Revo Capital Management B.V.
- Introduction
Revo Capital Management B.V. (hereafter ‘the Manager’) provides you with this privacy notice as asset manager of investment funds and therewith also on behalf of the funds managed, as further detailed in Schedule 1 (the Funds). This privacy notice applies to the data processing activities of the Manager and the Funds. In the context of our activities as independent private equity firm and management company, we collect, hold, use and / or otherwise process personal data of our clients, other business relations and stakeholders (investors, portfolio companies, service providers and our staff, incl. candidates). Based on applicable data protection and privacy laws (such as the General Data Protection Regulation, (GDPR) and the Dutch GDPR Implementation Act), we qualify as ‘joint controllers’ with respect to the personal data that we process in that context. We have made arrangements about our joint responsibilities with regards to the processing of personal data. For more information regarding the joint controllership and the arrangements made in this respect you may contact us via the contact details indicated in paragraph 13. The privacy notice as set out here is applicable to both the Manager, the Funds and relevant other business relationships.
We understand that your privacy is important and that you care about how your personal data are processed. We respect and value your privacy and will only collect and process personal data in the manner and for the purposes as described in this document and in compliance with our obligations and your rights under the applicable data protection legislation and regulations.
2. Information about us
Revo Capital Management B.V.
Address: Prof. J.H. Bavincklaan 7, 1183 AT Amstelveen, the Netherlands
Data Protection Officer (DPO) J.J. (Jaap) van Dijk, please find the contact details of our DPO below in paragraph13. Please refer to schedule 1 for the contact details of the Funds.
3. What does this privacy notice cover and whose personal data do we process?
This privacy notice is relevant for:
- Investors and prospective investors in our Funds or investment vehicles and individuals acting for, or on behalf of, or otherwise providing us with personal data with regard to (prospective) investors in our Funds or investment vehicles
- Portfolio companies and prospective portfolio companies of our Funds and individuals acting for, or on behalf of, or otherwise providing us with personal data with regard to (prospective) investees of our Funds or investment vehicles
- Employees of Revo and its group-related companies (including all candidates)
- Business partners and prospective business partners and individuals acting for, or on behalf of them.
(hereinafter, also referred to as: ‘you’).
This privacy notice explains on what legal basis we may process your personal data and:
- which personal data we collect;
- how and for what purposes we collect the personal data;
- how we may use / process such personal data;
- how we store the personal data;
- for what period we store the personal data; and
- what your rights are under the applicable data protection and privacy legislation.
We encourage you to carefully read this privacy notice. From time to time, we may need to update this privacy notice. This may be necessary, for example, if the legislation changes or if we change our business in a way that affects how we process personal data. In the event that the privacy notice will materially and / or substantially change, we will actively inform you or have informed you of this change and provide you with or have provided you with the new version of the privacy notice. You may also ask us to send you a copy of the most recent version of this privacy notice. The most recent version of this privacy notice will always be available on www.revo.vc.
Note: Where you provide personal data to us, which personal data relate to another individual than yourself (for example of the legal representative of the company you are representing), please provide the concerned individual with (a copy of) this privacy notice before providing us with his / her personal data.
4. What personal data do we collect and how do we collect this personal data?
We collect personal data in various ways:
- Directly from you, for example when you provide us with your personal information by telephone, email or other correspondence;
- Directly from you, for example when you engage in business with us, for example by subscribing to our fund or investment vehicle;
- From third parties, for example tax authorities, credit agencies, governmental and competent regulatory authorities;
- From the company you work for (in case the investor is a legal entity);
- Otherwise, for example, from public sources such as the trade register, public directories or your website.
We collect personal data in various ways:
- Directly from you, for example when you provide us with your personal information by telephone, email, other correspondence or by direct handover in a personal meeting;
- Directly from you, for example when you engage in business with us, for instance by subscribing to our funds or investment vehicles or when we invest in your business through our managed funds;
- From third parties, for example tax authorities, credit agencies, governmental and competent regulatory authorities;
- From the company you work for;
- Otherwise, for example, from public sources such as trade registers, beneficial ownership registers, other public registers, social media or your website.
