Privacy and Cookie Statement Cortese Capital Management BV

This privacy statement indicates how Cortese Capital Management BV (hereinafter: Cortese) processes your personal data and how you can exercise your rights under the General Data Protection Regulation (GDPR). The privacy statement is based on Cortese's external privacy regulations. This document is also via our website to see.

It is not inconceivable that our privacy and cookie policy will be expanded or changed in the near future. We therefore recommend that you regularly check this page to see if any changes have been made.

The most recent version [version 1.4 | 13-09-2022] of the privacy statement can be found on our website (www.cortese.nl).

About Cortese

Questions and complaints
Cortese takes the protection of your data seriously. If you have a question or complaint about the processing of your personal data, Cortese will first try to help you. If you have any questions and/or complaints about the processing of your personal data, you can contact us via telephone number 030 – 307 35 88 or by e-mail info@cortese.nl.
If you do not agree with Cortese's response, you can also file a complaint with the Dutch Data Protection Authority.

Personal data that Cortese processes
This privacy statement applies to personal data processed by Cortese. We process personal data of people with whom we have, have had or would like to have a relationship.

Depending on your relationship with Cortese and the way in which you communicate with Cortese, we process different types of personal data from you. We may process the following personal data from you:
We process your contact details in order to contact you by telephone or in writing (by e-mail or post) in response to the online contact form you have completed and/or to send you the information sources you have requested. In addition to contact details, we also collect identification details, bank details, correspondence and transaction details from the participants in our funds.

Special and/or sensitive personal data that Cortese processes
Our website and/or services do not intend to collect data about website visitors who are younger than 16 years of age, unless they have permission from their parents or guardian. However, we cannot check whether visitors are older than 16. For this reason, parents recommend that they be involved in their children's online activities, in order to prevent data about children from being collected without parental consent. If you believe that we have collected personal information about a minor without this consent, please contact us at info@cortese.nl and we will delete this information.

For what purpose does Cortese process this data?
Cortese processes your personal data for the following purposes:
• To process and execute your registration for participation in a Cortese investment fund and to comply with legal obligations.
• To be able to call or email you if this is necessary in connection with your participation.
• To be able to call or email you in response to a contact form you have completed and/or to send the information source(s) you have requested.
• To inform you about developments of (new) Cortese funds. If you no longer wish us to use your contact details for direct marketing, you can unsubscribe at any time by sending an email to redactie@cortese.nl. You can also use the unsubscribe link in the email or an enclosed reply card. After unsubscribing, we will no longer use your contact details for direct marketing. Your contact details will be kept for a maximum of 2 years after the last contact moment.
• To send newsletters and mailings for which you have registered. You can always unsubscribe via the unsubscribe link in the email or enclosed reply card.

How long is data kept?
Cortese does not store your personal data for longer than is strictly necessary to achieve the purposes for which your data is collected. The data will be deleted if we no longer consider it necessary to process your personal data or if we receive a request to delete your data, unless there is a legal obligation that requires longer retention (such as the tax retention obligation of seven years for administration, including invoices and other administrative documents). Your identity data is subject to a legal retention obligation of 5 years after termination of your participation in the funds.

Is your data shared?
Cortese only provides your personal data to third parties if this is necessary for the execution of an agreement with you, or to comply with a legal obligation.
When we provide your data to a third party, we make agreements with these parties (processors) to ensure the security of your personal data. This ensures that your data is not used for purposes other than those agreed upon and is deleted as soon as it is no longer needed.
Furthermore, we will not provide the information you provide to other parties, unless this is legally required or permitted. For example, it is possible that the police may request data from us in the context of fraud investigations. In that case, we are legally obliged to provide this information.

Cortese shares your data with the following third parties, including our processors:
• Hosting of our website
• WordPress
• CRM system
• Google*
• Bookkeeper/accountant/payroll processor
• Mail servers
• Telephone services
• Payment services
• Delivery services
• Banks

*Google

Google Analytics

If you agree to the use of our website on the cookie pages, this website uses Google Analytics, a web analysis service of Google Inc.

We use Google Analytics to track general visitor data and to analyze how effective our Google Ads advertisements are on Google search result pages. The data is therefore used for statistical analyzes of visiting and clicking behavior on the website. We also optimize the operation of the website. We have also set up Google Analytics in a privacy-friendly manner, so that IP addresses are anonymized and data is sent over a secure connection.

We have a processing agreement with Google. The statistical data is transferred to and stored by Google on servers in Europe and the United States. read it privacy policy from Google for more information, as well as the specific Google Analytics privacy policy. For information on how Google is compliant with the GDPR, Google has specific pages: Google Cloud and the GDPR en what Google does in the field of data protection.

