Last change: 1 Februari 2024

SproutBridge Equity Fund (“the Fund”) is managed by SproutBridge BV, located at Fokkerstraat 16 Unit 3.11, 3833 LD Leusden.
As administrator, SproutBridge BV is responsible for the processing of personal data as shown in this privacy statement.

1. Which personal data do we process?

SproutBridge B.V (“the Manager”) processes your personal data if a) you have registered for further information via the website sproutbridge.nl or by email to the Manager, b) if you have registered for the Fund’s newsletter to be sent, c) if you register as a participant in the Fund, or d) if you register for a meeting.

a. Sign up for the newsletter

The registration for the newsletter is registered via Hubspot and MailChimp, where interested parties enter their details themselves. When you click on the ‘Newsletter’ button, you will be redirected to MailChimp where you enter the following data, which the Administrator then processes:
• Name (first and last name)
• E-mail address
Mailchimp uses cookies. The Administrator has no influence or control over Mailchimp’s use of cookies.

b. Further information requested via an email sent to info@sproutbridge.nl

If you send a request for further information to the Manager via info@sproutbridge.nl, your name and email address (and if applicable: your telephone number) will be processed by the Manager.
The Manager uses cookies on its website (click here for an explanation).

c. Registration as a participant in the fund

See section 8 of this Privacy Statement

d. Register for an introductory meeting or deep-dive meeting

Registration for the meetings is registered via Calendly, where interested parties enter their own details. When you click on the possible dates and times you are already in the calendar environment on our page. When you enter the data, the administrator processes the following:
• Name (first and last name)
• Contact details: telephone / email

2. Why we need the data

The Administrator processes your personal data for the following purposes:
1. General information about the Fund
2. Sending newsletters and other reporting about the Fund.
3. To be able to call or email you if this is necessary to provide the Administrator’s services.
4. To offer you the opportunity to create an account on the Fund’s website
5. Invite interested parties to investment seminars regarding the Fund.
6. Registering for the meetings mentioned under point 5.
7. Creating participant lists for the meetings mentioned under point 5. These participant lists are only produced for the organization of the event by the Administrator himself.

The Administrator further analyzes (anonymous) generic data for the analysis of the use of the website.

3. How long we keep the data

The Administrator stores your data from the moment you register with your email address. If you ask us to delete your data, your data will be deleted as quickly as possible. The Fund itself has a legal obligation to retain data for a certain period.

4. Sharing with third parties

The Manager only shares your personal data with various third parties if this is necessary to perform the services after registration in the Fund (see paragraph 7.) and to comply with any legal obligation. The Administrator concludes a processor agreement with companies, as mentioned under paragraph 7, that process your data on behalf of the Administrator to ensure the same level of security and confidentiality of your data. The Administrator remains responsible for these processing operations.

5. View, adjust or delete data.

You have the right to view, correct or have your personal data deleted. You can do this by sending a request by email to info@sproutbridge.nl.

If you would like to exercise your right to object and/or right to data portability or if you have other questions/comments about data processing, please send a specified request to info@sproutbridge.nl. To ensure that the request for access has been made by you, we ask you to enclose a copy of your proof of identity with the request. Make your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and Citizen Service Number (BSN) black in this copy. This is to protect your privacy.

The Manager will respond to your request as quickly as possible, but in any case within 2 working days.

6. Security

The Administrator takes the protection of your data very seriously and has taken appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized modification. MailChimp and HubSpot (which is used for registering and recording email addresses) have their own security systems.

7. Special and/or personal data that we process

a. Data processing when participating in the fund

If you are going to invest in the Fund, please register via the registration form.
The information you provide will then be processed by the administrator of the Fund, AssetCare BV. The Manager has concluded a management agreement with AssetCare BV.

AssetCare BV is located at Eurocenter 1, 7th floor, Barbara Strozzilaan 310, 1083 HN Amsterdam.

AssetCare BV has its own privacy policy that you can request from the Data Protection Officer of AssetCare BV. He can be reached via +31(0)20 4703550 or via the following email address: bram.schrijven@assetcare.nl

b. Minimum age

Our website is aimed at professional and non-professional investors. In the latter category, an initial investment in the Fund must amount to at least €100,000. The Administrator therefore does not intend to collect data about website visitors who are younger than 16 years of age. Apart from providing a (business) email address, we cannot check whether a visitor is older than 16. If you are convinced that we have collected information about a minor without the consent of the parents (or legal representatives), please contact us by email and we will delete this information.

8. Changes to this privacy statement

The Manager reserves the right to make changes to this statement if new circumstances make this necessary. You can inform yourself of these changes by consulting the Statement regularly. The date of the last adjustment is stated at the top and bottom of this Privacy Statement.

9. Questions or complaints?

If you have any questions, or if you have the impression that your data is not properly secured and there are indications of misuse, you can contact the Administrator:
• Email: info@sproutbridge.nl
• Call: +31 (0)85 060 4417
• Write: SproutBridge B.V., Fokkerstraat 16 Unit 3.11, 3833 LD Leusden

The Administrator would also like to point out that you have the option to file a complaint with the national supervisory authority, the Dutch Data Protection Authority. (https://autoriteitpersoonsgegevens.nl/)