Privacy

At Circle Fund Management B.V. we process personal data. We believe it is important that you know how we handle your personal data so that you can be confident that your data is in good hands with us.

What do we use your information for?

To conclude an agreement if you become a customer with us.

In order to welcome you as a customer, we need personal data. For example, we need to receive a copy of an identity document to verify your identity. Without the requested personal data, we cannot fulfil our contractual obligations, but also certain legal obligations.

To fulfil our contractual obligations with you as a customer.

If you are a customer with us, we want to provide you with good service. For this purpose, we process personal data. For example, to carry out orders, we use your name and details of your deposits. The same applies to the parties with whom we work to fulfil our contractual obligations. See the Circle Fund memorandum for this. Your data will not be provided to third parties without your permission, unless necessary for carrying out work in accordance with the concluded agreement.

To maintain the relationship with you.

In addition to using your personal data to fulfill our contractual obligations, we also use the data to provide you with additional information, for example via our newsletters, or to approach you for customer surveys. If you do not appreciate this, please indicate this.

To process these on the basis of a legitimate interest that outweighs your interest as a customer.

For example, to combat fraud. For this purpose, we can compare data from public records and warning systems with personal data in our database.

To comply with legal obligations.

Legislation and regulations may require us to share personal data with, for example, supervisors or a government institution. We are always careful about this. In addition, as part of the retention obligation, we are obliged to keep certain data for a period of seven years after an agreement has ended.

For the development of our services.

In order to provide you with good service, we are constantly working to develop our services. In doing so, we can use data about our website visit. In some cases, we also process personal data for this purpose in order to carry out analyses to improve our services.

We do not collect more personal data than necessary for the purposes mentioned above, unless with your explicit consent. If you consent to the use of your personal data, you can withdraw it at any time.

What are your rights?

As a data subject, you have a number of rights, including the right to view your personal data and the right to correct personal data if they are incorrect. You can also ask us to restrict the processing of your data or to transfer your data. In a number of cases, there is the right to delete the data. This request must not conflict with legal obligations and the retention obligation.

You must express a request for inspection, correction or deletion, etc. by sending an email to: compliance@circle.fund.

If you do not agree with the processing of your data based on a government task, or on a weighing of interests, you have the right to object.

Finally, you have the right to file a complaint with Circle Fund Management B.V. or with the supervisor, being the Data Protection Authority, if you do not agree with how we process your personal data.

Cookies

We want your visit to our website to be as pleasant and smooth as possible. For this purpose, we use various types of cookies. These are small files that are automatically placed on your computer, mobile or tablet when you visit our website.

These cookies make the use of the website more pleasant. In addition, these cookies allow us to analyse how the website is used to improve it, but also to further develop our services. We are unable to identify you personally by the cookies that we use.

Most browsers are set to accept cookies by default. You can set your browser to reject cookies or to notify you when a cookie is being sent. However, some features of the website may not function properly if cookies are disabled. You can also delete the cookies at any time afterwards.

Security level

We protect the data entrusted to us by means of various technical and administrative security measures. In this way, we do our utmost to reduce the risk of loss, misuse, unauthorized access, disclosure or alteration. This includes encrypting data, physical and procedural access controls and firewalls. If you think that data has nevertheless been misused, we would of course like to hear it as soon as possible.

Privacy Policy Changes

Our privacy policy is in line with current laws and regulations and with the use of and opportunities within our current services. We reserve the right to change our privacy policy. Any changes in laws and regulations or our services may result in changes to this privacy policy. You can view our current privacy policy at any time on our website. It is advisable to do this regularly.