Privacy Statement
1. Introduction
This is the Privacy Statement of Ice Lake Capital Management B.V. and/or its group companies (“IceLake”, “we” or “us”). This Privacy Statement explains how we collect, use, share, store and protect personal data.
We understand that your privacy is important and that you care about how your personal data is used. We respect and value your privacy and will only collect and use personal data in accordance with applicable data protection and privacy laws.
For questions about this Privacy Statement, the processing of your personal data, or to exercise your privacy rights, you can contact us directly at:
This Privacy Statement may be changed over time. The most up-to-date version is published on our website. This Privacy Statement was last updated in June 2025.
2. Who is responsible for your personal data?
In the context of our activities as an independent investment company, we collect, hold, use and/or otherwise process personal data via our website and through other processes within IceLake.
Based on applicable data protection and privacy law, including the General Data Protection Regulation (“GDPR”) and the Dutch GDPR Implementation Act (“UAVG”), IceLake qualifies as the controller with respect to the personal data that we process.
This Privacy Statement applies to the processing by IceLake of personal data of, among others, employees, job applicants, business partners, investors, representatives of portfolio companies, website visitors and other individuals with whom we interact.
3. What personal data do we collect and how do we collect this personal data?
We may collect personal data in different ways, for example:
- when you provide personal data to us by telephone, e-mail, through our website or via other correspondence;
- through our business relationship with you or the organisation you represent;
- from third parties, such as tax authorities, credit agencies, governmental authorities, regulators, public registers or other competent authorities.
We may collect the following categories of personal data:
- personal identification information, such as name, date of birth and place of birth;
- contact details, such as address, telephone number and e-mail address;
- signatures, bank details and other financial information;
- job title, employee data, business contact details and company name;
- website usage data and information from public registers, such as excerpts from the Dutch Chamber of Commerce;
- information required to comply with legal and regulatory obligations, such as identification data and KYC-related information.
4. For which purposes do we process your personal data and on what ground do we process personal data?
Legal bases for processing
We process your personal data based on one or more of the following legal grounds:
(a) If the processing is necessary in connection with the execution of an agreement.
(b) If the processing is necessary to comply with our legal or regulatory obligations.
(c) If the processing is necessary for the purposes of the legitimate interests pursued by us.
(d) If you have given us your consent.
If we process your personal data based on your consent, for example for marketing purposes, you have the right to withdraw your consent at any time by contacting us at info@icelake.com. Withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal.
Purposes for processing
We collect and use your personal data for purposes such as:
(a) Providing our services and fulfilling contractual obligations, based on the performance of a contract and/or our legitimate interests. This may include personal information, contact details, business contact details, contractual information, and financial information.
(b) Administering, executing, and/or managing investments in our funds, based on the performance of a contract, legal obligations, and/or our legitimate interests. This may include personal information, contact details, financial information, investment-related information, and company information.
(c) Complying with legal and regulatory obligations, such as tax legislation, anti-money laundering, and KYC obligations, based on legal obligations. This may include identification data, contact details, financial information, company information, and information from public registers.
(d) Maintaining administration records, based on legal obligations and/or our legitimate interests. This may include personal information, contact details, business contact details, financial data, and administrative information.
(e) Communication purposes, such as processing and responding to your requests, based on our legitimate interests and/or your consent. This may include your name, e-mail address, telephone number, company name, job title, and the content of your message.
(f) Establishing, exercising, or defending our legal rights, based on our legitimate interests and/or legal obligations. This may include personal data that is relevant to the matter, such as contact details, correspondence, contractual information, and transaction-related information.
(g) Analytical and research purposes, such as fraud prevention, security, and improving our services, based on our legitimate interests. This may include website usage data, communication data, and other relevant information.
(h) Marketing purposes, such as sending newsletters or informing you of new investment opportunities, based on your consent and/or our legitimate interests. This may include your name, e-mail address, company name, job title, and marketing preferences.
IceLake does not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.
5. Who has access to your personal data?
We may share your personal data with third parties if necessary and legitimate, such as:
(a) Our group entities, for internal administration, governance, and business purposes.
(b) Funds, fund managers, investment vehicles, and other parties in which we participate, for investment management and administrative purposes.
(c) Affiliated or external service providers, for example for IT, administration, hosting, communication, compliance, or operational support.
(d) Banks and advisors, such as attorneys, accountants, and notaries, for financial, legal, audit, advisory, and transaction-related purposes.
(e) Governments, judicial and supervisory authorities, such as the Tax Authority and the Dutch Central Bank, where required by law or regulation.
(f) External auditors, for audit and financial reporting purposes.
(g) Potential buyers or merging parties and their advisors, in the context of a transaction, merger, acquisition, restructuring, or similar corporate process.
Some parties may operate outside the European Economic Area (“EEA”). In such cases, we use appropriate safeguards for data transfers, such as:
(i) Adequacy decisions by the European Commission.
(ii) Standard contractual clauses adopted by the European Commission.
(iii) Other valid transfer mechanisms under the GDPR.
6. How do we protect your personal data?
We have implemented technical and organizational measures to protect your personal data against destruction, loss, alteration, unauthorized access, or processing. These measures may include access controls, confidentiality obligations, secure systems, and internal procedures designed to protect personal data.
Access to personal data within IceLake is granted on a need-to-know basis. This means that only employees who require access to perform their responsibilities are authorised to process personal data.
We do not retain personal data for longer than necessary for the purpose for which it was collected, unless a longer retention period is required by law. Personal data processed for legal, tax, accounting, anti-money laundering, or regulatory obligations is retained for the period required under applicable law. Personal data processed for communication purposes is retained for as long as necessary to handle your request or maintain the relevant relationship. Personal data processed for marketing purposes is retained until you withdraw your consent or object to receiving marketing communications. Personal data relevant to legal claims may be retained for as long as necessary to establish, exercise, or defend such claims.
7. What are your rights?
Under data protection laws, you may have the following rights:
(i) The right of access to your personal data, which means that you can ask us whether we process your personal data and request access to that data.
(j) The right to rectification of inaccurate or incomplete data.
(k) The right to erasure, also known as the “right to be forgotten”, in certain circumstances.
(l) The right to restrict processing, which means that you can ask us to temporarily limit the processing of your personal data in certain circumstances.
(m) The right to object to data processing, for example where we process your data based on legitimate interests.
(n) The right to data portability, which means that you can request to receive certain personal data in a structured, commonly used, and machine-readable format.
Where we process your personal data based on your consent, you also have the right to withdraw your consent at any time by contacting us at info@icelake.com. Withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal.
To exercise your rights, contact us via the details below. You also have the right to lodge a complaint with your local data protection authority.
8. Contact details
If you have any questions, remarks, or complaints about how we process your personal data, or if you want to exercise your rights, please contact us at:
Where we process your personal data based on your consent, you have the right to withdraw your consent at any time by contacting us at the contact details below. Withdrawing your consent does not affect the lawfulness of processing based on consent before its withdrawal.