data for a legitimate interest. However, we can not always follow this, for example, if we are required to archive the data in accordance with the provisions of the tax code for audit purposes. In this case, however, the data will be blocked for further use and deleted after the end of the legal retention period.

f. Right of withdrawal:

If you have given us consent to the processing of your data, you have the right to revoke your consent at any time. This does not affect the legality of the consent based on the consent until the processing has been revoked.

g. Right to data portability:

You have the right to receive the data relating to you provided to us in a structured, common and machine-readable format. If you have made the data available on the basis of a consent or on the basis of a contract, you have the right to transfer the data to a person named by you.

f. Right to complain:

If you believe that we have not complied with data protection regulations when processing your data, you can submit a complaint to a data protection supervisory authority, which will review your complaint.

A list of the addresses of the data protection supervisory authorities can be found under:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

6. Your contact:

If you contact us on your own, we will save your data only to fulfill your request. The data will then be periodically deleted if we are not required by law to retain it.

When you contact us (via email), only the data provided by you (your email address, if applicable your name) will be stored by us to answer your questions. We delete the data that arises in this context after the storage is no longer required, or limit the processing if there are statutory retention requirements.

The transmission of your data as a result of a request is made voluntarily by you, so you give at the same time your consent for processing of your data (legal basis is Art. 6 para. 1 p. 1 lit. a GDPR). In addition, we have a legitimate interest according Art. 6 (1) S.1 lit. f GDPR to answer your request. Should your request be aimed at the conclusion of a contract, then the legal basis in accordance with. Art. 6 para. 1 p. 1 lit. b GDPR given.

7. Service Provider:

We will only share your information with the service providers mentioned in this information. In addition, we will not share any information without your consent.

If we use contracted service providers for individual functions of our offer or if we would like to use your data for advertising purposes, we will inform you in detail below about the respective transactions. Further disclosure to other third parties will not take place without your consent.

8. Our handling of your data:

We’ll process data from you if you:
– visit our websites
– communicate with us

We process data for the creation of static values by using cookies and when visiting our websites, a log file is created containing information transmitted to us by your browser, such as the time of retrieval and the amount of data transmitted.

In the case of an informative use of the website, i.e. if you do not register or otherwise provide us with information, we will only collect non-personal access data transmitted by your browser to our server (so-called “log files”). If you vsit our website, we collect the following data that is strictly necessary for us to display our website and to ensure the stability, functionality and security of both sites, so that the collection of this information is justified on both sides (legal basis is Art. 6 (1) (1) (f) GDPR). A transfer of these data to third parties does not take place.

Each time an internet file is requested, the following non-personally identifiable access data will be stored at Capitalmind:

• the page from which the file was requested,
• the name of the called file,
• the date and time of the request,
• the transferred amount of data,
• the access status (file transfer, file not found etc.),
• the access type (GET, POST),
• the browser or operating system used,
• the anonymized IP address of the requesting computer,
• the session ID

For reasons of data security, that is, to clarify unauthorized access or to prevent misuse of the website, the full IP address of the requesting computer is recorded, stored and automatically deleted 90 days after the end of access.

9. Retention Duration and Retention Periods:

The data collected in the context of inquiries (eg via e-mail) are stored for a period of 3 months, as long as we have no right of retention or obligation under laws.

All deadlines start at the end of the month in which the processing of the request is completed and / or you completely unsubscribe from newsletters.

Incidentally, the duration of the storage of personal data is based on statutory retention rights and obligations (for example from commercial or tax law). After the deadline, the data will be deleted, unless they are necessary for the initiation, execution and termination of a contract and / or there is no legitimate interest on our part in the processing.

10. Usage of Cookies

We use cookies that are strictly necessary for the operation of the website and also those that provide anonymous information about how this website is used.

Cookies are small files that are downloaded to your device when you visit these websites. Cookies are useful because they allow us to recognize your device.

You can limit the use of cookies in the settings of your Internet browser at any time or stop altogether. Please refer to the operating instructions of your Internet browser, which can be easily found on the Internet.

