Privacy Statement — Barista Capital

1. Introduction

Barista Management B.V. (“Barista Capital”, as well as “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data.

In connection with our activities as investment manager and in order to comply with our legal and regulatory obligations, we may need to process personal data relating to investors, prospective investors, business contacts, service providers and visitors to our website.

This Privacy Statement explains in a concise manner which personal data we may process, for what purposes, on which legal grounds and what rights you have in relation to your personal data.

2. Who is responsible for your personal data?

Barista Capital is the controller responsible for the processing of your personal data as described in this Privacy Statement.

Barista Management B.V.
Mauritskade 25, 2514 Den Haag
Chamber of Commerce: 42120639
E-mail: noreply@baristacapital.nl

3. Personal data we process

Depending on the nature of your relationship with us, we may process:

your name and contact details;
your position and organisation;
identification and KYC/AML information where required;
information relating to your relationship with Barista Capital;
correspondence and other information you provide to us;
information relating to your participation in meetings or events;
information provided by public sources, such as the Dutch Chamber of Commerce (KvK), and publicly available online sources;
technical information relating to your use of our website, where applicable.

We only process personal data that is relevant and necessary for the purposes described below.

4. Sources of personal data

We primarily obtain personal data directly from you, for example when you contact us, register for an event, express an interest in our activities or enter into a relationship with us.

Where necessary, we may also obtain information from other public or private sources.

In the context of our legal and regulatory obligations, including KYC and AML requirements, we may also obtain information from relevant third parties and public or official sources.

5. How do we use your personal data?

We may use your personal data for the following purposes:

to establish and maintain business and investor relationships;
to respond to enquiries and requests;
to provide information about Barista Capital and its activities;
to organise and administer meetings and events;
to carry out investor onboarding and KYC/AML procedures;
to comply with applicable legal and regulatory obligations;
to manage, secure and improve our website and IT environment;
to protect our legitimate business interests and legal rights; and
where applicable, to send communications or marketing information where we are legally permitted to do so.

6. Legal grounds

We only process personal data where we have a valid legal basis under applicable data protection law.

Depending on the circumstances, this may include:

compliance with a legal obligation;
performance of a contract or taking steps at your request prior to entering into a contract;
our legitimate interests, where these are not overridden by your privacy rights; or
your consent, where consent is required.

Where we rely on your consent, you may withdraw your consent at any time.

7. Sharing personal data

We do not sell your personal data.

We may share personal data where this is necessary for the purposes described above, including with:

regulators and public authorities, such as the AFM, DNB or the Dutch Tax Authorities, where required or permitted by law;
service providers that support our activities, such as IT, hosting, data storage, communication, administration and mailing providers;
the custodian, fund administrator and other professional service providers involved in the management and administration of the Fund, where applicable;
our legal, tax, accounting and other professional advisers.

Where a third party processes personal data on our behalf, we will enter into appropriate contractual arrangements where required by law.

8. International transfers

Where personal data is transferred outside the European Economic Area, we will ensure that the transfer is subject to an appropriate legal mechanism and adequate safeguards as required by applicable data protection law.

9. How long do we retain personal data?

We retain personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required by law or is necessary for the establishment, exercise or defence of legal claims.

Where specific statutory retention periods apply, we will comply with those periods.

10. Your rights

Subject to applicable law, you have the right to:

request access to your personal data;
request correction of inaccurate or incomplete personal data;
request deletion of your personal data;
request restriction of processing;
object to certain processing activities;
request data portability where applicable; and
withdraw your consent where processing is based on consent.

You may submit a request by contacting us at:

noreply@baristacapital.nl

We may need to verify your identity before processing your request.

11. Cookies

Our website uses cookies and similar technologies. For more information about the cookies we use and how you can manage your preferences, please see our Cookie Statement.

12. Complaints

If you have any questions or concerns about the way we process your personal data, please contact us first at: