This Privacy Statement regulates the processing of your personal data as part of the use of our website (www.vectispe.be) and the services we
offer. These processing operations are always carried out by Vectis Partners CVBA (hereinafter referred to as: “Vectis Private Equity”) as processing manager, established at Stratem 11 bus 2 in 9880 Aalter, with company number BE0548714548.
Protecting the personal data of customers and visitors is very important to Vectis Private Equity. That is why we make every effort to guarantee this data protection and always act in accordance with the General Data Protection Regulation (GDPR) when processing your personal data.
More specifically, Vectis Private Equity will always treat personal data lawfully for well- defined purposes. Finally, Vectis Private Equity takes the technical and organisational measures to ensure that personal data is secure.
Vectis Private Equity is responsible for the processing of personal data as described in this Privacy Statement and handles it in a manner that complies with the applicable legal requirements.
This Privacy Statement was last updated on 31 July 2019. Vectis Private Equity reserves the right to amend this Privacy Statement if necessary. Changes will always be communicated if fundamental.
2. Personal details
According to current legislation, personal data shall mean 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We define the processing of personal data as an operation or set of operations which is performed upon personal data or set of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of data.
Examples of personal data are name, address or e-mail address, but this also includes your IP address.
2.1.What personal data do we process?
What personal data do we process? Vectis Private Equity will process your personal data in function of general business operations, the application of laws and regulations and the management of (potential) investment files and portfolio. It is also possible that we will process images of you in function of camera security.
We process the following categories:
- Identification data (e.g. name, address, tel, e- mail)
- National registry number / copy of identity card
- Financial details
- Profession and employment (e.g. CV of applicant)
- Context (derived from e-mail and your question in the contact form)
- Image recordings (in conjunction with camera surveillance)
2.2. Why do we process your personal data?
Vectis Private Equity processes your personal data for the following purposes:
2.2.1. Administration and accounting
Vectis Private Equity collects invoicing and administrative data in order to fulfil its administrative obligations, such as charging the services provided to the client or keeping our statutory accounts. Vectis Private Equity is legally obliged to retain these personal details or 7 years.
2.2.2. Recruitment and applications
In the context of supporting portfolio companies, we occasionally collect data from people who apply to us, spontaneously or otherwise. This can be done through the contact section at www.vectispe.be, LinkedIn messages, emails, or other clear actions where an applicant indicates an interest in applying.
If the person is hired from the company in our portfolio, they will include your details in their personnel files. If the person is not hired but
does have an interesting profile, this candidate will be kept on the site reserve for an agreed period of time if the candidate has given his or her consent.
2.2.3. Newsletter and social media
We believe it is important to have a good relationship and communication with our investors, our portfolio companies and our broader contact base. That is why we contact you to keep you informed of relevant news items.
For the processing of personal data under this activity, Vectis Private Equity will use its legitimate interest. You can also register proactively via the consent form on our website.
You can unsubscribe at any time by clicking on the “unsubscribe” link at the bottom of the e- mail. Your e-mail address will then automatically be removed from the system.
2.2.4. Application of AML-legislation
Vectis Private Equity must comply with legal requirements and must therefore also process certain personal data in accordance with Anti Money Laundering (AML) legislation. For example, when collecting new funds and when distributing proceeds to the investor / shareholder, one will be required, among other things, to provide a copy of the identity card (or expiry documentation), the sector in which the person is active, to query economic interests abroad. These personal data are processed in a secure manner, in accordance with the requirements of the AML legislation.
2.2.5. Examination of new investment files
An investigation takes place prior to each new investment, in which personal data can be processed in order to determine the financial health and to obtain an overall view of the company. These processing operations are (usually) protected by means of a non- disclosure agreement.
2.2.6. Management of the investment portfolio
We professionally manage the investment portfolio and will carry out general and financial monitoring of the ongoing participations in the portfolio. In terms of personal data, this is limited to what is strictly necessary.
2.2.7. Requests for information via the contact form
The personal information we collect through the contact form on our website is used to answer your questions appropriately and accurately. In order to process your requests for information fully, we retain your personal data for as long as it is relevant to this activity.
2.2.8. Camera security
Vectis Private Equity has installed security cameras at certain locations to protect the physical safety of visitors and employees. Vectis Private Equity collects this data on the basis of its legitimate interest in providing security for everyone. The images are stored for a maximum of 30 days.
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2.3. Do we pass on your personal data to third parties?
Vectis Private Equity will not pass on the personal data to other parties who may use these personal data for their own purposes. Vectis Private Equity may occasionally pass on your personal data if necessary for legal requirements (e.g. to financial institutions for KYC procedures). Vectis Private Equity also uses a number of processors, which means that these are parties who may only process your data for purposes we determine. Under no circumstances will they process your personal data for their own purposes. This mainly concerns ICT partners and companies that carry out due diligence tasks.
3. What rights do you have, and how do you exercise them?
You can exercise any of the rights below by contacting us by sending an e-mail to email@example.com.
3.1. The inspection of your personal data.
You have the right to access all personal data that we process about you. You may also receive a copy of this information, which we will send to you on paper or digitally.
3.2. Improving your personal data.
You have the right to ask us to amend your personal details if they are incorrect or incomplete. You may also ask us not to use your personal details temporarily until they are correct or complete.
3.3. Withdrawing your consent.
If consent applies (e.g. you signed up for our newsletter), you have the right to withdraw your consent again at any time.
3.4. The deletion of your personal data.
You have the right to ask for your personal data to be deleted if they are no longer necessary in the light of the purposes of this privacy statement or if you withdraw your consent to the processing.
Please note: We are not obliged to delete your personal data if we have to or may keep them due to a legal obligation.
3.5. Transferring your personal data.
You have the right to receive your personal data in a universally readable format such as a text file or other digital file.
Please note: We are not obliged to transfer your personal data if they serve to fulfill a legal obligation.
3.6. Objection to the processing of your personal data.
If you feel that we are not using your personal data correctly, you may object to such processing, such as processing in the context of newsletters, marketing, or other processing that is not necessary in the context of our professional relationship.
Please note: An objection to a provision of a contractual agreement is not legally possible.
3.7. Filing a complaint with the supervisory authority
If you are not satisfied with the way in which your personal data is handled, you can lodge a complaint with the competent data protection authority. This is the Data Protection Authority in Belgium. For more information, please visit www.dataprotectionauthority.be