PRIVACY POLICY

Updated as on May 1, 2018

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO VISIT OR USE OUR SERVICES, YOU ARE AGREEING TO THE USE OF THE TECHNOLOGIES FOR THE PURPOSES DESCRIBED IN THIS POLICY. THIS POLICY HAS BEEN UPDATED TO COMPLY WITH THE GENEREAL DATA PROTECTION REGULATION (GDPR) EFFECTIVE FROM MAY 25, 2018.

Phenix capital Holding B.V. and its wholly owned operating entities or affiliates, (for the purpose of this policy - “Phenix Capital”, “we”, “our”, “us”) respect your privacy and are committed to protecting it. This Privacy Policy (“Policy”) is applicable for both Phenix Capital websites – www.phenixcapital.nl and www.impactsummiteurope.com (the “Site(s)”) and governs the privacy of its users (for the purpose of this Policy – “visitors”, “customers”, “you”, “your”) who choose to visit the website.

Our Policy provides with respect to any information that relates to or can be associated with an individual (“Personal data” or “Personal information”) and sets out the basis on which any personal data you provide us or we collect from you, will be shared or processed by us.

Who are we?

Phenix Capital is a boutique impact investing advisory firm founded in 2012 and headquartered in Amsterdam. We advise and assist institutional investors with designing their impact and sustainable development investing strategies, sourcing scalable impact investment opportunities through our database, measuring and reporting their impact and contribution to the SDGs. We also connect impact fund managers with institutional investors committed to aligning their investment policy with the SDGs. We provide an all-round perspective on impact investing for institutional investors and fund managers. Know more about us on www.phenixcapital.nl.

How do we collect your data?

When you use or interact with us through our Sites or our services, we may collect your Personal data and other data, provided to us either voluntarily or via automated means as visitors navigate through our Site.

One or more of the following means may collect this data:

(1) We may ask you to complete surveys for research purposes.

(2)  Information you provide by filling in the registration forms on our website.

(3)  If you apply for a job with us and submit a job application with us.

(4)  If you contact us, we may keep a record of your correspondence with us.

(5)  If you register to any Phenix Capital events, we may ask you certain personal information and you may be required to create a password.

[You shall be responsible for maintaining the confidentiality of your Registration Data. We will use commercially reasonable efforts to safeguard such information. You shall notify Phenix Capital in a timely manner of any (known or suspected) breach of security, including loss, theft, or unauthorized use or disclosure of your password.]

What type of data do we collect?

Personal data: For all users we collect the following details- your full name, your email id, your employer/ Organization, your job title, your country, your credit card details, your address, your work phone number, your password for the purpose of login to the website, your geography/location, your IP address any other data or information which may not be Personal data but may become Personal data if combined together with another non-personal information.

Additionally, user-provided information may include the amount and purpose of your investment, investment objectives, the sectors and geographic location of interest to you for impact investing and any other information you provide about your organization and investments available to and searchable by the public on the Site, and this information may be downloaded or exported by the public from the Site. We may also periodically provide this information to third party contractors and partners for purposes consistent with our mission.

Non-personal data or other data: We may collect non-personal data which may include certain technical data sent to us from the mobile device, computer used by you, geography, statistics of your activities, survey popular content, traffic source, location data, weblogs and other communication data, search engine query, or any other data collected by cookies.

Record of correspondence: We may collect and record copies of any correspondence you have/had with Phenix Capital.

How we use the data we collect?

We use the data collected for the following purposes listed below on the basis of your consent and/or our legitimate basis:

(1) If you subscribe to our newsletters/notifications, for sending you newsletters to keep you educated on the impact world and to bring to you what new services we are bringing.

(2) To carry out our obligations arising from the contracts entered between you and us.

(3) To notify you of any changes or additions to our services at our discretion.

(4) To ensure that content from our Site is useful and presented in the most effective manner for you and your computer.

(5) To provide you with information, products or services that you request from us.

(6) To send invitations and administer Events organized by us.

(7) To send surveys in order to support our research and analyze use of, interest in, our products, services or content offered by us.

(8) To send you email, follow-up questions about your participation in an Event.

(9) For promotions to our services and new services being introduced which may be of interest or useful for you.

(10) To better tailor the Site experience to visitors interests, user or customer interests and display content according to user functionality.

