Privacy statement and Cookie policy

The Goodwell Privacy Statement and Cookie Policy has been drafted in accordance with the requirements of the General Data Protection Regulation (GDPR), which first came into effect in Europe as of 25 May 2018. Keep reading for more information about how we collect, process and store your data, as well as your rights.

This Privacy and Cookie Statement was last updated on 10 October 2022.

Introduction

Goodwell collects and processes personal data with utmost care in order to conduct business with you and/or keep you informed of our company’s activities. If you are:

• A current or potential Goodwell investor
• A current or potential Goodwell portfolio company (investee)
• A current or potential Goodwell business partner, advisor or collaborator
• A job or internship applicant
• A newsletter subscriber
• Someone who has contacted Goodwell via our website

Personal data

Personal data is defined as any information that can be used to identify you, such as your name, address, email address, identity number, or telephone number. Depending on your business relationship with Goodwell, personal data may also include your bank account number, IP address and a copy of photograph of your passport. Any data Goodwell collects shall always be processed in line with the General Data Protection Regulation (GDPR), as well as applicable country-specific data protection regulations, based on whichever requirements are stricter.

Processing of special data such as your religion, ethnicity, or membership in a trade union can only be obtained if permitted by law or if consent for this specific processing is obtained. In all other situations, we are prohibited from using this special personal data.

Data and information collection on our website

Our website collects a series of general, anonymous data and information when a website visitor or automated system calls up the website. This data and information are stored in the server log files. The types of data collected by Google Analytics may include: browser types and versions, operating systems, referring websites, dates and times when the website is accessed, IP addresses, and any other data and information that may be used in the event of an attack on our information technology systems.

This general data and information are not used on draw any conclusions about individual visitors. The information is only employed to correctly deliver the content of our website, ensure the long-term viability of our information technology systems and website technology, and provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, we analyze anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by an individual.

Data security

To ensure the highest possible level of protection for your information, we invest in our systems, procedures and people. Our servers are well protected to keep your personal data safe from loss, destruction, corruption or theft. Access to any document that contains your personal data is restricted, and we only allow necessary access to such information. We take multiple steps to ensure that your personal data is handled with diligence and care. However, if you do not feel comfortable submitting personal data via our website, you may also use alternative means.

Legal basis for data processing

We only process personal data is in accordance with the grounds permitted by law. To be specific, we only use your personal data when it is necessary for one or more of the following reasons:

• To perform a contract with you
• To comply with a legal obligation
• For a legitimate interest of Goodwell
• Because you have given your consent for a specific purpose

Why we use your personal data

We use your personal data to help make our operations, business development and services as effective as possible, and to comply with legal and regulatory requirements. There are a variety of reasons why we may use your data, depending on your relationship with us. Some examples include:

• Maintaining contact with current and potential members of our community
• Evaluating potential investment opportunities
• Evaluating potential employees or interns
• Providing requested services or information
• Providing investors with information about their investments
• Verifying investors identities in order to accept and maintain their investments
• Sending invoices
• Investigating complaints
• Complying with tax and regulatory requirements
• Complying with anti-money laundering, anti-corruption, and other financial laws

How long we retain your data

Personal data is kept for as long as necessary to achieve its specific purpose. In general, the law does not stipulate maximum storage periods for various type of personal data. However, some legislation may specify minimum storage periods which we are under obligation to observe, such as laws pertaining to taxes or specific financial undertakings.

One reason why we may keep data for a longer period of time is if it is necessary for legal proceedings.

Cookies

Cookies are text files that are stored in a computer system via an internet browser. Goodwell’s website uses cookies to optimize the user experience and website performance.

Cookies are commonly used on a wide variety of website and servers. Many cookies contain a so-called cookie ID. This unique identifier consists of a string of character and websites and servers can use to recognize specific web browsers and individual visitors.

The use of cookies enables websites to offer more user-friendly services that would not be possible without the cookie setting. For example, it makes it possible to users to access certain information without having to enter their data every time they visit a website.

Website visitors can, at any time, prevent the use of cookies by blocking them via the relevant settings on their internet browser. In addition, existing cookies can easily be deleted through the browser’s security settings or other software. However, after cookies are deleted or deactivated, it is possible that certain website functionality will no longer be available.

Currently, the Goodwell website only employs functional cookies.

Newsletter subscriptions

Users may subscribe to our newsletter using the form provided on our website.

