Privacy Notice

Protecting your privacy

This Privacy Notice (the “Privacy Notice”) relates to http://www.anthosam.com, Anthos Fund & Asset Management B.V. (“Anthos”), with registered office Jachthavenweg 111, 1081 KM Amsterdam, The Netherlands, registered in the Commercial Register under trade register number 34258108. Anthos is committed to ensuring that your privacy is protected. So please read this Privacy Notice carefully to understand our views and practices regarding your personal data and how we will treat it.

What information (personal data) do we collect from you, and for what purpose?

We may collect and process the following personal data from you:

  • information that you have provided us by email or telephone. The legal basis for this data processing consists in our legitimate interest in processing your email or telephone inquiry and providing services or information requested by you (6 para. 1 lit. f GDPR );
  • any of your personal data we use for which you have provided us your consent. The legal basis for this data processing consists in the consent you have provided to the processing of personal data for one or more specific purposes (6 para. 1 lit. a GDPR ); and
  • details of your visits to our website, including, but not limited to, traffic data, location data and other communication data and the resources that you access. This data is collected and processed for the purpose of allowing the use of our websites (establishing a connection), ensuring system security and stability in the long term and allowing our Internet offering to be optimised, as well as for internal statistical purposes. The IP address will be evaluated for clarification and defence purposes only in the event of an attack on the website’s network infrastructure or in case of a suspicion of unauthorised or abusive use of the websites. It may further be used for identification purposes in criminal proceedings and in the context of civil and criminal proceedings against the individual concerned, as necessary and required. The legal basis for this data processing consists in our legitimate interest to process the data for these purposes (Art. 6 para. 1 lit. f GDPR).

We use the personal data you provide in a manner that is consistent with this Privacy Notice. If you provide personal data for a certain reason, we may use the personal data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the personal data you provide to answer your question or resolve your problem. We may also use the personal data and other information you provide in connection with your use of our website to help us improve the content and functionality of the website and to better understand our users. If we intend to use any personal data in any manner that is not consistent with this Privacy Notice, you will be informed of such anticipated use before or at the time at which the personal data is collected.

How long do we keep your information?

We retain your personal data only for as long as is necessary to achieve the purposes for which it was collected or to comply with legal obligations that require a specific legal retention period. We keep the data we hold about you under review to ensure that it is not stored for longer periods than are necessary; those periods are determined by considering the amount, nature and sensitivity of the personal data, the purposes for which we process your personal data and, if existing, the applicable legal requirements. In particular, if you provide information in connection with a question you have, your contact details, and request is successfully handled, the information you provided will be deleted as soon as possible, and in any event within six months.

To whom do we disclose your information collected through the Anthos website?

We will forward information only if that is necessary to deal with your inquiry, to provide requested services or information, or to analyse the usage pattern of the website. However, there may be other circumstances where we provide information to third parties to comply with any legal or regulatory obligation or request. We do not undertake marketing activities for third parties, nor do we provide information to third parties for their own marketing purposes.

Various third-party service providers are explicitly mentioned in this Privacy Notice. Additional service providers to whom personal data collected via the websites is passed on or who have or may have access is the company that hosts our website, namely Microsoft Ireland Operations Limited, Atrium Building Block B, Carmenhall Road, Sandyford Industrial Estate, Dublin 18, Ireland. The website is hosted on servers in Amsterdam (with a backup in Dublin). The data is passed on for the purpose of providing and maintaining the functionalities of our websites. The legal basis for this data processing consists in in our legitimate interest (Art. 6 para. 1 lit. f GDPR).

We may use the services of DocuSign, Inc., 221 Main Street, Suite 1000, San Francisco, CA 94105, USA, for the conclusion and signing of contracts between you and us. For that purpose, the contracts and potentially your personal data contained in such contracts, including signatures, will be processed and stored on servers operated by DocuSign Inc. The data will be stored on servers of DocuSign Inc. in the EU. We have executed an agreement with DocuSign Inc., which includes the necessary data privacy safeguards. For further information on how DocuSign is processing personal data in connection with the aforementioned services, please see the data privacy notice of DocuSign Inc. (https://www.docusign.com/company/privacy-policy). For this processing, we rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR.

Do we transfer data to recipients abroad?

We may transfer your data to third parties (contracted service providers) located abroad for the purpose of the data processing described in this Privacy Notice. Any such third-party companies are obliged to protect the privacy of individuals to the same extent as we do. If the level of data protection in a country does not correspond to the Swiss or European level, we shall ensure by contract that the protection of your personal data corresponds at all times to that in Switzerland or the EU.

Do we transfer data to the US?

Yes. For individuals residing in EU Member States or Switzerland, please note that, from the point of view of the European Union and Switzerland, the US does not have adequate data protection laws in place. To the extent that we have explained in this Privacy Notice that recipients of data (such as Google) are located in the US, we will ensure, by way of a contract (entering into standard contractual clauses issued by the European Commission) that your data is adequately protected by our partners.

How do we protect your data?

The security of your personal data is important to us. We collect, process and store all data in line with the regulations on personal data processing applicable in Switzerland and the European Union, in particular the Swiss Federal Act (FADP) of 19 June 1992 on data protection, the Ordinance on the Federal Data Protection Act (OFDPA) and the European General Data Protection Regulation (GDPR) of 27 April 2016. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is completely secure however. So though we will do our best to protect your information, we cannot ensure the security of data you transmit to our website. Any information you submit is sent at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

We take all reasonable care to prevent access to your personal information by unauthorised persons and to prevent unlawful processing, accidental loss, destruction and damage. We will not share your information other than as provided for in this Privacy Notice or as required by law, by court order or by other government or law enforcement authorities.

What should you consider when sending data over the Internet?

The Internet is generally not regarded as a secure environment, and information sent over the Internet (such as to or from the Anthos website or by email) may be accessed by unauthorised third parties, potentially leading to disclosure, changes in content or technical failures. Even if both sender and receiver are located in the same country, information sent over the Internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than exists in your country of residence.

Please note that we accept no responsibility or liability for the security of information in transit over the Internet to Anthos. To protect your privacy, you may wish to choose another means to communicate with Anthos, where you deem this appropriate.

Changes to this Privacy Notice

We regularly review our Privacy Notice; any changes will be included in this section of the site. We therefore ask you to consult it on a regular basis.

Contact

Questions, comments and requests regarding this Privacy Notice are welcome and can be emailed to anthosam@anthos.net or sent to the following address:

Anthos Fund & Asset Management
Jachthavenweg 111
1081 KM Amsterdam

Last updated in December 2020