Privacy Policy

We, Waterland Private Equity Investments B.V. and our affiliates (hereinafter jointly referred to as “Waterland”, “we” or “us”) take the protection of your personal data seriously and would like to inform you about data protection on our website.

I. Controller
We are responsible for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:

Waterland Private Equity Investments B.V.
Brediusweg 16
1401 AG Bussum
The Netherlands

For further information about our companies, please refer to the imprint information on our website https://www.waterlandpe.com/imprint/

II. Contact details of the data protection officer
Our data protection officer is available to answer any questions you may have and to act as your point of contact for data protection issues.

Contact details are:
Geert Wensink
confilegal@waterland.nu

III. Purposes of processing personal data and legal bases
When using the websites, the following categories of personal data may be processed by us:

1. Use of our Website
When you visit our website, a so-called log data record (also known as server log files) is stored temporarily and anonymized on our web server. This log data record consists of:

the page from which the page was requested (so-called referrer URL),
the name and URL of the requested page,
the date and time of the access,
the browser type, version and language,
the IP address of the accessing computer,
the amount of data transferred,
the operating system,
the message whether the access was successful (access status/Http status code), and
the GMT time zone difference.

The storage of the aforementioned access data is necessary for technical reasons in order to provide a functional website and to ensure system security. This also applies to the storage of your IP address, which is necessary and, under further conditions, can at least theoretically enable an assignment to yourself. In addition to the aforementioned purposes, we use server log files exclusively for the need-based design and optimization of our website for purely statistical purposes and without drawing any conclusions about your person. This data is not merged with other data sources, nor is it analyzed for marketing purposes.
We use your IP address only for the duration of your visit. Your IP address is stored on our web server for IT security purposes for a maximum of seven (7) days. Further storage of the data for logging purposes takes place exclusively in anonymized form by shortening the IP address so that it can no longer be assigned.

The processing is carried out on the legal basis of Art. 6 para. 1 lit. f) GDPR due to our legitimate interest. Our legitimate interest is to be able to display our website to you reliably and with as little disruption as possible.

2. Newsletter

a) General Information
If you are interested in our private equity business and in particular our portfolio companies, we offer you two different newsletters. With our newsletters we inform you either about all our press releases (All Press Releases) or only about press releases related to our portfolio companies (Press Releases related to our Portfolio Companies). To subscribe to our e-mail newsletter, in addition to your consent, we only need your e-mail address to which the newsletter is to be sent and your choice which of the two newsletters you would like to receive

If you register for our newsletter, the following personal data may be processed by us:

your e-mail address

Moreover, we process all information you wish to provide us with voluntarily, e.g.:

your full name and the name of your company
Function in the company.

b) Legal Basis
In order to use your data for sending the newsletter, we require your consent, which we ask for separately when you register for our newsletter.

If you would like to read the content again, you can do so below:

Registration notice for “Press Releases”

“Yes, I would like to receive the press announcements, which will be sent to me on a regular basis to the e-mail address I have provided. I agree that my e-mail address and the other information I have voluntarily provided, in particular my name, may be processed for this purpose.

I can revoke this consent at any time for the future by clicking on the unsubscribe link at the end of each newsletter and thus cancelling my subscription. Alternatively, I can also revoke my consent, for example by sending an e-mail to the contact details provided in the data protection information.

I am aware that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.”

Registration information for “Press Releases on the Portfolio Companies”

“Yes, I would like to receive the press announcements about the Portfolio Companies, which will be sent to me on a regular basis to the e-mail address I have provided. I agree that my e-mail address and the other information I have voluntarily provided, in particular my name, may be processed for this purpose.

I am aware that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.”

The aforementioned data processing is carried out on the legal basis of Art. 6 (1) lit. a), Art. 7 GDPR, i.e. your consent to receive the newsletter.

We store your consent for up to three years for verification, documentation and legal defense purposes, starting from the end of the calendar year in which you received the last newsletter or revoked your consent. The legal basis for this is Art. 6 (1) lit. f) GDPR in conjunction with Art. 7 (1), Art. 5 (2) GDPR due to our legitimate interest. Our legitimate interest is the proper documentation as well as the defense against or assertion of legal claims. The individual newsletter e-mails are only temporarily stored for the purpose of sending but are not stored beyond this.

c) Confirmation of registration and verification of your e-mail address
For security reasons, we use a procedure known as double-opt-in for newsletter registration: After registering for our newsletter, you will receive an activation e-mail at the e-mail address you provided. You will receive the requested e-mail newsletter only after you confirmed your registration by clicking on the link contained therein. This is to ensure that only you, as the owner of the e-mail address provided, can register for the newsletter.

If you do not confirm your registration within 48 hours of receiving the activation email, your newsletter registration will automatically be deleted for security reasons and you will need to register again, which is possible and welcome at any time.

The legal basis for processing in the context of verification is – if you gave your consent – your consent (Art. 6 (1) lit. a), Art. 7 GDPR), otherwise the deletion of the newsletter registration is based on our legitimate interest in accordance with Art. 6 (1) lit. f) GDPR. Our interest follows from the principle of legality, as only by sending the first email for verification purposes we can ensure that the newsletter registration was correct.

d) Newsletter cancellation/revocation of consent
If you no longer wish to receive e-mail newsletters from us, you can unsubscribe from our newsletter at any time by either clicking on the unsubscribe link at the end of each newsletter e-mail or by sending an informal e-mail to the e-mail address given above to revoke your consent.
However, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

3. Investor Portal
We typically communicate with our investors via the Investor Portal and to access the necessary information and documents concerning your investment.

For this purpose, we offer our investors a link to a portal on our website. All you need to register with the portal is an e-mail address and a secure password of your choice.

The portal is hosted by eFront Cloud, which is a BlackRock Inc. brand. A corresponding data processing agreement has been concluded with this service provider.

The legal basis for the provision of the Investor Portal is Art. 6 (1) lit. b) GDPR, as it serves the communication and exchange of documents within the framework of the contractual relationship. If you are an investor, you can access the quarterly reports, investment reports and other information about your investment on the Investor Portal and communicate with us.

We store your data until you no longer wish to use the Investor Portal. After that, we store your data for one more year on the basis of post-contractual, commercial and tax obligations in accordance with Art. 6 (1) lit. b) and lit. c) GDPR (see section III. 7. above for additional retention obligations under commercial and tax law). Further storage is also necessary due to the requirement of lawfulness and proper documentation, as this is the only way we can respond to any inquiries or queries and defend ourselves against or assert legal claims.

4. Whistleblower Protection System “Speak Up”
Anyone who, in connection with their professional activities with us or in anticipation of professional activities, obtained information about violations that are subject to criminal or administrative fines may contact us confidentially and anonymously via our internal whistleblower protection system ‘Speak Up!’ on our website.

The portal is hosted by WhistleSystem ApS. A corresponding data processing agreement has been concluded with this service provider.

You do not have to provide any personal data about yourself to report a violation, as we provide anonymous reporting. It is sufficient to send a description of the incident. If desired or necessary, you may also send attachments. Should you disclose your identity in your description of the incident because this is essential for the description of the incident or because you voluntarily give up your anonymity, we will of course treat this confidentially.

The legal basis for the provision of the ‘Speak Up!’ whistleblower protection system and the processing of the reported violations is Art. 6 (1) lit. c GDPR, as it is necessary for the fulfilment of a legal obligation in accordance with local law implementing the EU Whistleblowing Directive 2019/1937 (such as Section 12 German Whistleblower Protection Act).

5. Application
You may apply for a job by sending us your application documents via e-mail as indicated in the job posting. If you apply via e-mail, we will send you the data protection information by e-mail.

6. Further Processing Purposes
Notwithstanding the above list, further data processing may also be possible for the following purposes:

Compliance with legal requirements: We also process your personal data in order to fulfil other legal obligations that may apply to us in connection with our business activities. These include, in particular, retention periods under commercial, trade or tax law. We process your personal data in accordance with Art. 6 (1) lit. c) GDPR for the fulfilment of a legal obligation to which we are subjected to.
Law enforcement: We also process your personal data in order to assert our rights and to enforce our legal claims. We also process your personal data in order to be able to defend ourselves against legal claims. Finally, we process your personal data to the extent necessary for the defense against or prosecution of criminal offences. In this context, we process your personal data to protect our legitimate interests in accordance with Art. 6 (1) lit. f) GDPR. Our legitimate interest arises from the fact that we assert legal claims or defend ourselves in legal disputes or want to prevent or solve criminal offences.
Consent: If you have given us consent to process personal data for specific purposes, the lawfulness of this processing is given on the basis of your consent. Consent that has been given can be withdrawn at any time. Please note that the withdrawal is only effective for the future and processing up to that point is not affected.

IV. Duration of data processing
Your personal data will only be stored for as long as it is needed for the respective processing purpose. This may also include the periods of time required for the initiation of a contract (pre-contractual legal relationship) and the execution of a contract. As soon as this point in time is reached and there are no legal storage obligations (e.g. in connection with tax, commercial or tax-related processes, for Germany see also for example Sections 238, 257 German Commercial Code and Section 147 Fiscal Code), or if measures continue to have an effect beyond such periods (e.g. tax or company audits), you have not given us permission for further storage or have revoked it and we also do not need it for the assertion, exercise or defense of legal claims, the data will be deleted. When the statutory retention period expires, the personal data will be blocked or deleted, unless further storage by us is required and there is a legal basis for this.

