Privacy Policy


  1. SPEAR Investments I – the Controller

This is the privacy statement of SPEAR Investments I B.V., a private company with limited liability incorporated under the laws of the Netherlands with statutory seat in Amsterdam and its registered office at Apollolaan 151, 1077 AR Amsterdam, registered with the Dutch Chamber of Commerce under number 83051899 (‘SPEAR Investments I’).

If you want to ask us any questions regarding this privacy policy, email us at [l], as referred to under 7 below.

In relation to personal data SPEAR Investments I may receive directly from you as an employee or a customer or supplier, a person seeking contact with SPEAR Investments I via the website, email or phone, a person applying for a job at SPEAR Investments I, a visitor at a convention where SPEAR Investments I is represented, or a visitor of the website, SPEAR Investments I qualifies as a ‘controller’ under the General Data Protection Regulation (‘GDPR’) with respect to the processing of this personal data. One of the obligations of a controller under the GDPR, is to inform each person of whom it processes personal data, the data subject, regarding the following subjects:

  • The identity and contact details of the controller (paragraph 1 and 6);
  • The categories of personal data (paragraph 2);
  • The purpose of the processing and the legal basis thereof (paragraph 3);
  • The recipients or categories of recipients of your personal data (paragraph 4);
  • The period for which your personal data will be stored (paragraph 5);
  • Your rights in relation to your personal data (paragraph 6).

SPEAR Investments I wishes to inform you, as a data subject, on the abovementioned subjects in this privacy statement.

  1. Categories of personal data

When you access and move around the website, we may collect some or all of the following personal data about you:

  • technical information about your browsing details, such as your IP address.

  1. Purpose and legal basis

SPEAR Investments I only processes your personal data on the basis of one of the following grounds and for the following purposes:

  • The processing is necessary for the performance of a contract to which you are a party. SPEAR Investments I needs personal data of its suppliers and customers for the following purposes: to be able to inform them of matters relating to the subject of the agreement and the performance thereof.
  • The processing is necessary for compliance with a legal obligation to which SPEAR Investments I is a subject. There are several legal obligations applicable to SPEAR Investments I, with administrative obligations under which SPEAR Investments I is obliged to keep books, documents and other data carriers in relation to its administration, including verifying your identity
  • The processing is necessary for the purposes of the legitimate interest pursued by SPEAR Investments I. SPEAR Investments I has a legitimate interest in processing your personal data (i) for the purpose of informing (potential) customers regarding new developments, products and/or services, and (ii) for the purpose of our own protection by keeping files in case of complaints, claims or litigation.
  • You have given your consent to the processing of your personal data for a specific purpose. This is the case if (i) you have contacted SPEAR Investments I via phone, email or the website, with a question or information request. , (ii) you have given SPEAR Investments I your contact details at a convention, and (iii) you have applied for a job or internship at SPEAR Investments I. The processing takes then place for the purpose of: providing you with requested information.

  1. Recipients of your personal data

Your personal data may be stored in our accounting program, if you are a (representative of) a supplier or customer of SPEAR Investments I. This data is also accessible to our accountant and within our group of companies, including our shareholders. We ensure that a data processing agreement is in place with parties that are considered to be processors of your personal data under the GDPR, under which they are obliged to act in accordance with the provisions of the GDPR. Under no circumstances will your personal data be processed outside the EU/EEA.

  1. Storage and term

SPEAR Investments I may store your personal data for (i) as long as necessary in relation to the purpose for which it was obtained, being for the time of the agreement between parties, including a term for possible aftercare, or (ii) as long as legally required in relation to administrative obligations, being a period of 7 years, or (iii) for a period during which it is possible under Dutch law to submit a legal claim, being a maximum period of 20 years., or (iv) in case your personal data is submitted to SPEAR Investments I because you applied for a job or an internship at SPEAR Investments I, for a period of 4 weeks after it has become apparent that no employment or internship agreement will be concluded, with a maximum of 1 year if you have consented thereto.  At any given time, you may request SPEAR Investments I to delete your personal data in accordance with the provisions of the GDPR and as described in paragraph 5 of this privacy statement.

  1. Your rights

In relation to your own personal data, the GDPR grants you certain specific rights, being:

  • Right of access – you have the right to ask SPEAR Investments I whether or not your personal data is being processed by SPEAR Investments I.
  • Right to rectification – you have the right to obtain from SPEAR Investments I rectification of inaccurate personal data SPEAR Investments I may have from you to the extent permitted by the GDPR.
  • Right to erasure (or the ‘right to be forgotten’) – you have the right to obtain from SPEAR Investments I the erasure of your personal data to the extent permitted by the GDPR.
  • Right to restriction of processing – you have the right to obtain from SPEAR Investments I a restriction of processing to the extent permitted by the GDPR.
  • Right to data portability – you have the right to receive the personal data SPEAR Investments I has from you, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, without hindrance from SPEAR Investments I to the extent permitted by the GDPR.
  • Right to not be subject to automated individual decision-making – you have the right not to be subject to a decision based solely on automated processing, including profiling. SPEAR Investments I does not make use of automated individual decision-making in any of its processes.

Furthermore, in case you have a complaint as to how your personal data is treated by SPEAR Investments I, you have the right to lodge a complaint with a supervisory authority (for instance: the ‘Autoriteit Persoonsgegevens’ in the Netherlands).

In case SPEAR Investments I processes your personal data based on your consent, this consent can of course be withdrawn by you at any given time.

  1. Questions or complaints

In case you want to invoke one of your rights as stated in paragraph 5, or you have any other questions and/or complaints in relation to this privacy statement or as to how your personal data is treated, please let us know by sending an email to: [l], stating ‘Privacy’ in the subject of the email.

  1. Reservations

SPEAR Investments I reserves the right to modify this privacy statement unilaterally, in which case the old privacy statement will be automatically replaced by the new one. SPEAR Investments I therefore asks you to review this privacy statement on a regular basis.

 


Contact

Address

Apollolaan 151,
1077 AR Amsterdam

Phone

+ 31 (0) 208 946 270

General enquiries

info@spearinvestments.com

IR enquiries

ir@spearinvestments.com

Disclaimer

SPEAR Investments I B.V. is a private company with limited liability incorporated under the laws of the Netherlands with statutory seat in Amsterdam and its registered office at Apollolaan 151, 1077 AR Amsterdam, registered with the Dutch Chamber of Commerce under number 83051899 (‘SPEAR Investments I’).