Privacy
Privacy Policy Statement
Pursuant to the requirements of the General Data Protection Regulation (“GDPR”) as implemented in EU Regulation 2016/679 (in the Netherlands also known as the Algemene verordening gegevensbescherming (“AVG”)), Gamma Waves Partners B.V. (“Gamma Waves”, “we”, “us” or “our”) ensures compliance with the GDPR with respect to the collection and processing of personal data.
This Privacy Policy (“Privacy Policy”) concerns the protection and processing of personal data of (employees or management of) portfolio companies, investors, prospects, business partners or website visitors in the context of their relationship with Gamma Waves.
This Privacy Policy applies where we are acting as a data controller with respect to your information; in other words, where we determine the purpose and means of the processing of that information.
This Privacy Policy is intended to provide information on Gamma Waves’ data processing activities relating to your personal data, including the basis on which your information is collected, stored and used by us, as well as the rights available to you under the GDPR.
Contents of this Privacy Policy
What we collect
How we use it
Sharing of your personal data
Cookies
Security
Policy changes
Your rights
Contact
1. What we collect
We collect, use, share and store personal and financial information about you. Most of the information collected by us is information you have provided directly, whether by subscribing to receive information, contacting us, entering into a contractual relationship with us, or otherwise interacting with Gamma Waves.
Website usage
When you visit and/or request information via our website (“Website”), we may collect:
personal contact information (e.g. name, email address); and
information collected via cookies, such as IP address, browser type, pages visited, and time and duration of visits.
Investors, portfolio companies and business partners
When you enter into a contractual or business relationship with us (including as an investor or portfolio company), we may collect:
personal contact information (e.g. name, address, email address, location);
proof of identification (e.g. passport or ID copy);
financial information (e.g. banking details);
regulatory information (e.g. KYC, AML, FATCA/CRS, TIN);
investment-related information; and
any other relevant information provided in correspondence.
For legitimate business purposes, we may also process HR due diligence information relating to management of portfolio companies.
Recruitment
As part of our recruitment process, we collect and process personal data of job applicants to:
(i) enter into a potential contract,
(ii) meet legal obligations, or
(iii) pursue legitimate interests in managing recruitment.
This may include:
name, address and contact details;
date of birth and nationality;
qualifications, employment history and experience;
right-to-work information;
candidate photographs (where applicable).
Other sources
We may also collect limited personal information from public sources where we believe our services may be of interest to you.
2. How we use it
We process personal data in compliance with applicable laws, based on one or more of the following grounds:
Contract performance
Legal obligation
Legitimate interest
Consent (which may be withdrawn at any time)
Personal data may be used to:
perform contractual obligations;
provide information, advice or services;
comply with legal and regulatory obligations (including AML/KYC);
manage and administer our business;
respond to inquiries and communications;
improve our services and website.
We retain personal data only for as long as necessary for these purposes or as required by law.
3. Sharing of your personal data
We may engage third-party service providers (including IT, cloud, legal, compliance and administrative providers) to process personal data on our behalf. These providers receive only the data necessary to perform their services and are bound by confidentiality and data-protection obligations.
We do not sell personal data for marketing purposes.
Personal data may be transferred outside the EEA. Where applicable, we ensure appropriate safeguards are in place in accordance with GDPR requirements.
Personal data may also be disclosed where required by law or in connection with a corporate restructuring or transaction.
4. Cookies
Gamma Waves uses cookies and similar technologies to operate and improve the Website.
We use:
Technically necessary cookies
Analytical / performance cookies (e.g. Google Analytics)
Functionality cookies
Third-party functionality cookies (e.g. YouTube, Google Maps)
Cookies can be managed or disabled via your browser settings. Disabling cookies may affect Website functionality.
5. Security
Gamma Waves has implemented appropriate technical and organizational measures to protect personal data against loss, misuse or unauthorized access. While we take reasonable precautions, transmission of information over the internet cannot be guaranteed as fully secure.
6. Policy Changes
This Privacy Policy may be updated from time to time to reflect legal or operational changes. The most recent version will always be published on the Website.
Last updated: [insert date]
7. Your rights
Under GDPR, you have the right to:
access your personal data;
rectify or erase personal data;
restrict or object to processing;
withdraw consent (where applicable);
data portability.
Requests may be submitted to: info@gammawavespartners.com
You also have the right to lodge a complaint with your local data protection authority.
8. Contact
For questions regarding this Privacy Policy or our data-processing practices, please contact us at:
info@gammawavespartners.com
Gamma Waves Partners B.V.
Prinsengracht 769
1017JZ Amsterdam
The Netherlands