Google uses this information to keep track of how our website is used, to provide us with reports about the website and to provide Cortese as an advertiser with information about the effectiveness of our campaigns. Google may provide this information to third parties if Google is legally obliged to do so, or insofar as these third parties process the information on behalf of Google. We have no influence on this.

You can prevent the storage of cookies via the settings of your browser software. However, we would like to point out that in this case you may not be able to take full advantage of all the functions of this website. In addition, you can prevent the data collected by the cookies and relating to your use of the website (including your IP address) from being sent to Google and this data from being processed by Google by downloading and installing the browser plug-in which is available via the link https://tools.google.com/dlpage/gaoptout?hl=nl

More information about the terms of use and privacy protection can be found at https://www.google.com/analytics/terms/nl.html of op https://www.google.nl/intl/nl/policies/

Google Tag Manager

If you agree to the use of our website on the cookie pages, this website uses the Google Tag Manager. Tag Manager does not collect any personal data. The tool activates other tags, which sometimes collect data on their part. Google Tag Manager does not have access to this data. If a deactivation has been performed at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager. Google's privacy policy in connection with this tool can be found here: https://policies.google.com/privacy?hl=nl

Google Ads Remarketing

If you agree to the use of our website on the cookie pages, our website uses the functions of Google Ads Remarketing. We use this to advertise this website in the Google search results, but also on third-party websites. Information about how Google uses your data when you visit this site can be found here. https://policies.google.com/technologies/partner-sites

The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google places a cookie in the browser of your terminal device for this purpose, which automatically enables interest-based advertising using a pseudonymous cookie ID and based on the pages you have visited.

More extensive data processing only takes place if you have given Google permission to link your web and app browsing history to your Google Account and to use information from your Google Account to personalize advertisements you view on the Internet. In this case, if you are logged in to Google during your visit to our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, Google temporarily links your personal data to Google Analytics data to form target groups. You can permanently disable the installation of cookies for advertising preferences by downloading and installing the browser plugin available at the following link: https://adssettings.google.com/authenticated?hl=nl

You can also join the Digital Advertising Alliance at the Internet address www.aboutads.info inform you about the installation of cookies and make settings for this. Finally, you can set your browser so that you are informed about the installation of cookies and can decide individually whether to accept cookies or only accept cookies for certain cases or generally reject them. If you do not accept cookies, the operation of our website may be limited. More information and the privacy policy regarding advertising and Google can be found here: https://policies.google.com/technologies/ads?hl=nl

How to access, correct or delete your data?
You have the following rights:
• The right of access, rectification and erasure:
you have the right to know which personal data Cortese processes about you and you may subsequently request that it be rectified or deleted.

• The right to object:
you have the right to object to the processing of your personal data. If you object to the use of personal data for direct marketing, Cortese will no longer use your personal data for this purpose.

• The right to restriction of processing:
you have the right to request Cortese to limit the processing of your personal data, for example, when the data is no longer correct, the processing is unlawful, Cortese no longer needs your personal data or pending a decision on the objection you have made against processing.

• The right to data portability:
the right to receive your personal data in a structured, commonly used and machine-readable format, so that you can transfer this data to another party.

• The right to withdraw your consent:
the right to withdraw your consent at any time for the use of data that Cortese has obtained from you for a specific purpose based on your consent. Withdrawal of consent does not affect the lawfulness of the processing before the withdrawal.

For all requests listed above, please send us an email with “data privacy request” in the subject line. We will respond to your request as soon as practically possible. If we will need more than one month (after receiving your request) to respond to your request, we will inform you.

Security
Cortese takes appropriate organizational and technical measures to protect personal data against, for example, misuse, loss and unauthorized access. Access to your personal data is limited within Cortese. This way we ensure that only the necessary people have access to the data.
Servers and devices of our employees are equipped with up-to-date security software, such as a virus scanner and firewall.
We only send your data via secure internet connections (TLS, formerly SSL). You can see this in the address bar 'https' and the padlock.

Cookie statement
Cookies are small text files that can be used by websites to make user experiences more efficient. By law we may store cookies on your device if they are strictly necessary for the use of the site. We need your consent for all other types of cookies.

The Cortese website uses different types of cookies. Some cookies are placed by third-party services that appear on our pages. We use cookies to personalize content and ads, to provide social media features and to analyze our website traffic. We also share information about your use of our site with our partners for social media, advertising and analysis. These partners may combine this data with other information that you have provided to them or that they have collected based on your use of their services.

As a visitor, you can decide for yourself how cookies should be handled. Below you will find our Cookie statement, there you can also change or withdraw your consent. If you have any questions about your consent, please include the ID and date of the consent.

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