We collect or process some or all of the following personal data:
- Name, date and place of birth;
- Contact details, including but not limited to addresses, telephone numbers, facsimile numbers and email addresses;
- Function title;
- Investor / investee status;
- Copy of bills (e.g., utility, insurances, phone or other equivalent proofs of residence);
- Ultimate Beneficial Owner (UBO) related information (documents showing whether you are a UBO), including the interests the UBO holds in relevant legal entities;
- Information about whether you are a politically exposed person or not;
- Country or tax residence and tax payer ID;
- Payment information / bank account details;
- Anti-money laundering identification (including passport or driver’s license) and verification documentation;
- Source of Funds / Source of Wealth information;
- Purpose and intended nature of the business relationship;
- Information regarding your interest and holding in our funds or other investment vehicles, including ownership percentage, capital investment, income and losses;
- Information on our interests in portfolio companies, as well as on other shareholders, including ownership percentages, capital investment, income and losses;
- Excerpts of registers (public or not, for example excerpts from the Chamber of Commerce, information from available UBO registers); and
- Signatures.
We note that Revo does not process sensitive data, as defined in the GDPR, being:
- personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs;
- trade-union membership;
- genetic data, biometric data processed solely to identify a human being;
- health-related data;
- data concerning a person’s sex life or sexual orientation.
5. Legal bases for processing
The following legal bases shall apply with respect to the processing of these personal data:
- The processing is necessary for the performance of a contract with you or to take steps prior to entering into a contract, such as further detailed in paragraph 6 section (a);
- The processing is necessary for compliance with legal obligations to which we are subject, such as further detailed in paragraph 6 sections (b) and (c); and
- The processing is necessary for the purposes of the legitimate interests pursued by us, such as to enter into and execute a contract with a (prospective) client of our funds or investment vehicles, in case you act on behalf of such organization and the purposes further detailed in paragraph 6 sections (d), (e), (f) and (g).
6. Purposes for processing
We process your personal data for the following purposes:
(a) To provide the investment services to you and / or to comply with contractual obligations. Without these data, we are unable to provide the investment services to you and / or to comply with our contractual obligations towards you;
(b) To provide the investment services / to comply with contractual obligations with (prospective) clients of our funds or investment vehicles in case you act on behalf of such organizations;
(c) to conduct credit checks;
(d) to comply with regulatory, fiscal, tax information reporting, anti-trust, anti-money laundering and terrorist financing, anti-sanctions evasion and other legal and regulatory obligations;
(e) for the purposes of our internal administration;
(f) if necessary, for establishing, exercising and defending our legal rights;
(g) to monitor and record telephone and electronic communications for:
(i) quality, business analysis, training and related purposes in order to improve our services;
(ii) fraud prevention purposes, crime detection, prevention, (compliance related) investigation and prosecution;
(iii) exercising and defending our legal rights; and
(iv) content and meta data relating to our correspondence.
7. How long will we keep your personal data?
Personal data will be kept throughout the life cycle of your business relationship with us, however no longer than is necessary in light of the purposes for which we process them (we refer to the purposes as listed above in paragraph 6). Only where we are legally obliged to, or where this is necessary for defending our interests in the context of judicial proceedings, we will retain the personal data for longer periods.
8. How do we protect your personal data?
We will implement technical and organizational measures for ensuring a level of security appropriate to the specific risks that we have identified. We protect your personal data against destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed. More specifically, we have taken the following measures: access to personal data is limited to the persons with relevant responsible functions within the company and we have secured our devices and access to databases with usernames and security passwords.
Furthermore, we seek to ensure that we keep your personal data accurate and up to date. In that respect we kindly request you to actively inform us of any changes to your personal data (such as a change in your contact details).
9. Do we transfer and / or share your personal data?
In the context of the purposes as listed above, we can share your personal data with parties in the following situations:
- any bank, financial institution or other third-party lender providing any form of facility, loan, finance or other form of credit or guarantee;
- to our affiliates or any authorized third-party service provider, consultant or advisor engaged by us under the terms of any appropriate delegation or contractual arrangement, in order to provide the investment services to you, or to comply with regulatory requirements, or to provide (without limitation) the following functions:
- using our IT systems, software and business applications;
- supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, administrative, transfer, document storage, record keeping and other related functions, and
- collecting, processing, transferring and storing ‘customer due diligence’, source of funds / source of wealth information and verification data under applicable anti-money laundering and terrorist financing laws and regulations.
