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 provides information on the processing of personal data collected by IceLake.
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 data protection and other applicable privacy laws.
This Privacy Statement may be changed over time. The most up-to-date Privacy Statement is published on our website. This Privacy Statement was last updated in October 2024.
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 the website or other processes within IceLake. Based on applicable data protection and privacy law (such as 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 in that context.
This Privacy Statement is applicable to the processing by IceLake of personal data of its employees, job applicants, business partners, and other individuals.
3. What personal data do we collect and how do we collect this personal data?
We may collect your personal data in different ways via our website or via other processes within IceLake, for example:
- When you provide us with your personal information by telephone, e-mail, or other correspondence.
- From third parties such as tax authorities, credit agencies, governmental, and competent regulatory authorities.
We collect personal information that can identify a living person, including but not limited to:
- Personal information (name, date and place of birth).
- Contact details (addresses, phone numbers, and e-mail addresses).
- Signatures, bank details, and other financial data.
- Job title, employee data, business contact details, and company name.
- Website usage stats and information from public registers (e.g., excerpts from the Dutch Chamber of Commerce).
- Information to comply with legal and regulatory obligations, such as identification data.
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.
If we process your personal data based on your consent (e.g., for marketing purposes), you have the right to withdraw your consent at any time without affecting the lawfulness of processing 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.
- (b) Administering, executing, and/or managing investments in our funds.
- (c) Complying with legal and regulatory obligations (e.g., tax legislation, anti-money laundering, KYC obligations).
- (d) Maintaining administration records.
- (e) Communication purposes (e.g., processing and responding to your requests).
- (f) Establishing, exercising, or defending our legal rights.
- (g) Analytical and research purposes (e.g., fraud prevention, improving our services).
- (h) Marketing purposes, such as sending newsletters or informing you of new investment opportunities.
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.
- (b) Funds, fund managers, investment vehicles, and other parties in which we participate.
- (c) Affiliated or external service providers.
- (d) Banks and advisors (e.g., attorneys, accountants, notaries).
- (e) Governments, judicial and supervisory authorities (e.g., Tax Authority, Dutch Central Bank).
- (f) External auditors.
- (g) (Potential) buyers or merging parties and their advisors in the context of a transaction.
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. We also ensure that data is not stored longer than necessary for its intended purpose.
7. What are your rights?
Under data protection laws, you may have the following rights:
- (i) The right of access to your personal data.
- (j) The right to rectification of inaccurate data.
- (k) The right to erasure (the “right to be forgotten”).
- (l) The right to restrict processing.
- (m) The right to object to data processing.
- (n) The right to data portability.
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: