Privacy Statement

This is the Privacy Statement of United Momentum Holding B.V. and the parties it actively manages or otherwise controls, which are located at the Cruquiusweg 111R in Amsterdam (referred to hereinafter as "Momentum Capital" or "we").

We are a Dutch organisation that processes personal data. Processing also means the use of personal data. We process personal data because you make use of our services or because you have consented to certain processing.

For Momentum Capital a responsible handling of personal data is of great importance, which means that we treat your data with care. We respect the privacy of all stakeholders who are in any way connected to our organization or who use our services.

Momentum Capital processes your personal data in accordance with current privacy laws. This means, for example, that your personal data is processed for the purposes as described in this privacy statement. Furthermore, we will only process your personal data if you have given us consent to do so.

This privacy statement explains which data Momentum Capital uses for which purposes and the measures we take to protect your personal data. Should you have any questions about your privacy, please contact our Data Protection Officer at privacy@momentumcapital.nl.

We will only process your personal data if there is a lawful basis for doing so. If there is no such lawful basis, we will not process your personal data. We only process your personal data on the basis of the following legal grounds:

1. With your explicit consent. If we need your permission, we will ask you for it, for example by filling out a permission form.
2. For the performance of one or more agreements. We need to know who we are contracting with. In addition, the processing of your personal data is necessary for the execution of appearing agreements.
3. To be able to comply with our legal obligations. If, for example, the Prevention of Money Laundering and Terrorist Financing Act ('Wwft') applies to us, we must carry out a customer due diligence and, in some cases, even an enhanced customer due diligence.
4. Because we have a legitimate interest in processing them. This is the case, for instance, if we perform a customer due diligence (or have one performed) in the context of fraud prevention, careful management, to streamline internal processes (assessing and accepting customers) and to prevent money laundering and terrorist financing, even if the Money Laundering and Terrorist Financing (Prevention) Act ('Wwft') does not apply. Other examples of a legitimate interest are the processing of personal data for commercial purposes such as direct marketing to existing customers (only for similar services), the transfer of personnel data within/between parts of the same organisation and the processing of personal data for network security purposes.

In addition to the previously described principles, we only process personal data if we have a justifiable purpose for doing so. We determine these purposes prior to processing and record them in our dataprocessing register. Momentum Capital collects your data for the following purposes:

1. In order to carry out our commercial activities.
2. To be able to send relevant and / or commercial information (electronically) about current events and developments within Momentum Capital.
3. In order to approach you for participation in our meetings and activities.

We only process data that is necessary for the execution of our business and commercial activities. This means that we never process data about religion, race or political affiliation.

If we carry out a customer due diligence, we will process at least the following personal data. It makes a difference whether you are a natural person or a legal entity.

In the overview below you will find which categories of personal data we will in any case process for each category of data subject.

We also establish the purpose and intended purpose of the business relationship and process information on the source of funds.

Proof of identity

If an identification document has expired, we may ask you to send us a new copy of a valid identification document. We may then ask you to hide your Citizen Service Number and passport photograph.

Enhanced customer due diligence

In certain cases, we have to perform an enhanced customer due diligence. In those cases we will request additional information from you, such as proof that you actually live at the address you provided, a statement from you or from another party (e.g. a civil-law notary or an accountant) concerning your transaction(s) or your assets.

Other personal data

We may also process the following personal data:

• Contact details, such as a (mobile) phone number and e-mail address
• Date of birth
• Gender, marital status and family composition
• Nationality
• Payment details, such as invoice address, bank account number and credit card details if applicable
• Work-related data, such as the name of your company, employer, position and income details
• Origin of the assets
• (Technical) Data on the use of our website
• Data to comply with our (legal) employer obligations

In some cases Momentum Capital also processes special personal data, such as health data. These will only be requested if there is a legitimate purpose for this or if we have obtained your permission.

The above personal data can be combined so that targeted content and personalised information can be sent to you.

We obtain personal data from our data subjects by asking for it. In addition, our data subjects always have the choice of whether or not to provide us with this data, with the possibility of contacting us if they no longer wish their personal data to be processed by us. We may not be able to offer, provide or make available certain services in full if we do not have your personal data.

There are also personal data that we obtain from public sources. Such as information about companies that are registered with the Chamber of Commerce, where personal data of contact persons of the companies concerned are publicly available. We approach these (legal) persons in order to carry out our business and commercial activities. Consent for the processing of personal data is requested at the first contact with such persons.

