Privacy policy

Privacy
Hodl Management ltd respects your privacy and processes personal data in accordance with the European General Data Protection Regulation (GDPR). In this Privacy and Cookie Policy (hereafter ‘Policy’) we address the usage of cookies and how we handle and protect your personal data.
More precise, this Policy addresses:

  • What personal data we collect and how;
  • For what purposes and on what grounds we process your personal data;
  • For how long we keep your personal data;
  • With whom we share your personal data;
  • The rights you have as data subject; and,
  • How your personal data is protected.

This Policy applies to all persons who visit our websites and of whom Hodl Management ltd processes personal data, such as clients, prospects, persons who have subscribed to newsletters or events, and persons who have applied for a job at Hodl Management ltd.

What are personal data?
Personal data is any information relating to an identified or identifiable natural person. Personal data that we process may include:

  • Basic information, such as your first and last name, prefix, title;
  • Contact details, such as your e-mail address, postal address and phone number;
  • Personal data you provide us for the purpose of becoming our client, such as your nationality, date of birth, country of birth, residence address, TIN-number, bank account number;
  • Personal data you provide us for the purpose of attending events or meetings, such as access and
    dietary requirements;
  • Personal data you may provide us for the purpose of a job application, such as your full name, date of birth, address, phone number, nationality, marital status and any other personal data set out in your application;
  • Any other personal data relating to you which you may provide us or that we may obtain in
    relation to the purposes and based on grounds set out below;

We collect this personal data because you provided this data to us. For example, you may provide data when entering into an agreement with us, by entering your data on our website (www.hodlgroup.com), by giving us your business card or by applying for a job. We may also collect your personal data from other sources, such as from local counsel, counterparties, the Trade Register, the Land Registry or by using publicly available sources. If you are a mere visitor of our website, we will not collect any personal data.

Purposes and legal basis for the processing of personal data

Hodl Management ltd may process your personal data for the following purposes:

  • To identify and accept you as a client;
  • To provide our services;
  • To comply with our legal and regulatory obligations;
  • For marketing and business development activities, such as news updates, invitations for our events and other marketing communications that may be of interest to you;
  • To handle your job application or subscription to any of our recruitment services and events.

We will process your personal data using one or more of the following legal grounds:

  • Performance of a contract;
  • Compliance with a legal obligation;
  • Legitimate interest;
  • Your consent.

Sharing of personal data
In some cases we may also share your personal data with third pares. This may include, but is not limited to:

  • Third pares relevant to the investment services that we provide, such as the fund administrator, regulatory authorities and governmental institutions.
  • Third pares that we engage with, such as supervisory authorities and other bodies, in order to comply with legal obligations.
  • Third party suppliers in connection with the processing of your personal data for the purposes described in this Policy, such as IT providers, communication service providers or other suppliers to whom we outsource certain support services.

We will only share your personal data with these third pares for the purposes and on the legal grounds stated in this Policy.

Third pares to whom we transfer your personal data are themselves responsible for compliance with privacy legislation. Hodl Management ltd is neither responsible nor liable for the processing of your personal data by these third pares. To the extent that a third party processes your personal data as a data processor of Hodl Management ltd, Hodl Management ltd will conclude a processor agreement with such party that meets the requirements set out in the GDPR.

To be able to provide our services, it may be necessary for us to transfer your personal data to a recipient in a country outside of the European Economic Area. In that case, Hodl Management ltd will ensure that the data transfer is compliant with the applicable law.

How long do we keep your data?
Your personal data is kept in accordance with the GDPR.

Your personal data is processed up until the moment that you inform Hodl Management ltd that you no longer wish to receive any digital noces and/or Hodl Management ltd stops sending you newsletters, white papers, invitations to events or other digital mailings.

Your personal data will be erased if:

  • It appears that your email address is no longer in use (for example when error messages are received);
  • The consent based on which your personal data is processed and/or stored is withdrawn by you;
  • The aforementioned legal grounds on which your personal data is processed, expires because for example if your company ceases to exist, or you have had any contact with Hodl Management ltd for a period of 5 years (notwithstanding possible legal obligations).

Contact
If you have any questions or comments about our Policy or the processing of your personal data, please send a request in that regard to Hodl Management ltd, 5-9 Main Street, GX11 AA Gibraltar,  or per email to [email protected]

If you want to know more about this subject or have a complaint about the abuse of your personal data, please contact the Dutch Data Protection Authority (DAP).

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