Privacy Notice

Rivean Capital B.V. is a limited liability company established under the laws of the Netherlands, AFM licensed and registered in the Dutch trade register at the Chamber of Commerce under number 30204922, hereinafter “Rivean Capital” or “we”.

This privacy notice is applicable to visitors to our website or people who notify under the General Data Protection Regulation.

Visitors to our website

We anonymously measure the use of our website with the help of non-essential cookies to find out the number of visitors to the various parts of the site and/or the quality of the site.

We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website, nor do we follow any surfing behaviour on (other) websites.

Cookies are simple text files that are stored on your computer or mobile device by websites that you visit. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. We only use so-called third-party cookies, namely the cookies of Google analytics, with the following name:

_ga
_gat
_gid

The purpose of these cookies is to record if a user has accepted the use of cookies on our website. To withdraw your consent, you can adjust your browser’s settings. Find out to delete cookies at http://www.aboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.

To protect the website from hacking, we use a plugin. This plugin will not leave a cookie but bans any IP that is attempting to discover passwords.

This privacy notice concerns only our website and does not concern any website to which our website may link. Visitors who choose to visit these third-party websites, are advised to review their privacy policies to understand the policy and practices that are related to these third-party websites.

General Data Protection Regulation

We comply with applicable laws and regulation, such as the National privacy legislation and the General Data Protection Regulation of the EU. Rivean Capital has a privacy policy.

Our business focuses on legal entities.

We only collect personal information for the following purposes of the following persons:

• Human Resources Management: details of individuals who apply to work at Rivean Capital. We will only use the information they supply to us to process their application. We only disclose information to third parties, for example to take up a reference, when we obtained consent of the relevant individual and we will not disclose any information or take up any reference without informing them and without consent, unless the disclosure is required by law;
• To execute employment agreements: details of employees as prescribed by law;
• Business relation management/CRM: details of legal representatives of legal entities with whom we are engaged in business, details of contact persons;
• To fulfil legal obligations: details of UBO’s and legal representatives, details of employees for tax obligations;
  For responding to queries and providing relevant information.

The legal ground for our processing activities is:

• Execution of agreements;
• Our legitimate interest to communicate with business relations, to provide fund management, and to be able to operate as AFM-licensed financial institution.

The following personal information is collected:

• Name, address, postal code, city, country;
• Other contact details such as telephone and email address;
• Necessary screening and employment information such as Resume, Copy ID, certificates, background checks;
• KYC details such as Verified copy ID, UBO details as required by law.

Personal information that is collected is adequate, relevant and limited to what is necessary in relation to the purposes. Personal information will be destroyed or deleted if no longer necessary.

We may use third parties for certain services that need the processing of personal information such as payroll processor, IT providers and parties required for compliance reasons such as depositary offices and providers of software for CRM, AML-check and deal filing reasons.

We implemented the necessary administrative, technical and organisational measures to ensure a level of security, which is appropriate for the specific risks that we identified. Measures that we took are physical access control, logical access control, authorization levels and user records.

The persons of whom we collect personal information have certain rights:

• The right to information and access their personal information: We can be requested more information about our processing activities;
• The right to ask for rectification or deletion of personal information: When requested, we will complete or change inaccurate or incomplete data. If processing of personal information is unlawfully, we can be requested to delete personal information. For compliance reasons Rivean Capital may refuse the deletion of personal information such as but not limited to compliance with tax and AML legislation;
• The right to ask for a copy of personal information that is processed by us;
• The right to object or to complain about the collection, processing and storage of personal information. Complaints can be filed to us or to the Dutch Data Protection Authority.

Rivean Capital B.V. is responsible for all Rivean Capital’s subsidiaries and affiliates and its managed funds (“the Group”) to comply with privacy laws and regulations, such as EU General Data Protection Regulation. When required by law to notify certain specified information to Authorities on Data Protection, Rivean Capital will be responsible to notify this information on behalf of the Group.

Individuals who would like to know what kind of personal information we collect and register, or who would like to request access to this personal information, or request a correction of any mistakes or who would like to request to delete the information or block the use of the information, can write us:

Requests and complaints can be sent to:
Rivean Capital B.V.
Data Protection Officer
Herculesplein 104
3584 AA Utrecht, The Netherlands

We keep our privacy notice under regular review. This privacy notice was last updated in February 2023.