In summary, this policy covers:
• What personal data we collect from you and how;
• For what purposes we collect this personal data and on what grounds;
• How long we keep your personal data;
• Who we share your personal data with;
• The rights you have as a data subject in the processing of your personal data; and
• How your personal data is protected.
This policy applies to all individuals who visit our websites and from whom Major Capital processes personal data, such as customers, prospects, individuals who have signed up for newsletters or events, and individuals who have applied for a position with Major Capital.
1. What is personal data?
Personal data is any information relating to an identified or identifiable natural person. Personal data that we process may include:
• Basic information, such as your first and last name, prefix, title;
• Contact details, such as your email address, postal address and telephone number;
• Personal data you provide to us to become our client and to verify your identity in connection with applicable anti-money laundering regulations, such as your nationality, date of birth, country of birth, residential address, TIN number, bank account number and passport number;
• Personal data you provide to us for attending events or meetings, such as access and dietary requirements;
• Personal data that you provide to us in the context of a job application, such as your full name date of birth, address, telephone number, nationality, marital status and any other personal data included in your application;
• Any other personal data relating to you that you provide to us or that we obtain in relation to the purposes and on the basis of the grounds set out below;
We collect this personal data because you have provided it to us. For example, you may provide data when entering into a contract with us, by entering your data on our website (www.major-capital.com), by giving us your business card or by applying for a job. We may also collect your personal data from other sources, such as from local advisors, counterparties, the Trade Register, the Land Registry or by using publicly available sources. If you are merely a visitor to our website, we will not collect personal data.
2. Purposes and legal basis for processing personal data
Major Capital may process your personal data for the following purposes:
• To identify you, verify your identity and accept you as a customer;
• To provide our services;
• To comply with our legal and regulatory obligations;
• For marketing and business development activities, such as news updates, invitations to our events and other marketing communications that may be of interest to you;
• To process your application or registration to any of our recruitment services and events.
We will process your personal data based on one or more of the following legal grounds:
• Execution of a contract;
• Compliance with a legal obligation;
• Legitimate interest;
• Your consent.
3. Third parties
In some cases, we may also share your personal data with third parties. This may include, but is not limited to:
• Third parties relevant in connection with the services we provide, such as financial institutions, supervisory authorities regulatory bodies and government agencies;
• Third parties, in order to comply with legal obligations;
• External suppliers in connection with the processing of your personal data for the purposes described in this Policy, such as IT suppliers, communication service providers or other suppliers to whom we outsource certain support services.
We will only share your personal data with these third parties for the purposes and on the legal grounds set out in this Policy.
Third parties to whom we transfer your personal data are themselves responsible for complying with privacy laws. Major Capital is not responsible or liable for the processing of your personal data by these third parties. To the extent that a third party processes your personal data as a data processor of Major Capital, Major Capital will enter into a processor agreement with that party that meets the requirements set out in the AVG.
Data processing outside the EEA
In order to provide our services, it may be necessary for us to transfer your personal data to a recipient in a country outside the European Economic Area (EAA). In this case, Major Capital will ensure that the data transfer complies with the applicable legislation. In addition, Major Capital is aware of the EU Court of Justice ruling of 16 July 2020 with implications for the transfer of personal data. We are currently in the process of examining how best to overcome this. In any case, we at Major Capital value privacy very highly and try to do everything possible to find a suitable solution. If we have found a suitable solution, we will inform you about this through this privacy statement.
4. How long do we keep your data?
Your personal data will be stored in accordance with the AVG and other applicable laws and regulations.
Your personal data will be processed until such time as you inform Major Capital that you no longer wish to receive digital communications and/or information and/or Major Capital stops sending you newsletters, whitepapers, invitations to events or other digital mailings.
Your personal data will be deleted if:
• It appears that your e-mail address is no longer in use (e.g. in the case of error messages);
• The consent on the basis of which your personal data is processed and/or stored is withdrawn by you;
• The aforementioned legal basis on the basis of which your personal data is processed, expires because, for example, your company ceases to exist, or you have had no contact with Major Capital for a period of 5 years (without prejudice to any legal obligations).
5. Your rights
When processing your personal data, according to the AVG, you have a number of rights. We would like to explain below what your rights are. Should you wish to make a request under these rights, please contact us at [email protected] or the contact details at the bottom of this page.