Cookies can not run programs or transmit viruses to your computer. They serve to make the Internet offer more user-friendly and effective overall. This website uses the following types of cookies, the scope and operation of which are explained below:

• Transient cookies (a.)
• Persistent cookies (see b.).

a. Transient cookies:

Transient cookies are automatically deleted when you close the browser. These include in particular the session cookies. These store a so-called session-ID, with which various requests from your browser can be assigned to the common session. This will allow your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

b. Persistent cookies:

Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

c. Preventing cookies via the browser settings:

You can configure your browser setting according to your wishes, for exmple you can decline the acceptance of third-party cookies or all cookies. Please be aware that you may not be able to use all features of this site.

d. Cookies used:

We use the following cookies on our website:

Name of the Cookie

Description

Retention Period

More Information under Number

cookie_notice_accepted

This cookie stores your consent to cookies on our website

1 Month

_ga

This Google Analytics cookie distinguishes individual users by assigning them a random number as a customer identification number. It is included in every page request on a website and is used to calculate data about users, sessions, and campaigns for the purpose of analysis reports on the websites.

2 Years

14.

_gid

This Google Analytics cookie distinguishes individual users by randomly assigning them a number. It is included in every page request on a website and is used to calculate data about users, sessions, and campaigns for the purpose of analysis reports on the websites.

1 Day

14.

_gat

This cookie is related to Google Analytics and is used to reduce request rates, as shown in the documentation. It limits the collection of data on high traffic sites.

1 Minute

14.

_cfduid

This cookie is used by the content network Cloudflare to identify trusted web traffic.

1 Year

15.

11. Receivers and Categories of Receivers:

As a rule, personal data that you provide to us about yourself will only be processed by us. However, to perform our duties and responsibilities, we may need to disclose personal information stored about you to natural and legal persons, public authorities, institutions or other entities. In particular, the following categories of recipients are considered:

• Courts (for example in litigation)
• Non-public authorities if they are processors
• Lawyers, tax consultants, notaries, accountants

12. Deal rooms – Firmex Cloud Service:

Via our website, you can directly access the virtual data rooms of the external company Firmex in order to be able to provide your business partners with important and confidential documents securely online.

We do not process any data from you, so our privacy policy does not apply to the service of Firmex.

The data processing and the obligations under the GDPR are the sole responsibility of Firmex.

Please do not use the service of the company Firmex if you disagree with the data processing by the company Firmex.

We offer the possibility to register directly on our web pages on the cloud-based virtual data rooms of the company Firmex International, Ltd., 110 Spadina Avenue, Suite 700, Toronto, Canada (“Firmex” for short) to make confidential documents and other intellectual creations securely available online for your business partners or for other purposes.

We do not process any data and do not forward any data to Firmex. Insofar as you register with Firmex and use the Service, the Firmex Privacy Policy is the Responsible Body that you find here:

Customer Data Protection

Firmex claims to collect, inter alia, statistical access data when using the Dataroom. The access data include: name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, user’s operating system, referrer URL (previously visited page), IP address and the requesting one provider. Firmex uses the log data for statistical analysis for the purpose of operation, security and optimization of the offer, as well as for marketing purposes. In addition, Firmex processes the name, e-mail address and location of your office for authentication and communication purposes.

Please use the Data Room only if you agree with the Firmex privacy policy and wish to use the service voluntarily and with your express consent.

13. Newsletter:

You will receive a newsletter upon explicit request and your consent by entering your e-mail address in our newsletter form.

To verify the authenticity of your newsletter application, you will receive an e-mail confirming your application. Only in response to this we will process your data for sending a newsletter.

You may revoke your consent to receive newsletters at any time by clicking on a link in the newsletter or by sending an e-mail to info@capitalmind.com.

With your consent, you can subscribe to our newsletter, which informs you about our current interesting offers.

To register for our newsletter, we use the so-called double opt-in procedure. This means that after you have registered, we will send you an e-mail to the e-mail address specified in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be blocked and automatically deleted in accordance with § 9. The purpose of the procedure is to prove your registration and, if necessary, to inform you about possible misuse of your personal data. We use the services of MailChimp for the processing and storage of newsletter registrations.