- to any regulatory authority with whom we are required to cooperate in relation to an investment. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instruction of insurers or a government authority, such as data protection authorities.
Where relevant and to the extent permittable, we will implement safeguards to ensure the protection of your personal data when disclosing such data to a third party. For example, we may enter into data processing agreements when engaging a data processor providing for restrictions on the use of your personal data and obligations with respect to the protection and security of your personal data. We may share your personal data as set out above with other parties located in countries outside the EU or countries being part of the European Economic Area (EEA). In such case, it shall be ensured that measures are taken to ensure adequate protection of your personal data in accordance with applicable data protection legislation, for instance by assessing the level of data privacy legislation in a non-EEA jurisdiction. You may contact us if you wish insight in the adequate measures taken by us.
In connection with the aforementioned, please note that we may share certain personal data listed in paragraph 4 of this privacy notice with our group related company, Pupa Yönetim Destek Ve Danişmanlik Hizmetleri Anonim Şirketi (Pupa), that we engage to provide certain advisory services in the context of managing the Funds. Pupa is established in Türkiye, which has a comparable level of data protection regulations as in the EEA , but is not regarded as a ‘GDPR-safe’ country by the EU . In view hereof, we have entered into the standard contractual clauses as approved by the European Commission with Pupa. Pupa may on its turn engage another group-related company or other business relationship in Turkey to help Pupa with rendering aforementioned advisory services that is bound by the directions of Pupa and with whom Pupa has also entered into the relevant standard contractual clauses. You have the right to obtain a copy of the standard contractual clauses entered into by Pupa and if you are interested in receiving such copy, you may contact J. J. (Jaap) van Dijk, by email: [email protected]
10. Can I access my personal data?
If you want to know which of your personal data we have processed, you can ask us for details of those personal data and for a copy of it via the contact details included below in paragraph 12. This is known as a ‘data subject access request’.
All such requests should be made in writing and sent to the email or postal addresses shown in paragraph 12 below. In principle, there is no charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make unnecessary repetitive requests) a fee may be charged to cover our administrative costs in responding.
11. What are your other rights?
Under certain circumstances you have the right to:
- receive additional information regarding the processing of your personal data;
- rectify your personal data;
- the erasure of your personal data;
- object to (part of) the processing of your personal data;
- the restriction of (part of) the processing of your personal data; and
- data portability (receive your personal data in a structured, commonly used and machine-readable format and to (have) transmit(ted) your personal data to another organization).
Finally, you also have the right to lodge a complaint to the local data protection authority. The contact details of the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) are as follows: Bezuidenhoutseweg 30 (2594 AV) The Hague; telephone no. 088 – 1805 250, and www.autoriteitpersoonsgegevens.nl .
12. Automated decision making and profiling
We do not undertake any automated decision making or profiling based on your personal data.
13. Contact details
To contact us about anything related to your personal data and / or data protection, including exercising your data subject rights as discussed above in paragraphs 9 and 10, in particular your right to object, please use the contact details below:
For the attention of: J. J. (Jaap) van Dijk
Email address: [email protected]
Telephone number: +31 (0)6 20071629)
Postal Address: Prof. J.H. Bavincklaan 7, 1183 AT Amstelveen, the Netherlands
Schedule 1
This privacy notice applies to the personal data processing of the Manager and the managed Funds. The following entities are in any case covered by the definition of the Funds:
- Revo Capital Fund I B.V.
- Address: Prof. J.H. Bavincklaan 7, 1183AT Amstelveen, the Netherlands
- Revo Capital Fund II B.V.
- Address: Prof. J.H. Bavincklaan 7, 1183AT Amstelveen, the Netherlands
- Revo Capital Co-Investment Fund Coöperatief U.A.
- Address: Prof. J.H. Bavincklaan 7, 1183AT Amstelveen, the Netherlands