Privacy Policy

1. Data Controller Information

This privacy policy explains how eldoras B.V. ("we", "us", or "our") collects, uses, and protects your personal information when you use our website and services. eldoras B.V. acts as the Data Controller for all personal data processed through our asset management services and website operations.

Company Details:
eldoras B.V.
Schoolstraat 183
4816 ZX Breda
North Brabant, Netherlands
KvK Registration: 80527194
VAT Number: NL889603721B01

2. Data Collection and Legal Basis

The data we collect includes personal information such as your name, email address, phone number, postal address, and any information you provide when contacting us about our asset management services. We collect this information through our website contact forms, email communications, phone calls, and during the provision of our professional services.

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal bases:

• Legitimate Interest: For responding to inquiries and providing information about our services
• Contract Performance: When you engage our asset management services
• Legal Obligation: For compliance with financial services regulations and tax requirements
• Consent: For marketing communications where required by law

3. How We Use Your Information

We explain how we use your information in this section to ensure complete transparency about our data processing activities. Your personal data is used for the following purposes:

• Responding to your inquiries about our asset management services
• Providing professional asset management and investment advisory services
• Communicating with you about your portfolio and investment strategies
• Complying with legal and regulatory requirements in the financial services sector
• Improving our website and services based on user feedback
• Sending relevant information about our services (with your consent where required)

The use of your data is always proportionate and necessary for the specific purpose for which it was collected. We do not use automated decision-making or profiling that would significantly affect you without human oversight.

4. Data Sharing and Third Parties

eldoras may share your personal information with trusted third parties only when necessary for providing our services or complying with legal obligations. This includes:

• Professional service providers (legal advisors, accountants, auditors)
• Regulatory authorities when required by law
• Technology service providers who assist with our website and systems
• Financial institutions for transaction processing

We ensure all third parties maintain appropriate data protection standards and only process your data as instructed by eldoras. We do not sell, rent, or trade your personal information to any third parties for their marketing purposes.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal obligations. Specific retention periods include:

• Client data: For the duration of our professional relationship plus 7 years as required by financial regulations
• Contact inquiries: Up to 3 years from the last contact unless you request earlier deletion
• Website analytics: Up to 26 months as per cookie policy
• Marketing data: Until you withdraw consent or up to 3 years of inactivity

After the retention period expires, we securely delete or anonymise your personal data in accordance with our data destruction procedures.

6. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Correct inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Limit how we use your personal data
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for processing based on consent

To exercise any of these rights, please contact us using the information provided in the Contact section below. We will respond to your request within one month.

7. Data Security

eldoras implements appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication procedures
• Staff training on data protection and security
• Secure data backup and recovery procedures

While we take every reasonable precaution to protect your data, no method of transmission over the internet is completely secure. We cannot guarantee absolute security but commit to maintaining industry-standard protection measures.

8. International Data Transfers

As eldoras operates primarily within the European Union, your personal data is generally processed within the EU/EEA. If we need to transfer your data outside the EU/EEA, we ensure appropriate safeguards are in place, such as:

• European Commission adequacy decisions
• Standard contractual clauses approved by the European Commission
• Binding corporate rules or certification schemes

9. Cookies and Website Analytics

Our website uses cookies and similar technologies to enhance user experience and analyse website performance. For detailed information about our cookie usage, please refer to our Cookie Policy.

You can manage your cookie preferences through our cookie consent banner or your browser settings. Refusing certain cookies may limit website functionality but will not prevent you from accessing basic information about our services.

10. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child without appropriate consent, we will delete such information promptly.

11. Changes to This Privacy Policy

eldoras may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of significant changes by posting the updated policy on our website and updating the "Last updated" date.

We encourage you to review this privacy policy periodically to stay informed about how we protect your personal information.

12. Supervisory Authority

If you have concerns about how eldoras processes your personal data, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ Den Haag
Netherlands
Website: autoriteitpersoonsgegevens.nl

13. Contact Information

If you have any questions about this privacy policy, wish to exercise your data protection rights, or need to contact us regarding your personal data, please contact us using the following information: