Privacy statement Ruppert Trading B.V.

Version [March] 2022

 

We are Ruppert Trading B.V. (hereafter: "Ruppert Trading", "we", "us" and "our"), a Dutch investment fund manager managing a market neutral hedge fund. In the course of our activities, we process personal data. Via this privacy statement, we wish to inform you about such processing in accordance with applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR). If you have any questions or concerns about this privacy statement or the processing of your personal data, please do not hesitate to contact us.

 

Who are we?

We are Ruppert Trading B.V., registered in the trade register with registration number 34302237. Our postal address is Kruisweg 70 III, 2011 LG Haarlem, The Netherlands. For inquiries relating to your privacy, you can reach us via e-mail at info@rupperttrading.com.

 

In connection with the AlgoSight Fund (the "Fund"), we are joint controllers with Stichting Depositary AlgoSight Fund, registered in the trade register with registration number 67245714. Pursuant to the joint controller arrangement between Stichting Depositary AlgoSight Fund and Ruppert Trading, Ruppert Trading shall handle requests to exercise privacy rights (described below in more detail). The information regarding privacy rights in this privacy statement therefore also applies to your personal data processed by Stichting Depositary AlgoSight Fund and Ruppert Trading in connection with the Fund.

 

Legal grounds

We process personal data if (at least) one of the following lawful processing grounds applies:

• the processing is allowed based on your consent;
• the processing is necessary to perform or enter into a contract with you;
• the processing is necessary to comply with our legal obligations; or
• the processing is necessary for the purposes of a legitimate interest of us or of a third party. We only rely on this lawful processing ground if the legitimate interest outweighs your privacy rights and freedoms. In this case, you have the right to object on grounds relating to your particular situation.

 

Where possible, the information about processing activities below includes information about the specific lawful processing ground(s).

 

Processing activities

The nature of the personal data we process about you and the (legitimate) purposes depend on which category of data subjects (i.e. individuals to whom the personal data relate) you belong to. The below overview sets out per category of data subjects which personal data we process, for which purpose(s) and on the basis of which legal ground.

 

