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Privacy Policy

PRIVACY STATEMENT

Your privacy is of great importance to Refund Estate. For this reason, Refund Estate does everything in its power to protect all of your personal data in accordance with the provisions of the General Data Protection Regulation ("GDPR").

This Privacy Statement describes the measures Refund Estate has taken to protect your personal data and the data of any third parties.

A. CONTACT DETAILS

The contact details of Refund Estate are:

Refund Estate B.V. Papaverweg 34-B100 1032 KJ Amsterdam Telephone: +31 6 55 89 13 13 / +31 6 38 24 63 50 Email: info@refundestate.com

Refund Estate is registered with the Dutch Chamber of Commerce under number 99671514.

B. RESPONSIBILITY

Refund Estate is the data controller and is therefore responsible for the processing of any personal data received that is required to perform the agreement you have entered into with Refund Estate.

C. PERSONAL DATA

Refund Estate may obtain, use or process your personal data in various ways and always does everything in its power to store and protect this data securely.

Source of the personal data received

Refund Estate may obtain your personal data in the following ways:

  • Directly from you, by you providing it to Refund Estate by email, in writing or by telephone

  • From parties to whom you are connected privately or professionally and who are involved in a business relationship with Refund Estate, for example a financing application being handled by Refund Estate

  • From public sources (for example the Trade Register of the Chamber of Commerce, the Land Registry [Kadaster], company websites, social media)

Which personal data

Refund Estate may collect, store and process the following personal data:

  • Contact details, including name, residential, postal, business or registered address (including proof of registration at the relevant address) and contact details such as landline or mobile telephone numbers and email addresses of you and/or other individuals or businesses involved in the business relationship with Refund Estate

  • Data concerning both your identity and the identity of other individuals or businesses involved in the business relationship, such as a copy of your identity document, your date and place of birth, the number of your identity document (passport, ID card, driving licence, residence permit), Citizen Service Number (BSN) and other registration numbers issued, for example, by government or insurance bodies

  • Emails sent directly to Refund Estate or forwarded emails and (where announced in advance and your consent has been obtained) telephone conversations held with Refund Estate

  • Data you provide to Refund Estate concerning your income, assets, details of real estate, possessions and debts, and your business (including but not limited to annual figures, articles of association, deeds of incorporation, organisational charts, forecasts, budgets and business plans), insofar as this data is relevant to the business relationship you wish to enter into, or have entered into, with Refund Estate

  • The data referred to above is also collected for third parties (both individuals and businesses) who are or become involved, through you or on your behalf, in the business relationship you enter into with Refund Estate, such as (other) shareholders of the relevant company, partnership or joint venture

  • Where necessary and permitted under applicable laws and regulations, Refund Estate may collect all data relating to criminal convictions, sentences and offences

Legal bases

On what basis does Refund Estate collect your data?

  • Refund Estate requires your personal data and related information in order to provide its services under the business relationship you wish to enter into, or have entered into, with Refund Estate. The absence of this data makes it impossible to carry out the work arising from the agreement you have with Refund Estate

  • Refund Estate may be required to process or store personal data on the basis of a legal obligation

  • Refund Estate collects personal data following your consent. You may withdraw your consent at any time by notifying Refund Estate via the email address stated under A

  • Refund Estate may require your personal data or other information you have shared in connection with a legal dispute, a claim, or to defend the interests of Refund Estate in legal proceedings

D. PURPOSES

Refund Estate only collects personal data where this serves a purpose, and this purpose depends on the circumstances and the objective of the business relationship you have entered into, or intend to enter into, with Refund Estate.

The following purposes are defined in the broadest sense of the word:

  • Customary activities within the scope of the business relationship you have entered into, or intend to enter into, with Refund Estate, such as analysing financing options, proposals or quotations, drafting financing applications or memoranda and assessing these. This may take place both during the application process and after financing arranged through Refund Estate has been successfully concluded and for which work is carried out following completion of the application, such as (but not limited to) requests for information from the lender.

  • Checks that Refund Estate is required to carry out under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) or other laws and regulations, or as mandated by regulators, before Refund Estate can enter into a business relationship with you and also during this business relationship, such as anti-money laundering checks

E. SHARING OF PERSONAL DATA

Refund Estate only shares your personal data with parties involved in the application process or the ongoing financing.

Lenders

In order to arrange financing for you, it is necessary for Refund Estate to share your personal data with these lenders or with the data processor/service provider engaged by the lender. All of these parties fall under the General Data Protection Regulation (GDPR) and comply with this regulation. These lenders and the third parties they engage use this data solely to assess your financing application or to manage the financing provided.

Third parties

Refund Estate will only share your data with third parties where this is conducive to achieving the objectives of the business relationship you have entered into, or intend to enter into, with Refund Estate. In this case, third parties are exclusively parties involved in or required for your financing application, such as software companies or IT service providers that support Refund Estate in handling your financing application, companies that provide (cloud) storage, valuers, real estate agents, civil-law notaries, accountants or other advisers. These third parties may only use your data for the purpose for which it is provided.

F. RIGHTS

Under the General Data Protection Regulation (GDPR), you have rights regarding the processing of personal data by which Refund Estate is bound.

These rights include:

  • Access to your personal data by means of a data subject access request. Upon receipt of an access request, Refund Estate will share with you all personal data that has been stored.

  • Rectification, amendment or updating of your personal data. At your request, Refund Estate will correct any inaccurate data.

  • Transfer of personal data in a machine-readable format (data portability). At your request, Refund Estate will transfer your personal data to you in a machine-readable format.

  • Erasure of your personal data. At your request, Refund Estate will erase your personal data where Refund Estate no longer needs this data to carry out the business relationship you have entered into, and insofar as Refund Estate is not required by law or regulation to retain this data.

  • Restriction of the processing of your personal data. You may request Refund Estate to (temporarily) restrict, or partially restrict, the processing of your personal data on account of certain circumstances or purposes.

  • Should Refund Estate be negligent or have shared your personal data unlawfully, you have the option of lodging a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

To make requests as set out above or otherwise, you can contact Refund Estate via the contact options set out under A.

The rights set out above are not absolute and depend on the conditions laid down in the aforementioned privacy legislation and the laws and regulations applicable to Refund Estate.

G. RETENTION PERIOD

Refund Estate will only process and store your personal data for as long as this is necessary to carry out or manage the business relationship you have entered into with Refund Estate. After the engagement you have given Refund Estate under this business relationship has ended, Refund Estate will store your personal data only for as long as is reasonably deemed necessary to manage the relevant financing (for example, at the request of the lenders or on the basis of the arrangements made with the lenders regarding this), or where this is required by law or regulation or as a result of legal proceedings and claims.

H. AMENDMENTS

Refund Estate may amend this Privacy Statement from time to time where this is necessary due to changes in laws and regulations or the data protection regulations referred to in this statement, or due to changes in the working methods or organisation of Refund Estate. Any changes then take effect from the new version date of the Privacy Statement.

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