Privacy Policy

Trans Group Capital Management BV is the data controller responsible for your personal data. Our contact details are:

We have appointed a Data Protection Officer (DPO) who can be contacted at compliance@transgroupcm.nl regarding any matters related to the processing of your personal data.

We may collect and process the following categories of personal data:

Sensitive Personal Data: We may collect special categories of personal data (such as biometric data for authentication purposes) only where strictly necessary and with your explicit consent, or where required by law (e.g., anti-money laundering regulations).

We collect personal data through various methods:

We will only process your personal data when the law allows us to. The legal bases we rely upon include:

• ✓
  Performance of a Contract: Where processing is necessary for the performance of an investment management agreement or other contract to which you are a party.
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  Legal Obligation: Where we need to comply with a legal or regulatory obligation (e.g., anti-money laundering laws, tax regulations, AFM reporting requirements).
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  Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as fraud prevention, network security, or business development.
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  Consent: Where you have provided explicit consent for specific processing activities, such as marketing communications or processing of sensitive personal data.

We use your personal data for the following purposes:

We may share your personal data with the following categories of recipients:

• Service Providers: Third parties who provide services on our behalf, such as IT and system administration services, custodians, fund administrators, and legal advisors.
• Regulatory Authorities: The Dutch Authority for the Financial Markets (AFM), De Nederlandsche Bank (DNB), tax authorities, and other governmental or regulatory bodies as required by law.
• Professional Advisors: Lawyers, auditors, insurers, and bankers who provide consultancy, banking, legal, insurance, and accounting services.
• Portfolio Companies: Companies in which we invest, where necessary for due diligence or ongoing governance.
• Business Partners: Co-investors, syndicate partners, and introducers with whom we have a legitimate business relationship.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal data may be transferred to, and processed in, countries outside the European Economic Area (EEA). These countries may have data protection laws that are different to the laws of the Netherlands and the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe (Standard Contractual Clauses).
• Transferring to recipients who are certified under the EU-US Data Privacy Framework (where applicable).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have implemented appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

In general:

• Investor data is retained for the duration of the investment relationship plus 7 years (or longer if required by tax or financial regulations).
• Prospective investor data is retained for 2 years from the last interaction, unless you request deletion earlier.
• Website visitor data (cookies/analytics) is retained according to the specific cookie retention periods outlined in our Cookie Policy.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

If you wish to exercise any of these rights, please contact our Data Protection Officer at compliance@transgroupcm.nl. We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.

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We may update this Privacy Policy from time to time to reflect changes in legal requirements, our data practices, or our services. Any changes we make will be posted on this page and, where appropriate, notified to you by email.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. The date at the top of this page indicates when it was last updated.