Legal
Privacy Policy
Read how we process personal data, our legal bases and how to exercise your privacy rights.
Last updated:
Zenth Capital B.V. (“Zenth Capital”, “we”, “us” or “our”) processes personal data carefully, lawfully, fairly and transparently in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy legislation.
Controller
Zenth Capital B.V. Kamervoort 187, 6851 EE HUISSEN The Netherlands Dutch Chamber of Commerce (KvK): 98177893 E-mail: invest@zenthcapital.nl General: invest@zenthcapital.nl For questions about this Privacy Statement or our processing of personal data, please contact invest@zenthcapital.nl.
Personal data we process
Depending on your relationship with us, we may process the following categories of personal data:
name, address, place of residence, date of birth, nationality and contact details;
identification data and copies or details of identity documents where legally necessary;
information about profession, business activities, financial position, source of funds and source of wealth;
KYC, CDD, AML and sanctions-screening information required for client due diligence and verification;
information concerning participations, deposits, distributions, transactions and fund-related communications;
information submitted through contact, documentation, onboarding or subscription forms;
correspondence, call notes and communication preferences;
website and device data such as IP address, browser type, device category and cookie or similar identifiers, where applicable.
For contact or document requests, the website processes the submitted name, email address, phone number and other submitted request details to handle the request. The server temporarily uses the IP address from proxy headers in memory for rate limiting. These website forms do not request identity documents or bank details.
Purposes and legal bases
We process personal data only where a valid legal basis applies. Our main processing purposes are:
1. Contact and information requests – to answer questions, provide fund documentation and communicate with prospective participants. Legal basis: legitimate interests and, where applicable, steps taken at your request prior to entering into a contract.
2. Onboarding, client due diligence and participation – for identification, verification, due diligence, sanctions screening, administration and execution of a participation. Legal basis: performance of a contract, pre-contractual steps and legal obligations.
3. Legal and regulatory obligations – to comply with applicable financial-services, anti-money-laundering, sanctions, tax, reporting and record-keeping obligations. Legal basis: legal obligation.
4. Relationship management and service – to communicate with participants, provide reporting and administrative support and respond to requests. Legal basis: performance of the contract and legitimate interests.
5. News and commercial communications – to send relevant updates, invitations or information about Zenth Capital where legally permitted. Legal basis: consent or legitimate interests depending on the circumstances. You may opt out at any time.
6. Website, security and analytics – to operate and secure the website, prevent misuse and understand website usage. Legal basis: legitimate interests for strictly necessary and privacy-friendly measurement, and consent where legally required.
Sources of personal data
We primarily obtain personal data directly from you. Where necessary and permitted, we may also obtain information from public or legally accessible sources such as the Dutch Trade Register, sanctions lists and other sources used for identification, verification, due diligence and fraud prevention.
Sharing personal data
We share personal data only where necessary for our services, legal obligations or legitimate business operations. Recipients may include:
fund administrators, custodians/depositaries, banks, brokers and other financial service providers involved in fund or participant administration;
providers of onboarding, data-room, CRM, e-mail, hosting, IT, security and communications solutions;
auditors, lawyers, compliance advisers and other professional advisers;
competent regulators, law-enforcement bodies, tax authorities or other public authorities where required by law. Where an external party processes personal data solely on our behalf, we put appropriate contractual privacy and security arrangements in place.
Request details are sent to Brevo for contact registration, transactional confirmation emails and an internal notification to Zenth. A request does not subscribe you to marketing or a newsletter. Railway hosts the website and processes website traffic. Data is therefore not processed solely within Zenth. Processor agreements, storage locations and any international transfers still require legal confirmation.
Transfers outside the European Economic Area
Where personal data is processed outside the European Economic Area (EEA), we ensure that a valid transfer mechanism and appropriate safeguards are in place, for example an adequacy decision by the European Commission or approved Standard Contractual Clauses. Where necessary, we assess additional safeguards.
Retention
We retain personal data no longer than necessary for the purpose for which it was collected, unless a longer period is legally required or otherwise necessary. As a general approach:
contact and information requests: generally up to 12 months after completion, unless longer retention is needed for relationship management or evidence purposes;
data relating to prospective participants where no relationship is established: for no longer than necessary for follow-up, compliance and evidence purposes;
client, participation, KYC/CDD and transaction files: for the duration of the relationship and thereafter for the applicable statutory retention period;
marketing data: until opt-out, withdrawal of consent or until we determine that further processing is no longer appropriate;
cookie and analytics data: in accordance with the periods stated in the Cookie Statement and cookie settings. The GDPR does not prescribe one fixed retention period for all personal data. Where a specific statutory retention period applies, we follow that period.
Security
We implement appropriate technical and organisational measures to protect personal data against loss, unauthorised access, alteration, disclosure or other unlawful use. Measures are tailored to the nature and sensitivity of the data and may include access controls, strong authentication, encryption where appropriate, logging, backups, security updates and periodic reviews.
Your rights
Where the GDPR applies, and depending on the circumstances, you may request:
access to your personal data;
rectification of inaccurate or incomplete data;
erasure of personal data;
restriction of processing;
data portability;
to object to processing based on legitimate interests or to direct marketing;
withdrawal of consent, without affecting the lawfulness of processing before withdrawal. You may submit a request to invest@zenthcapital.nl. We may ask you to verify your identity appropriately. We generally respond within one month, subject to the statutory provisions on extensions.
Automated decision-making
Zenth Capital does not make decisions producing legal effects or similarly significant effects on you solely on the basis of automated processing, unless expressly permitted and subject to the safeguards required by law.
Cookies and similar technologies
We use cookies and similar technologies for website operation and security and, depending on your choices, for analytics and other non-essential purposes. Please see our Cookie Statement for more information. You can change your preferences at any time through “Cookie Settings” on the website.
Necessary cookies supplied by Zenth: NEXT_LOCALE remembers your language choice for 365 days after switching languages; zenth_consent stores your cookie choice, whether acceptance or refusal, for 180 days. Optional Analytics is off by default. Only after your explicit consent does the production website load Google Analytics 4 (GA4, provider Google, measurement ID G-ZJB3TFMM97). The _ga and _ga_ZJB3TFMM97 cookies distinguish browsers and maintain session state for page-visit statistics. They are configured for 180 days, without automatic renewal on every visit. Google receives controlled page addresses, page titles and referring pages, and technical connection information such as your IP address. Query strings, hashes, UTM values, calculator amounts and form data are not included in our pageviews. Before consent and after refusal, GA4 is not loaded and no analytics cookies are set. There are no advertising pixels or marketing cookies. You can change your choice or withdraw Analytics at any time using Cookie settings in the footer: measurement stops, GA cookies on this domain are deleted and the page may reload. Withdrawal does not automatically delete data already received by Google. Data retention in the GA4 property, processor agreements and any international transfers still require confirmation; cookie lifetime is not the same as data retention. External websites, including a participant portal, have their own privacy policies.
Cookie StatementExternal links and platforms
Our website may link to third-party websites or secure service-provider portals. Processing on an external website or environment may also be subject to that provider’s privacy notice. Where Zenth Capital remains the controller for data handled in an outsourced environment, this Privacy Statement continues to apply to our processing.
Complaints
If you have a complaint about our processing of personal data, please contact us first at invest@zenthcapital.nl. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
Changes
We may update this Privacy Statement when our services, website or applicable law changes. The most recent version will be published on this page. Where appropriate, we will actively inform affected individuals of material changes.
invest@zenthcapital.nl