Category of data subjects	Personal data	Processing purpose and legal ground
(Contact persons of) (potential) unit holders, clients, investors, business contacts, partners and suppliers	- name; - contact details (business); - company name; - function/title; - personal data from public sources, including Chamber of Commerce, company website; - personal data on business cards; - personal data in correspondence with individual.	Purpose: We process these personal data to enter into and maintain contact with the individual.   Legal ground: This processing is mostly based on our legitimate interest in entering into and maintaining contact with the individual, our legitimate interest in promoting and informing about our business, products, services and activities, and, where necessary, consent from the individual.
	- name; - contact details (business); - company name; - financial information, such as bank account number (IBAN) name of bank account holder, credit card data, VAT data; - personal data included in the agreement, correspondence and, if applicable, invoices; - (for suppliers:) information about the products and/or services delivered to Ruppert Trading.	Purpose: We process these personal data to enter into and/or execute an agreement with the individual or the company the individual represents. For (potential) unit holders, this also entails managing and administering the participation in the Fund. We also process personal data about your participation in the Fund for statistical analyses and research purposes.   Legal ground: This processing is based on our agreement with the individual (where applicable), or otherwise on our legitimate interest in entering into and/or executing an agreement between us and the company the individual represents. The processing activities for statistical analyses and research purposes are based on legitimate interests of us and other parties related to the Fund to conduct statistical analyses and research.
	- copies of legal identification document (passport, national ID card, driver’s license); - source of wealth (family fortune/active entrepreneurial/former entrepreneurial/income/other); - utility bill, bank statement; - tax residency; - national identification number (if legally required).	Purpose: We process these personal data to enter into and/or execute an agreement with the individual or the company the individual represents.Where relevant and necessary, we process these personal to comply with our legal obligations (e.g. to verify the identity and source of wealth of the (potential) unit holder/client).   Legal ground: This processing is based on our agreement with the individual (where applicable), or otherwise on our legitimate interest in entering into and/or executing an agreement between us and the company the individual represents, and/or our legal obligations.
	- name; - contact details (personal); - appointment information; - personal data in correspondence with the individual.	Purpose: We process these personal data to identify individuals and to grant them access to our premises and IT systems.   Legal ground: This processing is based on our legitimate security interest.
Persons who contact Ruppert Trading	- any personal data provided to Ruppert Trading by the individual.	Purpose: We process these personal data to enter into and maintain contact with the individual.   Legal ground: This processing is mostly based on our legitimate interest in entering into and maintaining contact with the individual and, where necessary, consent from the individual.
Visitors	- name; - contact details (personal); - appointment information; - personal data in correspondence with the individual.	Purpose: We process these personal data to identify individuals and to grant them access to our premises and IT systems.   Legal ground: This processing is based on our legitimate security interest.
Website Visitors	- personal data obtained via cookies.	Purpose: We use cookies to ensure the functionality of our website, analyse usage of our website and improve our website and its efficacy.   Legal ground: Where necessary this is based on consent from the individual. Please refer to our Cookie Policy for more information.
	- information submitted by individual via online forms on our website.	Purpose: We process these personal data to handle the request, question or complaint from the individual.   Legal ground: This processing is based on our legitimate interest in following up the individual’s request, question or complaint, or where necessary, consent from the individual.
Social Media Connections	- ‘likes’; ‘tags’; ‘hashtags’; - comments; - personal data contained in messages sent to, written by or shared by Ruppert Trading, or otherwise interactions with Ruppert Trading via social media channels.	Purpose: These personal data are processed to promote our business, products, services and activities, and to enter into and maintain contact with individuals via our social media channels.   Legal basis: This processing is based on our legitimate interest in promoting and informing about our business, products, services and activities, and to enter into and maintain contact with individuals, or where necessary, consent from the individual.
Applicants	- name; - contact details (personal); - date of birth; - gender; - marital status; - nationality; - letter of application; - curriculum vitae; - copies of diplomas and certificates; - testimonials; - certificate of good conduct; - job interview remarks; - personal data from public sources such as LinkedIn; - personal data in correspondence with the individual.	Purpose: We process these personal data for recruitment and selection purposes and, if applicable, to enter into an employment (or contractor) agreement with the individual.   Legal ground: This processing is based on our legitimate interest in fulfilling vacancies and, where necessary, consent from the individual.
	- name; - certificate of good conduct; - personal data required to conduct screening procedure, including (if necessary) information regarding prior convictions; - screening procedure results.	Purpose: We process these personal data for our pre-employment screening procedure.   Legal ground: This processing is based on our legitimate interest to hire individuals who meet our screening requirements and, where necessary, consent from the individual.
	- name; - contact details (personal); - appointment information; - personal data in correspondence with the individual.	Purpose: We process these personal data to identify individuals and to grant them access to our premises and IT systems.   Legal ground: This processing is based on our legitimate security interest.

 

Irrespective of the category of data subjects, we process personal data:

• to comply with legal obligations, e.g., to cooperate with competent authorities or pursuant to tax or data protection laws and regulations;
• in relation to company-law related events, such as entering into business transactions and related agreements (mergers, acquisitions, financing), as well as demergers, insolvency proceedings, etc. This is mostly based on our legitimate interest in entering into such transactions and related agreements or, where applicable, necessary to comply with our legal obligations;
• for the protection of our employees, visitors, premises and belongings. This is mostly based on legal obligations or a legitimate security interest;
• in relation to (the preparation of) legal proceedings and/or investigations. This is mostly based on a legitimate interest in protecting our legal position or the interest of other parties involved in such legal proceedings and/or investigations or, where applicable, necessary to comply with our legal obligations; and
• for records management purposes. This is based on our legitimate interest in keeping records or, where applicable, necessary to comply with our legal obligations.

 

Sources of personal data

We mostly obtain personal data directly from you. We may however obtain your personal data from a different source, such as your employer, our contact person at your organization, our suppliers (including for CRM and CDD purposes), business partners, recruitment agencies (for applicants), and/or insurance companies. We may also collect your personal data from publicly available sources, including the trade register (Chamber of Commerce), our social media channels, your website and/or the website of your company.