Your data is generally only stored on our servers in the EU subject to any disclosure that may be necessary in accordance with the information described in this privacy policy.

Processors engaged by us will only store your data on their system for as long as is necessary in connection with the provision of services for us in accordance with the respective assignment.

V. Transfer of personal data to third parties; basis for justification
Internally, access to your data is granted to those departments that need it to fulfil our contractual and legal obligations. In addition to the IT department, these are only such persons and departments required for the respective (and desired) processing of the data. Service providers and agents engaged by us may also receive data for these purposes. Your data will be passed on to technical service providers supporting us (including for website hosting, website support and quality assurance) for the purpose of providing this website and for the aforementioned purposes. We limit the disclosure of your personal data to the extent necessary, taking into account data protection requirements. In some cases, recipients receive your personal data as processors, Art. 28 GDPR, and are then strictly bound by our instructions when handling your personal data and are regularly monitored by us. In some cases, the recipients act independently under their own data protection responsibility and are also obliged to comply with the requirements of the GDPR and other data protection regulations. The legal basis for the transfer is then Art. 6 (1) lit. b) or lit. f) GDPR.

Moreover, your data will only be passed on to other third parties if this is expressly stated in this privacy policy or if there are other reasons for doing so. For example, we may transfer personal data to our legal or tax advisors in individual cases, whereby these recipients are obliged to maintain special confidentiality and secrecy due to their professional legal position. The legal basis for the transfer is then Art. 6 (1) lit. b) or lit. f) GDPR. If we are legally obliged to transfer your personal data, the legal basis is then Art. 6 (1) lit. c) GDPR.

In addition, we will only transfer your personal data to third parties in certain cases if you have given your express consent to do so in accordance with Art. 6 (1) lit. a) GDPR.

VI. Use of cookies, plugins and other services on our website

1. Cookie Policy
For information on how and which cookies we use and how you can manage your cookie settings and disable certain types of tracking, please see our cookie policy here. https://www.waterlandpe.com/cookie-policy/

2. Social Media Plugins
We do not use any social media plugins on our websites. If our websites contain symbols of social media providers (e.g. a LinkedIn symbol), we only use these to passively link to our company/profile page on LinkedIn.

VII. Data Transfer to Third Countries
Generally, your personal data will not be transferred to a third country. Exceptions may arise in the case of cookies. You can find more information on this in our cookie policy. https://www.waterlandpe.com/cookie-policy/

VIII. No automated Decision-Making (including profiling)
Automated decision-making (including profiling) is not applied.

IX. No Obligation to Provide Personal Data
In principle, you are free to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data.

X. Data Security
We use appropriate technical and organizational measures to protect personal data in order to ensure an adequate level of protection and to safeguard the personal rights of the persons concerned. The measures taken serve, among other things, to prevent unauthorized access to the technical facilities we use and to protect personal data from unauthorized access by third parties. In particular, this website uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as your contact requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from ‘http://’ to ‘https://’ and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties. However, we would like to point out that data transmission over the internet (e.g. when communicating by e-mail) may still have security gaps. It is therefore not possible to provide seamless protection of data against access by third parties.

XI. Your rights

1. General
You can assert your rights as a data subject with regard to your processed personal data against us at any time using the contact details provided at the beginning. As a data subject, you have the right, provided that the legal requirements are met,

to revoke the consent you have given us at any time in accordance with Art. 7 (3) GDPR. As a result, we are no longer allowed to continue the data processing based on this consent in the future;
in accordance with Art. 15 GDPR to request information about your personal data processed by us;
in accordance with Art. 16 GDPR to request the immediate correction of incorrect personal data stored by us or the completion of your personal data;
in accordance with Art. 17 GDPR to request the erasure of your personal data stored by us, unless processing is necessary for reasons arising from the law;
in accordance with Art. 18 GDPR to request the restriction of the processing of your personal data, insofar as the legal requirements are met;
in accordance with Art. 20 GDPR, to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller and
in accordance with Art. 77 GDPR to file a complaint with a supervisory authority. Generally, you can contact the supervisory authority at your regular place of residence for this purpose. In the case of Waterland Private Equity Investments B.V., the responsible data protection supervisory authority is the Autoriteit Persoonsgegevens.

2. Right of Objection
If your personal data is processed on the basis of legitimate interests in accordance with Article 6 (1) lit. f) GDPR, you have the right to object to the processing of your personal data in accordance with Article 21 GDPR if there are reasons for doing so that arise from your particular situation. If you wish to exercise your right to object, simply send an email to confilegal@waterland.nu.

XII. Changes to the Data Protection Information
As part of the further development of data protection law and technological or organizational changes, our privacy policy is regularly reviewed for the need for adaptation or supplementation. You will be informed of any changes on our website.