This is the privacy statement of Pacenotes Management B.V., hereinafter referred to as “Pacenotes”.  This privacy statement provides information about how we process personal data at Pacenotes and  what rights you have when we process your personal data. This privacy statement may be amended  from time to time, the most recent version will always be available on our website.  

Using our website gives you the possibility to visit other websites, for instance the websites of the  funds we invest in. Pacenotes is not responsible for the processing of your personal data on these  websites and our privacy statement is not applicable to these websites. For more information about  how these companies process your personal data when you visit their website, please refer to the  privacy statement on their website.  

Who are we?
Pacenotes is an investment firm focused on investments in leading VC funds as well as investments directly into ventures. The main service Pacenotes offers is the management of investments fund(s) containing the capital of our investors. Pacenotes is registered at the AFM (Autoriteit Financiele  Markten). 

If you have any questions concerning the processing of your personal data, please contact us.

How do we collect personal data? 
We collect personal data in the following ways:  

Limited partners – when you (may) become involved as a limited partner; • Funds – when we (may) invest in your fund;  

Ventures – when we (may) invest in your company; 

Careers – when you (may) apply for a job or an internship;  

Events – when you (may) sign up for an event; 

News and publications – when you subscribe to our newsletter.  

What personal data do we collect? 
When making use of our services, we collect personal data. Different types of personal data may be  collected depending on how you make use of our services. We collect and process the following types  of personal data:  

Contact information;  

Address details;  

Gender and age; 

Nationality; 

Identification documents; 

Financial information; 

Career information (curriculum vitae); 

Information concerning background checks.  

Why do we process your personal data? 
We use your personal data in order to provide our services and to comply with legal obligations. We  only collect and process personal data that is necessary in relation to the purposes for which your  personal data is processed. Below you will find more information about the specific purposes of 

processing your personal data, on what lawful ground of processing the processing is based and what  the retention period is.  

Limited partner management 
If you are one of our limited partners, we process your personal data. Prior to onboarding you as a limited partner we perform a due diligence check as part of our client validation process. When the  outcome of the customer screening is positive, we start the identification and verification process  based on the information you provided us with. This includes data such as your contact information  but also your identification documents. Next is the risk assessment and classification. After finishing  the client validation process, we start with the onboarding and signing the contracts. When you’ve  become one of our limited partners, we continuously monitor possible changes and keep screening  the possible risks.  

Using your personal data in relation to the client validation process is necessary for us to fulfil our legal  obligations following from the Anti-Money Laundering and Anti-Terrorist Financing Act, the Financial  Supervision Act, Alternative Investment Fund Managers Directive, the Sanction Act and Investment  Products Regulation.  

If you become one of our limited partners, we are obliged to store your personal data for a period of  five years after ending our relationship.  

Fund management
If we invest in your fund or your company, we will process the personal data that you provide to us,  for example your contact information, which we need to be in touch with you. We store your personal  data for a period of five years after ending our relationship. Processing your personal data for the  purpose of fund management is based on your consent. By accepting our investment, you provide us  with the consent to process your personal data.  

Who has access to your personal data?
Personal data we collect may be transferred within Pacenotes’ organisation, but only if Pacenotes has  a legitimate interest to do so. We exchange your data within our organisation for administrative  purpose to create a complete overview of your contacts and contracts.  

The following third parties may have access to your personal data, where relevant, for the provisioning  of their products or services to us or to you:  

Third parties relevant to the services that we provide, such as due diligence providers, partner funds, counsels, experts and alike parties; 

Bank payment system operators and credit card companies, for the fulfilment of payments, as  identified while you undertake your payment;  

Insurance companies; 

IT suppliers hosting our website and technology service and software providers;  • Parties who support Pacenotes in their marketing activities, such as digital agencies and mailing  houses;  

Fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;  • Regulatory bodies, government agencies and law enforcement bodies;  

Our financial advisors, legal advisors, fund administrators and auditors;  

Other third parties with whom we are required by law to share the personal data.  

We may disclose personal data to third parties if we are required or authorised by law or where we  have a public duty to do so, if you have consented to the disclosure, or if we are otherwise permitted  to disclose the information under applicable privacy laws. 

When third parties are given access to personal data, we will take the required contractual, technical  and organisational measures to ensure that your personal data is only processed to the extend that  such processing is necessary or within the scope of the consent we have received from you. We will  ensure that third parties will only process personal data in accordance with the applicable law.  

When a third party processes your personal data for or on behalf of Pacenotes, we will enter into an  agreement with such third party to agree on appropriate conditions subject to which the processing  of personal data is allowed. In this agreement we include obligations to ensure that your personal data  is processed by the data process solely to provide services to us.  

How is my personal data secured?
Pacenotes takes technical and organizational measures to protect your personal data against loss or other forms of unlawful processing. We treat your information confidential. When we use a software supplier or a data processor, we also make sure they take the necessary technical and organisational  measures.  

The regulation which have been put in place to protect your privacy apply throughout the European Economic Area (EEA). This means that any country within the EEA must meet the same privacy  standards as the Netherlands. All the personal data that we hold about you will be processed in the  EEA.  

What if a security incidents occurs?
In case of a security incident or data breach, Pacenotes shall take the required actions to discover the  incident in a timely manner. The incident will be assessed and if there is a risk for the data subjects,  Pacenotes will report the data breach to the Data Protection Authority. Pacenotes will also inform you  if your personal data is involved and this constitutes a hight risk for your.

If you detect a security incident or a data breach, please let us know by sending us and e-mail at hello@pacenotes.vc or get in contact with us by phone.  

What are your rights?
Right of access – if you want a more detailed overview of your personal data that we process;  • Right to rectification – if we process incorrect personal data of you;  

Right to erasure – if the processing of your personal data is based on your consent and after  withdrawing this consent, we have not other lawful ground for processing your personal data;  • Right to restriction – if you for instance challenge the accuracy of the personal data.  

If you want to use one of the data subject rights as described above, please send us an e-mail. Please provide us with the necessary information to identify you.  

Complaint to the Data Protection Authority?
Your satisfaction with the way we process your personal data is important to us. We try our very best  to keep you satisfied and your personal data secure. If you have any complaints concerning the way  we process your personal data, please get in contact with us.

If we cannot work this out together, it is  possible to file a complaint with the Data Protection Authority by using this form: 

https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/gebruik-uw-privacyrechten/klacht-melden-bij-de-ap