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Privacy

This is the NPM Capital Privacy Statement for customer, supplier and business partner data.  This Privacy Statement provides information on the processing of personal data by NPM Capital N.V., Breitnerstraat 1, 1077 BL Amsterdam, The Netherlands and/or its group companies, hereafter NPM Capital,  we or us.
 
The primary purpose of this Privacy Statement is to inform you. We want you to feel secure when visiting our site and are committed to maintaining your privacy when doing so.

This Privacy Statement may be changed over time.  The most up-to-date Privacy Statement is published on our website. This Privacy Statement was last changed on May 23rd 2018.

This Privacy Statement is applicable to the processing by NPM Capital of all personal data of its customers, suppliers and business partners and other individuals.  This Privacy Statement does not address the processing of personal data of employees in the context of their employment relationship with NPM Capital.

WHO IS RESPONSIBLE FOR YOUR PERSONAL DATA?
NPM Capital N.V., Breitnerstraat 1, 1077 BL Amsterdam, The Netherlands and/or its group companies are the controllers of the processing of all personal data that fall within the scope of this Privacy Statement.

FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA? 
(a)    When you interact with NPM Capital (online or offline)
(i)    What does this purpose entail?
If you get in touch with us, e.g. via info@npm-capital.com, we will use your personal data in order to reply to and answer your question.
(ii)    On what legal ground do we process personal data for this purpose? 
We process your information for this purpose based on our legitimate interest to adequately answer your questions.
(iii)    Which personal data do we process for this purpose?
For this purpose, we process your name, contact details, your correspondence with NPM Capital about your question, and all other personal data which you have shared with us or are necessary to answer your question.
(iv)    For what period do we retain your personal data for this purpose?
We will retain your personal information for the period necessary to fulfil the purpose above, unless a longer retention period is required or permitted by applicable law.

(b)    To comply with the law and to protect health, safety, security, NPM Capital assets and interests 
(i)    What does this purpose entail?
We process your personal data in order to safeguard our employees, customers, suppliers and business partners.  As such, we authenticate your access rights to our premises. When you (want to) do business with us, we will process your personal data for assessment and acceptance purposes, for the performance of the agreement and any actions in relation to the agreement, such as audits or legal process. We may screen your personal data against publicly available government and/or law enforcement agency sanctions lists. We also process your personal data to protect NPM Capital assets and interests.
(ii)    On what legal ground do we process personal data for this purpose? 
We will process your information for this purpose based on our legitimate interest as appropriate or necessary (a) under applicable law, including laws outside your country of residence and including sectorial recommendations (e.g. third party due diligence); (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions and other applicable policies or agreements; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of yours or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
(iii)    Which personal data do we process for this purpose?
For this purpose, we process your contact details such as your address and email address, personal details such as your name and date of birth, payment and credit information, data generated before or during the performance of an agreement between you and NPM Capital, your chamber of commerce number, your VAT number or other required tax details, your visiting history to NPM Capital premises and any information that is relevant for the above purpose.
(iv)    For what period do we retain your personal data for this purpose?
We will retain your personal information for the period necessary to fulfil the purpose above, unless a longer retention period is required or permitted by applicable law.

(c)    To use our website 
(i)    What does this purpose entail?
If you use our website, we process technical data to offer you our website functionalities and to allow our website's administrators to manage and improve our website's performance.  NPM Capital also uses cookies to ensure you can retrieve information from our website quickly and easily, read more about cookies below. 
(ii)    On what legal ground do we process personal data for this purpose? 
We process personal data for this purpose based on our legitimate interest to offer a technically adequately working Website and to improve our website’s performance.
(iii)    Which personal data do we process for this purpose?
For this purpose, we process the personal data you have entered into our Website or that is generated by the functionalities you have used in our website and the technical data from your device such as its IP address, the internet browser you use, the pages you have visited on our website, your click- and surf behaviour and the length of your session.
(iv)    How long do we retain your personal data for this purpose?
For this purpose, your personal data will be retained for the duration of your website visit (session).  After this term, your personal data will be aggregated and used for analytical purposes.

WHO HAS ACCESS TO YOUR PERSONAL DATA? 
Access to your personal data within NPM Capital
Your personal data may be exchanged with NPM Capital, shareholders and associated companies. We exchange your data for administrative purposes and so that we can have a complete overview of your contacts and contracts with the NPM Capital.

NPM Capital employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

Access to your personal data by third parties
The following third parties have access to your personal data, where relevant, for the provisioning of their products or services to NPM Capital: banks, insurance companies, IT suppliers, accountants, forensic specialists, lawyers or consultants.

When third parties are given access to your personal data, NPM Capital will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary.  The third parties will only process your personal data in accordance with applicable law.

If your personal data are transferred to a recipient in a country that does not provide an adequate level of protection for personal data NPM Capital will take measures to ensure that your personal data are adequately protected, such as entering into EU Standard Contractual Clauses with these third parties.

In other cases, your personal data will not be supplied to third parties, except where required by law.

The use of your personal data by data processors
When a third party processes your personal data solely following NPM Capital instructions, it acts as a data processor.  We enter into an agreement with such a data processor for the processing of personal data.  In this agreement we include obligations to ensure that your personal data are processed by the data processor solely to provide services to us.

HOW ARE YOUR PERSONAL DATA SECURED? 
NPM Capital has taken adequate safeguards to ensure the confidentiality and security of your personal data. NPM Capital has implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, da Amsterdam, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing.  Examples are IT security policies, staff training and secure servers.

QUESTIONS OR REQUESTS FOR ACCESS, CORRECTION AND REMOVAL 
You can request access, correction, restriction, portability or removal of the data that NPM Capital processes about you at any time by sending a request to info@npm-capital.com.

In your request, please make as clear as possible what personal information your request relates to. For your protection, we will only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may request you to provide verification of your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event within any applicable legally required timeframes.

If you feel that we do not comply with applicable privacy rules you have the right to lodge a complaint with a competent data protection authority.

Should you have any questions regarding the processing of your personal data, please contact our Privacy Officer, Cyriel Mintjens, via info@npm-capital.com.

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