Last Updated: July 1, 2025
At Valmere Capital, we are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, store, and disclose your personal data when you use our services, interact with our website, or engage with us in any way.
By using our services, you agree to the collection and use of information in accordance with this Privacy Policy. We regularly review and update this policy to ensure compliance with the General Data Protection Regulation (GDPR) and the Dutch Data Protection Act (Uitvoeringswet AVG - UAVG), and other applicable laws and regulations.
1. Important Information
Who We Are: Valmere Capital is an AI-driven investment firm committed to intelligent investing.
Data Controller: Valmere Capital is the Data Controller of your personal data.
Contact Us: If you have any questions about this Privacy Policy or our data protection practices, please contact us at:
Changes to this Policy: We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page indicates when it was last revised. We encourage you to review this policy periodically. Material changes will be communicated to you directly where required by law.
2. Personal Data We Collect
We collect personal data that is necessary for providing our investment services, managing our relationship with you, and complying with legal and regulatory obligations. The types of personal data we may collect include:
Identification and Contact Data: Name, address, email address, phone number, date of birth, gender, nationality, national identification number (e.g., BSN/TIN if applicable for tax), passport details, utility bills, photographs, and signature.
Financial Data: Bank account details (IBAN, BIC/SWIFT), payment card details, income, source of wealth, investment history, transaction details, and financial statements.
Professional and Employment Data: Occupation, employer details, and professional qualifications.
Transactional Data: Details about investments you make, services you use, and payments to and from you.
Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access our website or services.
Usage Data: Information about how you use our website, products, and services.
Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.
Special Categories of Personal Data: In limited circumstances, and with your explicit consent or where strictly necessary and permitted by law, we may collect sensitive personal data such as political opinions (for PEP screening), or health information (e.g., for specific financial planning or insurance purposes). This will always be handled with enhanced security and only when absolutely essential.
3. How We Collect Your Personal Data
We collect personal data through various methods, including:
Direct Interactions: When you open an account, apply for our services, fill out forms, subscribe to our newsletters, participate in surveys, or communicate with us via phone, email, or in person.
Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical and Usage Data using cookies, server logs, and other similar technologies.
Third Parties or Publicly Available Sources: We may receive personal data about you from third parties such as:
Public databases and registers (e.g., corporate registries, sanctions lists).
Identity verification services.
Credit bureaus.
Our AI and data analytics partners (who process data under strict confidentiality agreements).
Referral partners.
4. How We Use Your Personal Data (Legal Basis for Processing)
We use your personal data primarily for the following purposes and under the following lawful bases as per the GDPR:
To Perform a Contract with You or Take Steps At Your Request Before Entering a Contract:
Opening and administering your investment accounts.
Processing your transactions and investment instructions.
Communicating with you about your investments and our services.
Providing personalized investment advice and portfolio management (where applicable).
To Comply with Legal and Regulatory Obligations (Legal Obligation):
Performing Anti-Money Laundering (AML) and Know Your Customer (KYC) checks.
Complying with financial regulations, tax reporting requirements, and court orders.
Detecting, preventing, and investigating fraud, financial crime, and security breaches.
For Our Legitimate Business Interests (Legitimate Interest):
Improving our products, services, and website.
Developing new investment strategies and AI models.
Conducting market research, statistical analysis, and internal reporting.
Managing our business operations, including IT systems and network security.
Marketing our services to you (unless you object).
Enforcing our terms and conditions.
Recovering debts owed to us.
Exercising our legal rights (e.g., in litigation).
Where we rely on legitimate interests, we ensure that a careful balancing test is performed to confirm that your interests and fundamental rights do not override our legitimate interests.
With Your Consent (Consent):
Sending you marketing communications about products and services that may be of interest to you, where specific consent is required (e.g., for electronic marketing to individuals not yet clients).
Processing Special Categories of Personal Data where no other legal basis applies.
For any other purpose for which we obtain your explicit consent. You have the right to withdraw your consent at any time.
5. Disclosure of Your Personal Data
We may share your personal data with the following categories of recipients:
Within Valmere Capital: For internal administration, client management, and to provide our services.
Service Providers: Third-party vendors and service providers who perform services on our behalf, such as IT support, cloud hosting, payment processing, data analytics, marketing, and legal/advisory services. These third parties are contractually bound to protect your data and are restricted from using it for any other purpose. We only use processors who can provide sufficient guarantees to implement appropriate technical and organisational measures.
Financial Institutions: Banks, brokers, fund administrators, custodians, and other financial institutions involved in processing your transactions.
Regulatory and Law Enforcement Bodies: Where required by law, court order, or to cooperate with regulatory investigations (e.g., Autoriteit Financiële Markten - AFM, De Nederlandsche Bank - DNB, Fiscal Information and Investigation Service - FIOD).
Professional Advisors: Lawyers, auditors, and consultants for professional advice and compliance.
Potential Purchasers/Investors: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the new entity. We will notify you if such a transfer occurs.
With Your Consent: Any other third parties to whom you explicitly consent to us sharing your data.
6. International Data Transfers
As an AI-driven firm, our operations or service providers may involve transferring your personal data outside of the European Economic Area (EEA). Where we transfer your personal data outside the EEA, we will ensure that appropriate safeguards are in place to ensure your data receives a similar level of protection as it would within the EEA, as required by the GDPR. This may include:
Transferring data to countries deemed by the European Commission to provide an adequate level of data protection.
Implementing Standard Contractual Clauses (SCCs) approved by the European Commission.
Ensuring the recipient has adopted Binding Corporate Rules (BCRs) or other approved mechanisms.
7. Data Security
We have implemented robust technical and organizational security measures to protect your personal data from accidental loss, unauthorized access, use, alteration, or disclosure. These measures include:
Encryption: Using encryption for data in transit and at rest.
Access Controls: Restricting access to personal data to authorized personnel on a need-to-know basis.
Firewalls and Network Security: Protecting our systems from external threats.
Regular Audits and Penetration Testing: To identify and address vulnerabilities.
Employee Training: Ensuring our staff understand their obligations regarding data protection and privacy.
Despite our efforts, no system is entirely impenetrable. In the event of a personal data breach, we have procedures in place to address it promptly, including notifying you and the Dutch Data Protection Authority (Autoriteit Persoonsgegevens - AP) where required by law.
8. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. This typically means:
For the duration of your relationship with us.
For a period after the termination of our relationship, as required by applicable laws (e.g., AML/CFT regulations often require data retention for a specified number of years after a client relationship ends).
For legitimate business interests, such as dispute resolution or audit requirements.
9. Your Data Protection Rights
Under the GDPR, you have the following rights concerning your personal data:
The Right to Be Informed: To be informed about the collection and use of your personal data.
The Right to Access: To request access to the personal data we hold about you.
The Right to Rectification: To request correction of inaccurate or incomplete personal data.
The Right to Erasure (Right to Be Forgotten): To request the deletion of your personal data where there is no compelling legal or regulatory reason for its continued processing.
The Right to Restrict Processing: To request the restriction of processing of your personal data in certain circumstances.
The Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
The Right to Object: To object to the processing of your personal data in certain situations (e.g., for direct marketing).
Rights in Relation to Automated Decision-Making and Profiling: To object to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, and to request human intervention.
To exercise any of these rights, please contact us using the details provided in Section 1. We will respond to your request within one (1) month of receipt. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
10. Children's Privacy
Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children without parental consent. If we become aware that we have collected personal data from a child without appropriate consent, we will take steps to delete that information.
11. Cookies
Our website uses cookies to enhance your Browse experience, analyze site traffic, and personalize content. For more information on how we use cookies and how you can manage your preferences, please refer to our separate Cookie Policy [Link to Cookie Policy - if applicable, otherwise remove this section].
12. Complaints
If you have a complaint about our handling of your personal data, please contact us in the first instance. We will do our best to resolve your concerns.
You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens - AP) if you believe your data protection rights have been violated.