(11) To communicate with visitors and customers by e-mail, telephone, postal mail and/or mobile devices about products or services that may be of interest and that are offered by us, our affiliated companies.

Sharing your Personal data with others:

Phenix Capital takes the privacy of our Users very seriously, and we do not sell, rent, or otherwise provide your personally identifiable information to third parties, except as described in this policy.

Affiliates or subsidiaries: We may share your personal information to any member of our group of companies, which means our ultimate holding company, and its subsidiaries or affiliates.

Agents and/or Service Providers/ Third Parties:

(1)  We may share your information with our third parties to provide services contained on our Site.

(2)  We use Google analytics to track number of visits to our site and improve our website.

(3)  We may store your personal information in locations (servers or databases with hosting service providers) outside the direct control of Phenix Capital.

(4)  We may also transfer or assign such information as necessary in case of change in third party service provider, divestitures, mergers or dissolution.

(5)  We may share your personal information with third parties that perform support services to facilitate your transactions with Phenix Capital only to the extent necessary for the purpose of processing your payments, refunding your payments or dealing with complaints and queries relating to such payments and refunds.

(6)  For payment purposes, your browser may be directed to other third party service provider. This re-direction process will not be apparent to you. These third party websites automatically receive your IP address when this happens, and they may also collect information from your interaction with our websites including computer and connection information, standard web log information. Such information does not identify you individually.

Legal Matters: We may share your personal information with third parties as permitted by, or to reasonably comply with applicable laws and regulations or legal request; to protect against fraud, security or any other issues; safety or vital interests of any natural person; to cooperate with law enforcement or regulatory authorities and to protect Phenix Capital’s rights or property. 

Please note that Phenix Capital is not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, or any other company, including app developers, app providers, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any Personal Information you disclose to other organizations through or in connection with the Applications.

Disclosures

We may provide non-identifiable Personal information to our third parties/contractors for the purpose of providing and maintaining our services. We use reasonable efforts to limit the use of such shared information solely for this purpose and to use other appropriate confidentiality and security measures. 

International Transfer of data:

The hosting facilities for our website is situated in the EU. Any transfers of the to countries outside of the EU will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

We may send your Personal data outside the jurisdiction from which it was collected or originated. Where Personal data is transferred or accessed outside of a specific jurisdiction, we ensure that appropriate safeguards are in place to comply with the applicable data protection regulations.

You acknowledge that Personal data that you submit for publication through our Site or services may be available, via the internet, globally. We cannot prevent the use (or misuse) of such Personal data by others.

Steps we take to protect your data

Limit access to your personal information to authorized Phenix Capital employees, agents or third parties. Follow stringent standards of privacy. We maintain reasonable physical, electronic and managerial procedures to safeguard and secure your personal information.

We also use specialized technology such as firewalls and implement controls to authenticate and protect information during transmission through various means, including, where appropriate, encryption.

However, it cannot be assured that these security measures will prevent any unauthorized interception of or access to your personal information and you hereby agree not to hold the Phenix Capital liable for use of your personal information obtained in any unauthorized manner.

Retention and destruction of your Personal data:

We take all due reasonable steps to ensure the accuracy of the information we hold about you. We will not use your Personal information unless it is accurate and up to date to the best of our knowledge.

We will only retain your up-to-date personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, research or reporting requirements and to a maximum of 15 years.. To determine the appropriate retention period for Personal data, we take into consideration the amount, nature, and sensitivity of the Personal data, the potential risk of harm from unauthorized use or disclosure of your Personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Your Personal data for any purpose will not be stored with Phenix Capital for longer than it is necessary for the purpose it was collected for. The transaction data will be retained for a period of 2 years.

In certain cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will continue to review the requirement of keeping such data and upon a decision that it is no longer necessary for the processing purposes, we will delete the data.

We may retain your Personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to us at privacy@phenixcapital.nl. If you request us to remove the data, we will respond to their request within 30 days.

Your rights:

(1)  Right to Information and Access to the personal information being used

(2)  Right to consent

(3)  Right to withdraw consent

(4)  Right to object to direct marketing

(5)  Right to rectification and erasure – You may ask us to correct any errors or delete your Personal information (whole or in parts) that we hold

(6)  Right to object or restrict our processing of your information

(7)  Request a copy of your personal information

Opt-out: You may opt out from receiving email communications or text messages from us at any time by emailing us at privacy@phenixcapital.nl or by clicking “Unsubscribe” on our Site.