The right to transfer your data
If you no longer wish to use our services, you may choose to become a customer with another provider. There too, they will probably record certain data about you. To make that switch easier, the Privacy Act has established the right to ‘data portability’.
With this data portability, your data can easily be taken to the other provider. In this way you can have your data sent to you, after which you can use it again with another provider. You can also request us to send the data directly to the other provider.
The right to have your data deleted
In addition to being able to take your data with you when you become a customer with another provider, you also have the right to have your data deleted if you are no longer a customer of ours. This is not possible while you are a customer because we have to keep certain necessary data due to tax obligations (such as registration for the tax authorities). Data that is not necessary can of course be deleted at any time.
The right to view your data
We are always talking about “your data”, but what data is it really about? In order to gain insight into this, the privacy law provides the right to inspect your data.
The right to have your data corrected
Is the information we have on you incorrect or incomplete? That is annoying and we would like to solve this for you. In that case you can make a request to supplement or correct your data (the right to rectification).
The right to object
You have the right to object to the processing of your personal data for direct marketing. This is the case when we at Major Capital send advertising mail to you without your consent. We may do this under certain conditions, but you can therefore always object.
The right to withdraw your permission
If you have given Major Capital (explicit) permission to process personal data, you can always request us to withdraw this permission. If you do so, we may no longer process personal data from you.
The right to restriction of processing
In some cases, you may request us to restrict (temporarily or otherwise) the processing of your personal data. Legitimate reasons for requesting a restriction of processing include, for example, if you dispute the accuracy of the personal data or have lodged an objection to the processing of personal data by Major Capital.
Should you make a request under any of the above rights, we at Major Capital may ask you to identify yourself. We request this identification information to ensure that you are the person to whom the personal data in question belongs.
Cookies are small text files that are stored on your computer, smartphone or other device by means of a characteristic string of characters when you access our website (or app).
Cookies serve, among other things, to make our website more user-friendly and effective and to provide you with a personalized user experience. However, cookies cannot cause any harm by, for example, running programs or transmitting viruses. Cookies also do not allow us to identify individuals.
- Refusing cookies
- Disabling cookies
In addition, you can set your browser to accept the cookies only if you agree. You can find more information about how to block cookies or receive a warning before a cookie is stored in your browser’s manual.
- Deleting cookies
Most cookies have a maximum expiration date. If the expiration date of these cookies has passed, the cookie will be deleted automatically. You can also choose to delete cookies manually, before this date has passed. More information on manually deleting cookies can be found in your browser manual.
What cookies does Major Capital use?
Major Capital only uses first-party cookies (cookies placed by Major Capital itself) and not third-party cookies (cookies placed by third parties).
With regard to their function, we can distinguish the following cookies:
- Essential/necessary cookies
Essential cookies are necessary to navigate the website, use basic functions and ensure the security of the website. Because these cookies are necessary for the operation and security of the website, they cannot be disabled.
- Functional Cookies
Functional cookies are mainly to provide you with additional functions and personal settings. By means of functional cookies we can provide you with services such as chat or certain language settings. If you refuse these cookies, (some) services may not work fully.
- Performance cookies and analytical cookies
Performance cookies and analytical cookies collect information about how you use our website, which pages you visit and, for example, whether errors occur when using the website. These cookies do not collect information that could identify you; all information collected is anonymous and is only used to analyze our website, improve it and find out what interests our users.
At Major Capital, we do not use performance cookies or analytical cookies.
- Advertising cookies, targeting cookies
Advertising and targeting cookies are used to provide you with targeted advertisements or third-party offers and to measure the effectiveness of these offers. These cookies do not store any directly identifiable information, but are only based on unique identifying characteristics of your browser and device.
At Major Capital, we do not use advertising cookies or targeting cookies.
- Sharing cookies
Sharing cookies are used to improve the interactivity of our website with other services (for example, our social networks).
At Major Capital we do not use sharing cookies.
If you have any questions or comments about our Policy or the processing of your personal data, you can send a request to the data controller: Major Capital Management B.V. We will do our best to be of service to you.
Major Capital Management B.V.
1043 NX Amsterdam
Chamber of Commerce: 82427755
In addition, if you are not satisfied with the way we have processed your request or if you do not agree with the way we process your data, you have the right to lodge a complaint with the supervisory authority: the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Major Capital reserves the right to modify this privacy and cookie statement. You are requested to regularly consult this privacy and cookie statement so that you are aware of any changes.