Fintage House BV (hereafter “FH”), Fintage Collection Account Management BV, Fintage AVPR BV and Lasso Rights Limited (hereafter “Fintage Group”,) are all privately owned, independent companies – Fintage Group and FH are collectively referred to as “Fintage”, “we”, “us” and “our”. Each of the above mentioned relevant entity of the Fintage Group in general, and for staff, job applicants and generic business contacts and events only FH, will be the data controller as prescribed in the entity’s local law (the “Data Controller”)

In the context of our activities, we collect, hold, disclose and/or otherwise process personal data.

We value the right to privacy and strive to protect the personal data we collect and us in accordance with the applicable data protection legislation and more specifically with the General Data Protection Regulation (GDPR) and its relevant national implementing legislation. In this privacy policy (the “Policy”) we will elaborate on whose personal data we collect, what personal data we collect, how we collect personal data, for what purposes we use personal data and to whom personal data is disclosed by us.

Further, this Policy includes important information regarding your rights with respect to the processing of your personal data.

This Policy applies to both personal information supplied to us either by an individual or by others.  We may use personal information supplied to us for any of the purposes as set out in this Policy, or as otherwise disclosed at the point of collection.

This Policy is an important document. We encourage you to read it very carefully.

In this Policy, we use the terms:

“Personal Information” is any information relating to an identified or identifiable natural person;

“identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors; and

“you” and “your” (and other similar terms) refer to our clients, individuals associated with our clients, contacts, suppliers, job applicants, staff and visitors to Fintage’s website, fintagehouse.com.

Your rights in relation to Personal Information and how to exercise them

 Under certain circumstances you have the following rights:

• the right to ask us to provide you, or a third party, with copies of the Personal Information we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;

• the right to request erasure, anonymisation or blocking of your Personal Information that is processed in breach of the law;

• the right to object on legitimate grounds to the processing of your Personal Information. In certain circumstances we may not be able to stop using your Personal Information, if that is the case, we’ll let you know why; and

• withdrawal of consent – when Personal Information is processed on the basis of consent an individual may withdraw consent at any time (this may apply to processing of special categories of Personal Information where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership). In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you), or contact the relevant Data Controller as set out below.

To exercise such rights (bar withdrawing from marketing emails – as described above) and if you have any questions about how we collect, store and use Personal Information, then please contact us using the details as set out in the “Data Controller contact information” section below.

What basis do we have for processing your Personal Information?

We will only process personal Information where we have a lawful reason for doing so.  The lawful basis for processing Personal Information by us will be one of the following:

• the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
• the processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering legislation);
• the processing is necessary for the pursuit of our legitimate business interests (including that of the delivery and the promotion of our services); and
• the data subject has given consent to the processing of his or her personal information for one or more specific purposes*

*This applies to marketing communications in the Netherlands and Germany.

What Personal Information do we collect and process?

We aim to be transparent about why and how we process Personal Information.  For further information on our processing activities please review the relevant section below:

Business contacts

Collection

We process Personal Information about contacts using client relationship management tools, our online portals through which the financial status of your projects are made available, Windows Outlook and our hard drive (collectively “Data Collection Systems”). Personal Information is collected and added to the Data Collection Systems by Fintage staff, and includes: name, email address, job title, telephone number, area of business, jurisdiction, bank account details, personal tax numbers and other business contact information.  The Personal Information may also be collected by virtue of us providing our services to you or at a networking event.  In addition Personal Information may also be collected via Fintage’s website, fintagehouse.com.

Use

• For contact and communication purposes: we may use your contact information to send you news about any events we are organising or participating in, and/or other information about us and the services that we provides that we believe may be of interest to you.  You can specify your contact preferences by subsequently advising us of your contact preferences using options provided on all of our marketing emails or the contact details as set out in the “Data Controller contact information” section below.
• Making contact details available to Fintage Group staff.
• Performing analytics – such as trends, sales intelligence, marketing effectiveness (such as click and open rates) uptake and progress.
• Utilising artificial intelligence to research news feeds, sites, posts etcetera and performing analytics to assist us in contacting you with relevant information.

Retention

Personal Information is retained on Data Collection Systems for as long as it is necessary for the purposes set out above (being the length of the business relationship).  If a business contact requests to be forgotten their contact details will be deleted from our Data Collection Systems.  If a business contact opts out of receiving marketing materials their details will still be retained (as our lawyers may still be in contact) but marketing materials will no longer be sent.

Clients and individuals associated with clients

Collection

We request that our clients only provide Personal Information which is necessary for us to carry out our services.

If we need Personal Information in respect of individuals associated with clients in order to provide our services we ask our clients to provide this Policy to the data subjects.

In the majority of circumstances we will collect Personal Information from our clients or from third parties acting on behalf of our clients.

Use 

• Providing our services: we will use and disclose Personal Information in such a manner as we believe is reasonably necessary to provide our services, for example:

• we will use Personal Information in order to provide payment notifications:
• we will use Personal Information in order to administration overviews;
• we will use Personal Information in order to make payments.
• we may need to instruct other (third) parties on your behalf (including correspondence with you), to liaise with other professional service providers in relation to matters that we are handling, or because we need to liaise with another (third) party on a matter you have instructed us on.

