General data protection policy

1. General

The website https://www.sparkingcapital.com/ is (indirectly) the property of Sparking Capital Fund Management B.V. (the “Manager”). The Manager complies with the current legal regulations regarding the protection of personal data. This policy contains information about the purposes that the Manager pursues when processing your personal data, about the use of cookies and about how you can exercise your rights with regard to your personal data.

1. Data processing
   1. Purpose of processing
      1. Personal data is the information related to a (natural) person and which can be used to identify that person such as name, email address, telephone number, social media usernames, identification number, location data or business titles.
      2. In order to process your intent to becoming an investor in a fund or entity managed by the Manager and to provide you with the best possible service on the Manager’s website, it is required that the Manager records personal data in certain situations.
      3. The Manager collects and processes personal data when you express your intent to become an investor in a fund or entity managed by the Manager necessary for admission to becoming an investor and to execute agreements in connection thereto. In addition, the Manager collects and processes personal data from visitors to the website for its business operations and for advertising purposes. The Manager will never resell, rent or otherwise provide data to third parties for the personal information you provide, unless this is necessary to execute a relevant agreement, to provide a certain service or when the Manager is legally obliged to do so.
   2. Collection of personal data

The Manager collects personal data directly for the purposes indicated above. The Manager also collects and processes personal data from publicly accessible sources such as internet, social networks, World-Check or commercial registers. Furthermore, the Manager may receive personal data from third parties as part of your request to become an investor in a fund or entity managed by the Manager (including but not limited to organizations in which you have a shareholding) or in connection with legal requirements that are applicable to the Manager.

1. Retention period for personal data

The Manager does not store personal data that it processes for longer than is necessary for the purpose of the data processing or is required by the Archives Act.

1. Sharing of personal data
   1. Your personal data may also be shared and disclosed with the recipients listed below:

1. to our affiliated companies insofar as reasonably necessary for the purposes indicated above or for bona fide compliance purposes, as well as on the legal basis as set out in this policy;
2. to service providers such as fund management services providers, intermediaries or external advisors who perform services on our behalf, including without limitation administration and fund management activities (such as know your client and any-money laundering), investment services, communications, market research, payment, emailing and computer services, and legal services;
3. we will share your personal data with KRIF B.V. and if relevant to its direct or indirect subsidiaries (hereinafter “KRIF”) which provides specific fund administration services to the Manager. KRIF will process your personal data in accordance with KRIF’s data protection policy, available here: https://krif.nl/privacy-policy/.
4. we may further disclose your personal data to any third parties based on your consent to do so.
5. We may also provide personal data to third parties in the following situations:
6. to public authorities, auditors, or institutions competent to exercise inspections on the Manager, which may ask us to provide information, based on their legal obligations or to whom we are obliged to provide this information as part of our legal and regulatory obligations;

1. to comply with legal process and to prevent fraud;
2. to enforce this policy, or other contracts with you, including investigation of potential violations thereof;
3. to comply with a legal requirement or to protect the rights and assets of the Manager or other entities or people;
4. to third party acquirers, if the Manager’s business would be subject to a change of control or other similar procedure or acquisition and your personal data would be part of the transaction.
5. Google analytics

1. For advertising purposes the Manager uses Google Analytics to track how our website is used and how effective our Adwords ads are on Google search result pages. The information obtained through this, including your IP address, is transferred to and stored by Google on servers in the United States. Please read Google’s privacy policy for more information and also the specific privacy policy of Google Analytics.
2. Google uses this information to keep track of how our website is used, to provide us with reports about the website and to provide its advertisers with information about the effectiveness of their campaigns. Google may provide this information to third parties if Google is legally obliged to do so, or insofar as these third parties process the information on behalf of Google. The Manager has no influence on this. The Manager has not allowed Google to use the obtained analytics information for other Google services.
3. Data security
   1. The Manager uses careful security procedures for the protection of the processed data, among other things to prevent unauthorized persons from inadvertently gaining access to this data. The Manager protects your data by all possible means, but due to the public nature of the internet, the Manager cannot always guarantee the security of the transmission of information over the internet 100%.
   2. Your data may be transferred abroad, inside and outside the European Economic Area (EEA), when we use processors (e.g. fund management/administration services providers, such as KRIF, or mailing services providers) for purposes such as those of servicing, support, back-up or any other legitimate interest.
4. Cookies
   1. The Manager uses cookies on its website. Cookies are small files that are placed on a computer by a web page server. Cookies are unique per user and can only be read by a server in the domain that sent the cookie to your computer.
   2. The main purpose of cookies is to save you time and effort. Thanks to cookies, the chosen settings and preferences are remembered for future use. In addition, cookies are used to keep statistics. The information that a cookie stores is not linked to your name, address and/or e-mail address, so does not contain any personal information.
   3. You can choose whether or not to accept cookies. Most browsers automatically accept cookies, but you can usually change the settings of your browser so that cookies are not accepted if desired. If you choose not to accept cookies, you may not be able to make full use of interactive features of the website.
5. Third-party websites

Our website contains links to other websites. The Manager is not responsible for the privacy policies of websites that are not under the control of the Manager.

1. Changes to the policy

The Manger reserves the right to amend the policy. Any changes will be published on the website.

1. Inspection, questions and information

If you have any questions about how the Manager handles your personal data or you would like us to change or delete your personal data, you can contact us at: [email protected].