For the transfer of personal data to the US, MailChimp has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US- Framework. Legal basis for the use of MailChimp is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR.

Third Party Information about MailChimp: The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, United States
Terms of Use: http://mailchimp.com/legal/terms
Privacy Policy: http://mailchimp.com/legal/privacy

The only requirement for sending the newsletter is your e-mail address. After your confirmation, we will save your e-mail address for the purpose of sending you the newsletter. The legal basis is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR.

You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the cancellation by clicking on the link provided in each newsletter e-mail, by e-mail to info@capitalmind.com or by sending a message to the contact details stated in the imprint.

14. Usage of Google Analytics:

With your permission, we use the web analytics service provided by Google Analytics, which uses cookies to anonymously analyze and provide us with your browsing habits on our web pages so that we can keep our website and service up to date.

You can revoke your consent at any time and prevent the analysis by Google Analytics for our and for all third party websites by downloading and installing a browser application. You can find the browser application under the following link:

http://tools.google.com/dlpage/gaoptout

However, please note that if you do this, you may not be able to use all the features of this website and other websites to the fullest extent possible.

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google” for short). Google Analytics uses so-called “cookies” (see above under § 10 lit. d), text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, in the event of activation of IP anonymisation on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website usage and internet usage to the website operator.

The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.

This website uses Google Analytics with the extension “_anonymizeIp ()”. As a result, IP addresses are processed shortened, a person-relatedness can be excluded. Insofar as the data collected about you is assigned a personal reference, it will be immediately excluded and the personal data will be deleted immediately.

We use Google Analytics to analyze and regularly improve the use of our website. With the statistics we can improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal information is transferred to the US, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US Framework. The legal basis for the use of Google Analytics is your consent, Art. 6 para. 1 sentence 1 lit. a GDPR.

Third Party Information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
Terms of Use: http://www.google.com/analytics/terms/en.html,
Privacy Policy: http://www.google.com/intl/en/analytics/learn/privacy.html,
and the privacy policy: http://www.google.com/intl/en/policies/privacy.

15. SSL-Encryption with Cloudflare:

This site uses SSL encryption for security reasons and to protect the transmission of sensitive content, such as the requests you send to us as the site operator. You can recognize an encrypted connection by changing the address line of the browser from “http: //” to “https: //” and the lock symbol in your browser line. If SSL encryption is enabled, the data you submit to us can not be read by third parties.

To provide you with secure data transmission using SSL encryption on our website, we use the service of Cloudflare, Inc. 101 Townsend St San Francisco, CA 94107 (“Cloudflare” for short) which uses a “cookie” (see above) under § 10 lit. d).

We have concluded a corresponding data processing agreement with Cloudflare on the basis of the GDPR. Cloudflare is a certified participant in the EU-US Privacy Shield Framework. Cloudflare has undertaken to handle all personal data held by Member States of the European Union (EU) in accordance with the Privacy Shield Framework in accordance with its applicable principles. For more information about the Privacy Shield Framework, see the US Department of Commerce Privacy Shield List at https://www.privacyshield.gov. Cloudflare collects statistical information about your visit to this website. The access data include: name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, user’s operating system, referrer URL (previously visited page), IP address and the requesting one provider. Cloudflare uses the log data for statistical analysis for the purpose of operation, security and optimization of the offer.
Legal basis is our mutual legitimate interest according Art. 6 para. 1 p. 1 lit. f GDPR, as Cloudflare is used for security purposes and to protect the transmission of all personal and confidential data.

Please read also the privacy policy of Cloudflare which can be found here https://www.cloudflare.com/privacypolicy/.

16. Data Protection Officer:

According to the requirements of Art. 37 GDPR, we are currently not obliged to designate a data protection officer.

17. Change of this Information:

Changes in legislation or laws may require an adjustment to this information. We kindly ask you to take note of this information every time you visit our website.

18. Contact:

If you have questions about data processing or asserting your rights mentioned above, please contact:

Capitalmind B.V.
Reitscheweg 49
5258 BX ‘s-Hertogenbosch
Netherlands

As of May 2018