Privacy statement

Protecting privacy and personal information is essential and is enshrined as a fundamental right. Streamline Trading B.V. (ST) places great importance on safeguarding your privacy and the security of your personal data in accordance with the General Data Protection Regulation (GDPR). In this Privacy Statement, we describe how we handle and protect your personal data.

This Privacy Statement covers

What are personal data and how do we obtain these personal data;
Purposes and legal bases for the processing of personal data;
Sharing your personal data;
Retention periods;
Security of your personal data; and
Your rights regarding your personal data.

Our Privacy Statement is intended for all individuals whose personal data ST processes, including participants in ST's fund, prospects, individuals who have subscribed to newsletters or presentations of ST's fund or ST, and individuals who work for or apply to work at ST.

We collect personal data because you have provided them to us, such as when you provide data when entering into an agreement with us, or by handing us your business card, or by applying for a job. We may also obtain your personal data from other sources, such as commercial register files, counterparties, the internet, or by using other public sources.

What are personal data?

Personal data refer to any information about a natural person. We may process, among others, the following personal data:

Basic data such as your first and last name, prefix, title;
Contact information such as your email address, postal address, and phone number;
Personal data you provide to us in the context of attending events or meetings, such as knowledge and experience data, and dietary preferences;
Personal data you provide to us for job applications, such as your basic data, date of birth, address, phone number, nationality, marital status, and any other personal data provided in your job application;
Any other personal data concerning you that you provide to us or that we may obtain for the purposes and on the legal bases as described hereinafter.

Purposes and legal bases for the processing of personal data

ST may use your personal data for the following purposes:

To provide our financial services;
To comply with our legal obligations;
For marketing and business development activities, such as newsletters and invitations to our meetings that may be of interest to you;
For processing your job application or registration for one of our meetings.

We process your personal data based on one or more of the following legal bases:

The performance of a contract;
Compliance with a legal obligation;
Legitimate interests;
Your consent.

Sharing your personal data

We do not use your personal data for other commercial purposes by third parties. In certain cases, we may share your personal data with third parties, including but not limited to:

Third parties, such as regulators and other authorities, to comply with legal obligations;
Third parties relevant to our services, such as activities outsourced to, among others, the Administrator and Custodian.
External suppliers related to the processing of your personal data for the purposes described in this Privacy Statement, such as IT suppliers, communication service providers, or other suppliers to whom we outsource certain supporting services.

The sharing of your personal data with these third parties only occurs for the purposes mentioned in this Privacy Statement and solely based on the legal bases stated in this Privacy Statement.

Third parties to whom we provide your personal data are also responsible for compliance with privacy laws. Joint efforts are made to meet all legal requirements. To the extent that a third party processes your personal data as a processor of ST, ST enters into a data processing agreement with this third party that complies with the requirements described in the GDPR.

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.

Retention periods

We do not process your personal data for longer than is necessary for the purpose for which they were provided (see the section 'Purposes and legal bases for the processing of personal data'). We retain your personal data in accordance with legal and regulatory requirements. This means that your personal data will be retained for as long as they are needed to achieve the relevant purposes.

Your personal data will be processed until the moment you inform ST that you no longer wish to receive digital messages and/or ST stops sending newsletters, invitations to meetings, or other digital mailings.

Your personal data will be deleted if:

Your personal data are processed and/or retained based on consent, and you withdraw your consent;
The legitimate interest on the basis of which your personal data are processed no longer applies, subject to legal retention obligations (such as the tax retention obligation of usually 7 years), for example, if you sell all your participations in the Streamline Trading fund and no longer wish to have contact with ST.

Security of your personal data

ST has implemented appropriate technical and organizational measures as far as can reasonably be expected of us to protect your personal data against loss or any form of unlawful processing. We require our employees and any third parties (our processors) who necessarily have access to the personal data to maintain confidentiality. In addition, our employees are adequately familiar with the responsibilities and obligations of the GDPR. In short, ST will ensure that your personal data are as secure as possible.

Your rights

At the bottom of every digital message from ST, you can change your email preferences. So, you can always withdraw your consent.

You also have the right to request ST to provide access to your personal data and/or to correct, supplement, delete, or shield them, and/or to restrict or obtain your personal data. A request for access and/or correction can be made in writing to Streamline Trading B.V., Wibautstraat 131D, 1091GL Amsterdam, or by email to fonds@streamline-trading.com.

To the extent that your personal data are processed on the basis of a legitimate interest, you have the right to object to this processing. Such an objection can be made in writing to Streamline Trading B.V., Wibautstraat 131D, 1091GL Amsterdam, or by email to fonds@streamline-trading.com.

If you have a complaint about the processing of your personal data, we ask you to contact us about it. If this does not lead to a satisfactory outcome, you have the right to lodge a complaint with the Dutch Data Protection Authority.

Changes

ST may adjust this Privacy Statement from time to time. You can view our Privacy Statement on our website. We advise you to do so, at least when you provide personal data to ST.

Contact

If you have any questions or comments about the processing of your personal data, you can contact Streamline Trading B.V., Wibautstraat 131D, 1091GL Amsterdam, or by email to fonds@streamline-trading.com.

September 4, 2023