PRIVACY STATEMENT – DOUBLEDIVIDEND MANAGEMENT B.V.
Registered office and principal place of business in Amsterdam, registered with the Dutch Chamber of Commerce under number 30199843.

This document describes the policy that DoubleDividend Management B.V. (hereinafter: “DoubleDividend”) follows regarding the collection, processing, use, storageand protection of personal data (hereinafter: “Privacy Statement”).

DoubleDividend is engaged in investing, tailored investment advice and asset management, and the management of investment funds. This Privacy Statement applies to all of DoubleDividend’s business activities and services, as well as to the website www.doubledividend.nl and its use.

Processing of PersonalData
Personal data is any information that can be used to identify a natural person. A person is identifiable if, based on a specific piece of information, the person’s identity can be determined, directly or indirectly, without disproportionate effort. Examples of directly identifying information include a name, address and date of birth. Data that cannot be used to identify an individual directly but can be traced back to an individual with the help of other data also falls under the definition of personal data. An example of this is an IP address.

Asset Management Agreement
If you enter into an agreement with DoubleDividend for the management of your assets or investment advice, or if you are considering entering into such an agreement, we process the following personal data:

  • last name, first name, and initials;
  • address information;
  • email address;
  • phone number;
  • proof of identity;
  • BSN number;
  • LEI (Legal Entity Identifier) code;
  • Payment information;
  • IP address and MAC address;
  • Browser types and times of user activity.

Investors in our investment funds
If you are an investor in our investment funds, we may process the following personal data about you:

  • last name, first name, and initials;
  • address information;
  • email address;
  • phone number.
  • proof of identity;
  • BSN number;
  • Payment information.

Newsletters
We can send you, as a client, a newsletter to keep you informed of the latest developments and information about our products and services. You can also sign up for our newsletter on our website. In that case, we’ll only ask for your name and email address. At the bottom of each newsletter, there’s a link that lets you unsubscribe at any time.

Contact Form, Schedule an Appointment, or Request More Information
If you fill out a contact form, we’ll ask for your name and email address. You’re also welcome to provide your phone number if you’d like us to contact you by phone. If you’d like to schedule an appointment with us or receive more information, we’ll ask for your name, email address and/or phone number.

Purpose of Processing Personal Dataat
We use the personal data that DoubleDividend receives from you for the following purposes:

  • to enter into agreements with you and to be able to execute and fulfill them;
  • to agree on assignments and/or to be able to carry them out (or have them carried out);
  • to inform you about our services and other activities (for example, via email, newsletters, and company magazines) and to be able to send you offers;
  • to comply with applicable laws and regulations;
  • to maintain financial records, and;
  • to grant you access to and allow you to use our website www.doubledividend.nl.

If you wish to engage our services for the management of or advice on your assets, request information from us, or schedule an appointment with us, we will process your personal data for the purpose of performing a contract. In addition, we process certain data about you because we are legally required to do so.

It is also possible that DoubleDividend has a legitimate interest in processing your personal data. However, in every situation, DoubleDividend will conduct a thorough balancing of interests between safeguarding your privacy, on the one hand, and DoubleDividend’s legitimate interest, on the other. Only if DoubleDividend’s legitimate interest outweighs your privacy interests will your personal data be processed on this basis.

In all other cases—for example, when subscribing to the newsletter—we explicitly request your consent to process your personal data. If you have given your consent to the processing of your personal data, you are always free to withdraw that consent.

Recipients of Your Data
DoubleDividend will handle your personal data with care and confidentiality and will use only the data necessary to provide its services. In certain cases, we will share your personal data with third parties, including, but not limited to:

  • third parties, such as regulatory authorities and other agencies, in order to comply with legal obligations; or
  • third parties, such as Saxo Bank, CACEIS Bank Netherlands Branch, Van Lanschot Kempen, the NNEK Fund Platform, and administrative offices, that are relevant to our services; or
  • external vendors in connection with the processing of your personal data, such as IT vendors, communication service providers, or other vendors to whom we outsource certain support services.

Third-Party
The DoubleDividend website may contain references and/or hyperlinks to one or more third-party websites, such as one of the asset management comparison sites. DoubleDividend is in no way liable for how these third parties comply with privacy laws. DoubleDividend therefore recommends that you review the privacy policies of these third-party websites so that you are aware of how they handle your personal data.

Cookies
Our website www.doubledividend.nl uses cookies. A cookie is a small text file that is placed on your device and stores information about your use of the website. Most browsers allow you to refuse cookies or to be asked for permission each time a server attempts to place a cookie on your device. If you do not allow cookies to be placed, this may affect the user-friendliness of the website, or you may not be able to access certain parts of the website.

DoubleDividend uses cookies:

  • Functional cookies are cookies that are technically necessary for this website to function or that provide a service or feature you have requested.
  • Analytical cookies: These are cookies placed by a third-party service provider with whom we partner: Google Analytics 4. This type of cookie does not identify you individually, but helps DoubleDividend, among other things, to:
    • to analyze the use of this website or
    • to compile statistics.

Google Analytics 4 (GA4) generates statistical and other information about the use of this website through cookies. Google stores this information and uses it for reporting purposes. Google Analytics 4 collects all data from devices located in the European Union (based on IP geolocation) via domains and on servers in the European Union before the traffic is forwarded to Analytics servers for processing. Google’s privacy policy is available at https://policies.google.com/privacy.

Retention period
Your personal data will not be retained longer than necessary for the purpose for which DoubleDividend collects or processes the data, unless retaining your data longer is necessary to comply with a statutory retention obligation of DoubleDividend.

Security of personal data
 DoubleDividend has taken appropriate technical and organizational measures, in accordance with the state of the art, to prevent data loss or unlawful processing of your personal data.

Transfer to Other Countries
DoubleDividend will only transfer your personal data to countries within the European Economic Area and to countries whose privacy laws have been determined by the European Commission to provide a level of protection equivalent to that of the GDPR.

Rights of Data Subjects
The General Data Protection Regulation (GDPR) establishes that you have certain rights regarding your personal data. These include the right of access, the right to data portability, and the right to erasure. You can find more information about this on the website of the Dutch Data Protection Authority.

How can you exercise your rights?
You can submit a request by sending an email to: privacy@doubledividend.nl . We will first verify your identity. To do so, we will contact you by phone or in writing. We will process your request as quickly as possible. If we are unable to do so within four weeks, we will inform you of the reason and let you know how much longer it will take.

Please note that in some cases we may not be able to comply with your request, for example, if there is a legal obligation to retain data. If we are unable to comply with your request, we will, of course, let you know as soon as possible.

Complaints
If you are not satisfied with the services provided by DoubleDividend, you can submit your complaint to us in writing (by email or letter) free of charge. Read more about this in our complaints procedure on the website www.doubledividend.nl.

If we have not handled or are not handling your complaint to your satisfaction, you have the right to file a complaint with the Dutch Data Protection Authority regarding DoubleDividend’s processing of your personal data.

Changesto the Privacy
Changes may be made to this Privacy Statement. This Privacy Statement is published on the website www.doubledividend.nl. Please check this website regularly. This Privacy Statement was last updated on June 30, 2025.cy Statementat

Contact Information
DoubleDividend Management B.V.
Ms. D. Timmerman
Rapenburgerstraat 173
1011 VM Amsterdam
privacy@doubledividend.nl