Privacy Statement

Privacy Policy

Updated on 15 December, 2020

This Privacy Policy sets out how we handle your personal data. You can be confident that we handle your personal data with due care and in line with the General Data Protection Regulation (“GDPR”). We, Pymwymic Investment Management B.V., the manager of all Pymwymic entities (“Pymwymic”), are the controller of your personal data.

This Privacy Policy is intended for you, if:

  • you are an investment member or a potential investment member of Pymwymic;
  • you or your company showed interest to get in touch with Pymwymic through our website, via email, social media, phone or personal interaction with any employees or representatives;
  • you apply for a job and submit a job application with us;
  • you have been connected to the Pymwymic network;

Data collection

We collect personal data you provide when interacting with Pymwymic via telephone, website, online platform, in person or over email. Furthermore, we ask for personal data when you enter into a contract with us. We will process your personal data, or that of your related individuals, for carrying out business or contact with you. Further information concerning why we process personal data will be set out in this Policy.

Data about you

When we talk about personal data, we talk about information that says something about you. The best-known forms of personal data are your name, address, email address, telephone number, age and date of birth. Personal data may also include your bank account number and your IP-address. We may also process information about you such as information about your employer/organization, job title, and any other data or information which may not be personal data but may become personal data if combined together with other (non-)personal information.

We may process your passport photograph, this might qualify as a special category of personal data. Therefore, we will only use this personal data if this is permitted by law or if we have obtained your consent for this specific processing.

Additionally, user provided information may include the purpose of your investments, investment objectives, the sectors and geographic location of interest for impact investing and any other information you provide about your investments. We may also periodically provide this information to third party contractors and partners for purposes consistent with our mission.

What legal basis for processing do we have?

Processing of personal data is only allowed when it is based on one of the “grounds” permitted by law. We only use your personal data for one or more of the following reasons:

  • the processing is necessary for the performance of a contract to which you are a party;
  • the processing is necessary for compliance with a legal obligation;
  • the processing is necessary for the purpose of the legitimate interests of Pymwymic, such as staying in contact (for more information about our legitimate interests please contact us); and
  • the processing is based on your given consent.

For what purposes do we use your personal data?

We use your personal data to help make our operations, business development and services as effective, reliable and efficient as possible. This is done for either one of the following purposes, depending on the nature of your relationship with us:

  • For maintaining (network) relations;
  • For sending different kind of information such as, but not limited to, newsletters, reports and materials pertinent to our activities. And also to  send surveys in order to support our research and analyse use of, interest in, our services or content offered;
  • To send you an answer by email related to follow-up questions about our website, online platform, content, your participation in an event or any other feedback;
  • To send potential investment opportunities or potential collaboration proposals that would be of your interest;
  • to help improve our (online) services, timing and content of future messages and/or to prioritize follow-ups based on perceived communications relevance;
  • To verify the identity of investment members in order to accept and maintain their investment;
  • To carry out our obligations arising from the contracts entered between you and Pymwymic;
  • To comply with tax and regulatory requirements; and
  • To comply with anti-money laundering, anti-corruption, and other financial laws.

Do we share your personal data with others?

Pymwymic does not sell, rent, or otherwise provide your personal data to third parties, except as described in this Privacy Policy.

Sub-contractors

Sometimes it is necessary to provide your personal data to third party companies that perform services on behalf of Pymwymic, so called sub-contractors. Sub-contractors we might use are IT service providers. For example, the email service provider. If you have given us your name and email for purposes of communication, your email address is shared with our email service provider. Our sub-contractors are only allowed to process your personal data for us, under our instructions. We may provide non-identifiable personal data to sub-contractors for the purpose of providing and maintaining our services. We use reasonable efforts to limit the use of such shared information solely for this purpose and to use other appropriate confidentiality and security measures.

We only work with sub-contractors that comply with the GDPR.

Providing your personal data to third parties

Financial service providers

If you are a member of Pymwymic, we share the necessary part of your personal data with our financial administrator and accountant in order for them to carry out their work.