Momentum Capital always communicates transparently about the way personal data are obtained.

Your personal data is processed by us to enter into agreements, to carry out our business purposes, to promote our business interests including carrying out activities aimed at increasing our client base (commercial activities), to assess and accept the client relationship in the context of fraud prevention and to comply with applicable laws and regulations.

If you fill in a contact form on the website, or send us an e-mail, the data you send us will be kept as long as the nature of the form or the content of your e-mail requires for a complete response and handling. These data will never be used for further unsolicited approaches that are not in line with your indicated interest, question or request.

We use the personal data voluntarily provided by you to communicate with you and to inform you of matters relevant to our services.

There is no fixed storage period, or fixed criterion, that we can assign to the categories of personal data that are processed by Momentum Capital. This data is stored for as long as is necessary for the initial purpose of collection.

Personal data will be stored for as long as those involved make use of our services, but also for the period thereafter. This is done because we maintain close customer contact and our data subjects are in most cases connected to our organization as investors for a longer period of time.

As an exception to the above, we may need to store certain data for longer in order to comply with legal requirements. For example, in the case of payment data, the Dutch General Tax Act requires us to retain it for 7 years for the Dutch Tax Authority.

At any time you can request to see the personal data Momentum Capital has collected about you. You have the right to:

1. general access to your personal data that is known to us;
2. information about the processing of your personal data;
3. rectification of the personal data known to us;
4. erasure of the personal data (right to be forgotten);
5. restricting the processing of your personal data; and
6. if possible, to transfer your data to other parties (data portability).

We would also like to draw your attention to the fact that you have the right to lodge a complaint with the Dutch Data Protection Authority. Naturally, we will first look for a suitable solution with you, as we do our utmost to prevent you from being dissatisfied with our services and the way we handle your personal data.

For exceptions and explanations of the above rights, we refer you to the website of the Dutch Data Protection Authority.

If you wish to exercise the right to be forgotten, this may be in conflict with our services and other regulations (e.g. our legal obligations). We will nevertheless work with you to find a suitable solution so that you can exercise your right as best we can.

If you have previously given us consent for the processing of your personal data, but wish to withdraw this consent, this is also possible.

You can submit a request as mentioned above if Momentum Capital processes your personal data. The request should be made in writing by post or e-mail. If you wish to exercise one of your rights, please send your request to: privacy@momentumcapital.nl. 

Your data may be exchanged and combined within Momentum Capital.

In order to process personal data, we sometimes make use of third parties who have access to your data, such as banks and administrative offices that are relevant to our services, external service providers in connection with the processing of your personal data, such as ICT service providers, the accountant, or other parties to whom we outsource certain support services. Where possible, we require these parties to act in the capacity of data processors. This means that we determine the purpose and the means and that the data processor processes your data in accordance with our instructions and our security requirements. These agreements are recorded in data processing agreements.

It is possible that some processors are located outside the European Union, where other laws and regulations apply. In such cases, additional agreements are made and measures are taken to ensure that Momentum Capital can guarantee the same level of privacy protection to its data subjects at all times.

We make every effort to take appropriate technical and organizational measures to prevent the loss of personal data or unlawful processing. Momentum Capital works in the field of IT security and software with suppliers who have appropriate resources and management procedures to secure the personal data that we process in order to prevent unauthorized access or disclosure, to keep the data accurate and to guarantee its rightful use.

The website of Momentum Capital can use cookies for functional purposes, so that the website continues to function properly. It is important that the website continues to function correctly so that we can provide you with the best possible service. We currently use a tracking cookie for Google Analytics. We do this to improve the experience on our website. In addition, we use Leadfeeder, which shows data from companies that have visited our website. From 1 January 2013 it is mandatory to inform you and ask your permission beforehand if Momentum Capital can place certain cookies. Technically necessary cookies (functional cookies), which are necessary for the functioning of the website, Momentum Capital may place without permission.

Momentum Capital reserves the right to modify this privacy statement. The revision date will be updated in that case. You can find the most recent version on the homepage of Momentum Capital.

Published: March 2022

Momentum Capital values your privacy. In order to ensure that your interests are protected, a Data Protection Officer (DPO) has been appointed. In case of any questions, please contact:

Data Protection Officer
Phone number: 020 – 5600 800
Cruquiusweg 111 R
1019 AG Amsterdam
privacy@momentumcapital.nl