Please note that you cannot opt-out of receiving service messages from Phenix Capital whilst you are contractually liable to receive those services.

Cookie Policy:

What are Cookies?

When you visit the Site, we may send one or more “Cookies” - small text/data files - to your computer to uniquely identify your browser, remember some specific information on the Site and let the Phenix Capital help you log in faster and enhance your navigation through the Site.

Why we use Cookies?

(1)  Cookies are used to analyze trends for administering the Site, tracking users’ movements within the Site and to further gather demographic information about our user base as a whole.

(2)  We may receive reports based on the Cookies on an individual as well as aggregated basis.

(3)  To improve security of the Site by “authenticating” you, when you sign in to our site.

(4)  To keep a track of your preferences for e.g. language, time zone and timeouts after periods of inactivity.

(5)  To perform research and analytics in order to improve our Site and our products and services

(6)  A cookie may convey anonymous information about how you browse the Site to us. We do not use Cookies do not collect personal information about you

Types of Cookies we use:

Persistent Cookie - A persistent cookie may remain on your computer after you close your browser so that your browser can use it on subsequent visits to the Site. Persistent cookies can be removed by following your web browser’s directions.

Session Cookie - A session cookie containing an encrypted, unique identifier is temporarily tied to your account and it disappears after you close your browser. These session cookies allow us to uniquely identify you when you are logged into the Site and to process your online transactions and requests.  You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent.

Authentication cookie: An authentication cookie identifies you when you visit our Site and as you navigate

Personalization cookie: A personalization cookie stores the information about your preferences in order to personalize the website for your use

Status cookie: A status cookie determines the status if you are logged in to or out of our Site.

Security cookie: A security cookie is a security measure used to protect our website and services generally,

Analysis cookie: We use Google analytics to analyze the use of our website.

Managing cookies:

You can disable or delete cookie data used by browser add-ons or by changing the add-on's settings or visiting the Site of its manufacturer. Please note that, if you decline to use cookies, you may experience reduced functionality and, for sites using authentication-related cookies, declining cookies may prevent you from using the Site altogether. Please use the below links to obtain latest information on blocking and deleting cookies via these links:

Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Opera: http://www.opera.com/help/tutorials/security/cookies/

Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

Safari: https://support.apple.com/kb/PH2141

However, some features of the Site may not function properly if the ability to accept cookies is disabled.

Security

Although we will use our reasonable commercial efforts to protect your Personal information, we cannot guarantee the security to such information. This is due to the fact that the transmission of data over the internet is never 100% secure. After receiving your data we use strict security measures to try to protect it against loss, misuse, unauthorized alterations or interception when transferred electronically. We maintain physical, electronic and procedural safeguards including the use of encryption technologies to protect your confidential information.

Changes to the Policy

We reserve the full right and sole discretion to amend, update, change or modify this Policy at any time, with or without prior notice to the user. The revised Policy shall be effective immediately, once posted on the Site. If any material changes are made, you will be informed/ or notified at our sole discretion by either of the following method - on our website, by newsletter, by blog post, by email or any other method we deem fit for such information. You are required to visit our website periodically to review our Policy and learn or any revisions. If you visit any other site referred on the Website, the same shall be governed by the privacy policy of such sites.

Dispute Resolution & Governing Law

If you feel that the Phenix Capital is not abiding by its posted privacy policy, you should first contact us by email at info@phenixcapital.nl.

By accessing this Site, you and Phenix agree that all matters relating to your access to, or use of this Site shall be governed by and construed in accordance with the laws of The Netherlands, without giving effect to any principles of conflicts of law.

All disputes regarding this privacy policy will also be resolved under the law of The Netherlands.

Links to other websites

We are not responsible for the privacy policies of any sites that are linked to or from the Site or any site that you use to access the Site. Please consult the respective privacy policies associated with these sites for more information on their privacy policies and for instructions on how to opt-out of certain practices. Our privacy policy does not apply to, and we cannot control the activities of, such other web sites.

Contact Information:

If you have questions or comments about this Privacy Policy, please contact us at privacy@phenixcapital.nl

Alternatively, if you have questions or comments please send them to us at:

Phenix Capital

Barbara Strozzilaan 101,

1083 HN Amsterdam

or, email to

info@phenixcapital.nl