 

Your rights

Pursuant to the GDPR, you have various rights with respect to your personal data, including:

• right of access: the right to obtain a confirmation as to whether or not we process your personal data, and if so, the right to access such personal data;
• right to rectification: the right to have inaccurate personal data relating to you rectified;
• right to erasure (the right to be forgotten): the right to have personal data relating to you deleted;
• right to restriction of processing: the right to have the processing of personal data relating to you restricted;
• right to data portability: the right to have personal data relating to you transmitted to another company in a structured, commonly used and machine-readable format;
• right to objection to processing: the right to object to the processing of personal data relating to you, on grounds relating to your particular situation; and
• right to withdraw consent: if the processing of your personal data is based on your consent, you have the right to withdraw such consent. This does not affect the legality of the processing prior to the withdrawal.

 

You can send a request to exercise any of your rights in writing via the contact information set out in this privacy statement. Applicable data protection laws prescribe various conditions, limitations and exceptions in relation to the privacy rights set out above. We will determine on a case-by-case basis whether such conditions, limitations or exceptions apply.

 

If you send us a request to exercise your rights, we must verify your identity pursuant to applicable data protection laws. Should you provide us with a passport copy for this purpose, we kindly request you to delete all irrelevant personal data (such as the citizen service number) on the copy. Dutch citizens can use the 'KopieID-app' of the Dutch Government for this purpose (available in the Apple App Store and Google Play Store).

 

Further to the rights listed above, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, the 'DDPA'). If you wish to do so, please note that the DDPA will only handle your complaint if you have filed a complaint with us first. If you live in a different EU Member State, you may also lodge a complaint with your local data protection authority.

 

Recipients of personal data

Your personal data are accessible to persons within our organization who have a valid reason to access your personal data. Under specific circumstances, your personal data may also be shared with recipients outside of our organization. This for instance includes our group companies, the Fund (including its delegates and/or its or their duly authorised agents and any of their respective, related, associated or affiliated companies, such as the Administrator of the Fund and Stichting Depositary AlgoSight Fund), third parties identified in the Offering Memorandum of the Fund, service providers (such as accountants, auditors and lawyers), competent authorities and governmental institutions (such as tax authorities, supervisory authorities, police or the Chamber of Commerce), courts and dispute resolution committees, bailiffs or similar public or private officers, insolvency administrators,, banks, insurance companies and intermediaries, and potential and current unit holders, clients, suppliers, business partners, or opposing parties and their respective professional advisers and service providers.

 

International data transfers

To the extent our business operations require us to transfer any personal data to recipients outside of the European Economic Area, we will take necessary measures to ensure compliance with the GDPR. This means such international data transfers will take place if:

• an adequacy decision from the European Commission applies to the recipient, meaning that the country of destination offers an adequate level of data protection;
• appropriate safeguards have been put in place, such as binding corporate rules or a data transfer agreement on the basis of EU standard contractual clauses; or
• a specific derogation applies on the basis of applicable data protection laws.

 

The countries for which adequacy decisions exist are listed on the website of the European Commission. If your personal data are transferred pursuant to appropriate safeguards, you can request a copy as part of your right of access. Where appropriate, the same applies to specific derogations.

 

Personal data retention

We do not retain personal data for longer than necessary for the purpose(s) for which we have collected personal data. Where applicable, we retain your personal data to comply with our legal retention obligations.

 

After a data retention period has expired, your personal data may persist on backup or archival media for an additional period.

 

Mandatory provision

You may be required to provide your personal data to us on the basis of a contractual or legal obligation. We will inform you of such obligation(s) where this applies. If you fail to provide us with your personal data even though this is mandatory pursuant to law or contract, we cannot provide our services and may decide to terminate our relationship with you as an individual or business.

 

Cookies

Please refer to our cookie statement for more information about our use of cookies.

 

Changes to this privacy statement

We may update this privacy statement from time to time. The most recent version of this privacy statement is always published on our website www.rupperttrading.com/en/Privacy-notice. If material changes are made, we will inform you thereof using contact details available to us.

 

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