Newsletters may only be received by individuals who have supplied a working email address, and who also complete a second confirmation step by email (double opt-in process). This confirmation email is used to prove that the owner of the email is indeed interested in receiving the newsletter.

When registering for the newsletter, we also store the IP address of the computer system used to complete the registration, as well as the date and time that it occurred. The collection of this data is necessary to understand the (possible) misuse of the email address at a later date.

The personal data collected as part of the newsletter registration process will only be used to send our newsletter or to send updates about (changes to) our newsletter service. This personal data collected for the newsletter will not be transferred to third parties, and individuals can revoke their consent to storage of this data or unsubscribe to our newsletter at any time. To unsubscribe, use the link provided in each newsletter, or email us at info@goodwell.nl.

Who is responsible for data processing?

The responsible party is:

Goodwell Investments BV

Attn: Saskia Power

Herengracht 201

1016 BE Amsterdam

The Netherlands

Email: info@goodwell.nl

Web: www.goodwell.nl

Third-party access to personal data

We never sell personal data to third parties. However, in some instances, it is necessary to share your personal data with third-party companies that perform services on behalf of Goodwell. We only work with service providers that comply with GDPR. Here are some examples of the types of service providers we work with:

Financial service providers

If you are an investor in Goodwell, it is necessary to share certain personal data with our fund administrator, accountants and auditor. Our fund administrator may also conduct profiling activities (i.e., automated processing of personal data to evaluate specific information about an individual) in order to prevent fraud, manage risks and investigate unusual transactions.

Email and website service providers

Your email address may be shared with our email or website service providers in order to send you information about our company or services, and to optimize the performance of our website.

Legal, tax or regulatory service providers

If you are involved in any official complaint or legal action that requires the participation of Goodwell, we may need to provide your personal data to our lawyers. We may also need to provide personal data to legal, tax or regulatory service providers to meet our legal and tax obligations. In this case, we will provide only information that is strictly necessary to meet our legal or tax obligations or respond to a specific legal claim or official complaint.

Service providers and partners outside Europe

Goodwell is not an international organization, but personal data may be shared with affiliates and partners located in countries including, but not limited to Norway, India, Ghana, Kenya, Nigeria, South Africa, Rwanda, Uganda, Zambia, Mozambique and Mauritius.

Any data shared outside of Europe is only shared with parties who agree to comply with GDPR. Please contact us at info@goodwell.nl if you would like to request a copy of the specific safeguards applied to the export of your information.

What are your rights?

Right to object to processing for informative emails

You can unsubscribe from any of our email communications by using the unsubscribe link at the bottom of the email or by contacting us directly at info@goodwell.nl.

Right of access, right to rectification, right to restriction of processing, right to be forgotten

Upon request, we will provide you with an overview of what, if any, personal data we have on file about you. Should your personal data be incorrect, you may have it rectified. You may also ask us to restrict our use of your personal data in the future, in whole or in part, or request deletion of your personal data. Please note, however, that we cannot comply with a request to restrict processing or to be forgotten if we must process your personal data for compliance with a legal obligation (for instance, if you are a current investor in Goodwell). Please see ‘how long we retain your data’ for further information.

Right to data portability

If we need to process your personal data because we have entered into a contract with you, we can arrange for you to receive the data you have provided to us, so that you can provide this data to another party if you choose. This is referred to as data portability. Information which is processed for the purpose of a legal obligation or a legitimate interest is not covered by this obligation.

Right to object to profiling

It may be the case that you do not want us to use your personal data for profiling. Sometimes, however, we are allowed to do this, for instance to prevent fraud, manage risks or investigate unusual transactions, even if you object to the processing of data. In such situations, we will of course comply with the law.

If you wish to exercise any of above rights, please inform us by sending an email to info@goodwell.nl. We will respond within one month or less, and will handle your request free of charge.

Questions or complaints?

If you have any questions about this Privacy Policy, please contact us by email at info@goodwell.nl. We are happy to help you. Furthermore, you have the right to file complaints with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Changes to this Privacy Policy

Changes to the law or our products and services may affect the way in which we use your personal data. Should this occur, we will revise this Privacy Statement accordingly.

Goodwell Investments B.V.
Herengracht 201 I  1016 BE Amsterdam I The Netherlands
Telephone: +31 852 737 462  I Mobile: +31 6 538 60 207
E-mail: info@goodwell.nl I Website: www.goodwell.nl  I Twitter: @GoodwellInvest