If you are an investment member of Pymwymic, we share the necessary part of your personal data with our fund manager and our accountant in order for them to carry out their work. Our fund manager may also conduct profiling activities in order to prevent fraud, manage risks and investigate unusual transactions.

Other third parties

We may share your information on virtual event platforms during our virtual events, for example with other attendees during a virtual event or conference. This will improve and better the experience and interaction amongst attendees. If this is the case you will be informed.

We may share your personal information with third parties as permitted by, or to reasonably comply with applicable laws and regulations or legal request; to protect against fraud, security or any other issues; safety or vital interests of any natural person; to cooperate with law enforcement or regulatory authorities and to protect Pymwymic’s rights or property.

Please note that Pymwymic is not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, or any other company, including app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any Personal Information you disclose to other organizations through or in connection with the applications.

Sub-contractors outside European Economic Area

We may occasionally share personal data with our sub-contractors outside Europe. In that case, we ensure that either the country has adequate equivalent protections, and that we have concluded separate agreements with those parties, and that these agreements comply with the European standard.

Security

To ensure the highest possible level of protection for your information, we invest in our systems, procedures and people. Our servers are well protected to keep your personal data safe from loss, destruction, corruption or theft. Access to any document that contains your personal data is protected and we only allow the necessary persons to access such documents. Furthermore, we have a strict privacy policy in place to assure all of our employees handle your personal data with due diligence.

Retention period of your data

We keep personal data for as long as necessary to achieve the specific purpose. After this period, your personal data will be erased from our systems to the best of our capability.

The law does not stipulate specific storage periods for personal data. Other legislation may specify minimum storage periods, however. If it does, we are under the obligation to observe these periods. Such legislation includes tax laws or laws governing financial undertakings specifically. Another reason for which we may keep your data longer is if we become involved in a lawsuit or other legal proceedings.

What rights do you have?

GDPR entitles you to a number of rights in relation to your personal data. You may exercise these rights by sending an email to info@pymwymic.com. We will respond without undue delay, in any even event within one month, and will handle your request free of charge. It involves the following rights:

  • Right to Information and Access to the personal information being used
  • Right to withdraw your consent
  • Right to object to direct marketing
  • Right to rectification and erasure – You may ask us to correct any errors or delete your Personal information (whole or in parts) that we hold
  • Right to object or restrict our processing of your information
  • Right to be forgotten
  • Right to data portability
  • Right to object to profiling
  • Request a copy of your personal information

Opt-out: You may opt out from receiving email communications or text messages from us at any time by clicking “Unsubscribe” on our website or in the
e-mail received, in the settings of the online platform or by emailing us at to info@pymwymic.com.

Links to other websites

We are not responsible for the privacy policies of any websites that are linked to or from our website or any website that you use to access our website. Please consult the respective privacy policies associated with these sites for more information on their privacy policies and for instructions on how to opt-out of certain practices. Our privacy policy does not apply to, and we cannot control the activities of such other websites.

Questions or complaints?

Should you have any questions about this Privacy Policy, please send an email to info@pymwymic.com. We are happy to help you.  Furthermore, you have the right to take your complaint to the Data Protection Authority (Autoriteit Persoonsgegevens).

Changes to the Privacy Policy

Changes to the law or our services and products may affect the way in which we use your personal data. If this happens, we reserve the full right and sole discretion to amend, update, change or modify this Privacy Policy at any time, with or without prior notice to the user. The revised Privacy Policy shall be effective immediately, once posted on our website. Please visit our website periodically to review our Privacy Policy and make sure you have read the latest update of the Privacy Policy.

Applicable Law

By accessing our website, you and Pymwymic agree that all matters relating to your access to, or use of this website shall be governed by and construed in accordance with the laws of The Netherlands, without giving effect to any principles of conflicts of law. All disputes regarding this privacy policy will also be resolved under the law of The Netherlands.