• Managing client relationships: providing clients with information on our services and updates that we consider may be relevant to them; arranging and hosting events; and identifying where we may make improvements in service delivery.
• Client engagement: as part of our client on – boarding process we carry out certain background searches to verify whether or not there are any potential issues that may mean we cannot work with a particular person (to identify criminal convictions, politically exposed persons, sanctions or other potential reputation issues).
• Compliance with anti-money laundering regulation and prevention of terrorism: we may use your Personal Information (e.g. evidence of your identity) in order to fulfil our obligations to check the identity of our clients in compliance with anti-money laundering law and regulations and prevention of terrorism, this information may be shared with any outside Counsel.

Note: in this context you may provide us with Personal Data relating to another individual than yourself, for example of the ultimate beneficial owner of the company you are representing. If this is the case, please provide the concerned individual with (a copy of) this Policy and ensure that he/she has read and understood this Policy before providing us with his/her Personal Data.

• A third-party business partners whom we may engage to provide us with your personal information in order to enable us to conduct background checks and screening activities, comply with our legal obligations and for other purposes as described in this Policy. Such third-party is responsible for any personal information which they may collect and hold about you until it is received by us.

Retention

Our general retention period for documentation created for the purpose of providing our services is 7 years after the earlier of the expiry of term of our contract with you or the termination of our contract with you.  In some instances there are legal and regulatory exceptions which may require documentation to be held for longer or shorter periods.  If you require further information please contact us using the details as set out in the “Data Controller contact information” section below.

Job applicants

Please refer to information made available when applying online for further details as to how Personal Information is collected, processed and how long it is retained for.

Journalists

Collection

Personal Information, including name, email address, telephone number and other business contact information, may be collected from PR agencies or from databases that we subscribe to.

Use

• Press releases and joint press releases from our clients/organisations that we are working with.
• Invitations to meet Fintage’s staff.
• Fintage events/receptions.
• To highlight any spokespeople who may be of interest on a specific industry theme or topic relevant to the journalist.
• Business trips may require the use of the Personal Information to assist us with travel arrangements.
• Internal communications.

Retention

Personal Information will be retained for as long as it is necessary for the purposes of the above, or if you advise us you no longer wish to be contacted your Personal Information will be removed from our contact lists.

Suppliers (including individual contractors)

Collection

Personal Information, including name, email address, telephone number and other business contact information, is collected to receive services from suppliers, to manage the relationship with the supplier, and for the provision of services to our clients.

Use

• To receive services from our suppliers: please note that we will use and disclose their Personal Information in such manner as we believe is reasonably necessary to receive and to review the provision of those services from suppliers.
• Services to clients: if a supplier is assisting us in delivering services to our clients we will process Personal Information to manage that relationship.
• Administration: to agree payment arrangements with our suppliers, and to make payments to them.

Retention

A general retention period of 7 years will be applied unless there are any legal and or regulatory exceptions which may require documentation to be held for shorter or longer periods.  If you require further information please contact us using the details as set out in the “Data Controller contact information” section below.

Staff

Personal Information in relation to staff will be held on various internal systems and applications.  A privacy notice which sets out the purposes for which Personal Information will be processed and contains information on data subject rights is provided to staff at the commencement of employment and is available in the firm’s intranet.  If further information is required please contact your local Human Resources contact person.

Visitors to the Fintage website

Collection

 Personal Information will be collected if you sign up to attend any of our events.

Use

• Business contacts: if you have signed up to attend one of our events please see the paragraph above headed ‘Business contacts’.

Who else may have access to your Personal Information?

On occasion, we may need to share your Personal Information with third parties.  We will only share Personal Information where we are legally permitted to do so.

Where you supply the Fintage Group with Personal Information as a client, we will assume, unless you instruct us otherwise in writing, that we can disclose your Personal Information in such manner as we believe is reasonably necessary to provide our services (including as described in this Policy), or as is required under applicable law. This might be because, for example, we may pass your Personal Information to third parties such as:

• events: we may need to pass on your Personal Information (e.g. name, company, occupation) to a third party in connection with management of an event, in which case the details will only be used by the third party for that specific purpose;
• business partners, service providers and other affiliated third parties: to enable us to provide our services to you, we may need to share your Personal Information with our business partners (including other professional advisers such as accountants or auditors), external service providers and/or overseas counsel. Our arrangements with external service providers currently cover the provision of support services including IT, AML/CDD checks, events management, document production, business and legal research, secretarial services, marketing and business development;
• disclosures required by law or regulation: in certain circumstances, please note that we may be required to disclose Personal Information under applicable law or regulation, including to law enforcement agencies or in connection with proposed or actual legal proceedings.

International transfers of Personal Information (including to outsourced service providers)

How we look after your Personal Information

We have in place appropriate technical and organisational security measures to protect your Personal Information against unauthorised or unlawful use, and against accidental loss, damage or destruction.

Links to other websites

Fintage website, fintagehouse.com, may link to other, unaffiliated third party websites.  Please note that Fintage is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third party websites.  You must always carefully review the privacy and confidentiality policy of any third party website that you may visit in order to understand how the operators of that website may collect, store and use your Personal Information.

Data Controller contact information: privacy@fintagehouse.com