This statement may be updated from time to time, for example if we add new functionalities to our website that require the processing of personal data. The amended version will be published on our website, stating the date on which it was last updated. If the changes may significantly affect you, we will inform you thereof in an appropriate manner. 

Quadrum processes personal data about you because you use our services and/or because you have provided personal data to us yourself. 
 
Below is an overview of the personal data we process when you visit our website: 

• Location data
• Information about your activities on our website
• IP address
• Internet browser and device type  

Below is an overview of the personal data we process if you are an investor with us: 

• Name, address and place of residence details
• Telephone number
• Email address
• Date and place of birth
• Citizen Service Number (BSN), where legally permitted
• Financial personal data, such as IBAN and investment and distribution amounts attributable to you
• Tax-related personal data, such as tax identification number, tax residence and (inter)national tax status
• Data relating to your role and involvement within an organisation, insofar as relating to you personally (e.g. UBO position, function, signing authority)
• Data relating to your PEP status and any listing on sanctions lists (insofar as applicable to you personally)
• Data from identity documents, including a copy of an identity document with photograph and document details, where legally permitted
• Correspondence directly linked to you personally (such as emails and letters in connection with your investment)
• Login and account details of personal investor accounts (username, role and necessary log data such as login times)
• Your communication and marketing preferences (such as newsletter opt-in/opt-out and preferred communication channel) 

If you wish to become an investor with us, we are legally obliged to verify whether you are included on a sanctions list. In doing so, we may process special categories of personal data, such as criminal record data. In addition, where legally permitted, we process your BSN. This is considered sensitive personal data.

Our website and services are not intended for minors. If you are nevertheless convinced that we have collected personal data relating to a minor, please contact us via info@quadrum-capital.nl. We will then delete such information. 

Quadrum processes your personal data for the following purposes.

If you are a visitor to our website:

• For the (technical) maintenance of our website and to improve our website. Quadrum processes your data for this purpose on the basis of its legitimate interest in the proper functioning of its website.

If you are an investor with us: 

• To provide our services to you, including entering into and performing investment agreements and managing your investments. 
  Quadrum processes your data for this purpose because it is necessary for the performance of the agreement between Quadrum and you.
• To comply with statutory customer due diligence (CDD) and anti-money laundering obligations (such as the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), sanctions legislation and FATCA/CRS). 
  Quadrum processes your personal data for this purpose because it is necessary to comply with legal obligations that apply to Quadrum.
• To maintain accurate and complete financial records, including compliance with tax and reporting obligations. 
  Quadrum processes your personal data for this purpose because it is necessary to comply with legal obligations that apply to Quadrum.
• To perform investment analyses and reporting. 
  Quadrum processes your personal data for this purpose because it is necessary for the performance of the agreement between Quadrum and you, and on the basis of our legitimate interest in optimising our services.
• To inform you about changes in our services and products. 
  The processing of your data for this purpose is necessary for the performance of the agreement between Quadrum and you.
• To inform you about the financial position and performance of your investments, including investor reporting and capital calls. 
  The processing of your data for this purpose is necessary for the performance of the agreement between Quadrum and you and to comply with legal reporting obligations.
• To make payments, such as distributions to you and processing your payments. 
  The processing of your data for this purpose is necessary for the performance of the agreement between Quadrum and you and to comply with legal obligations.
• For customer and relationship management, including fundraising, maintaining contact records and communications, and organising investor meetings and events. 
  Quadrum processes your data for this purpose on the basis of its legitimate interest in maintaining its business relationships and, where necessary, on the basis of your consent.
• To prepare aggregated reports and internal analyses to optimise our services and business operations. 
  Quadrum processes your personal data for this purpose on the basis of its legitimate interest in improving its services.
• To record and archive decisions, minutes and other governance documents in which your data may appear, for the purposes of internal and external accountability. 
  Quadrum processes your personal data for this purpose because it is necessary to comply with legal obligations and on the basis of its legitimate interest in proper governance and record keeping.
• To send our newsletter and other information about Quadrum and its funds. 
  Quadrum processes your data for this purpose on the basis of its legitimate interest in informing existing investors about similar services and, where necessary, on the basis of your consent. 

Quadrum does not store your personal data any longer than is strictly necessary to achieve the purposes for which your data is collected. Specifically, Quadrum applies the following retention periods. 

If you are a visitor to our website, we store your data for a maximum of three months. 

If you are an investor with us: 

• We store CDD data for 5 years after the termination of the business relationship between Quadrum and you
• Other administrative and financial data in the context of our statutory administrative obligation are in principle retained for 7 years after this data is no longer current.
• CRM, relationship and marketing data (including contact history, communication preferences and subscriptions to newsletters or invitations) are retained for a maximum of 2 years after the last substantive contact, or until you unsubscribe or object to this processing, unless a longer period is necessary due to an ongoing investment relationship or legal obligation. 

We may retain your data for longer if this is necessary to protect our interests in the event of (impending) disputes and/or proceedings. 

Quadrum only provides your data to third parties if this is necessary for the performance of our agreement with you, to comply with a legal obligation or if this is necessary to protect our legitimate interest. 

If you visit our website, Quadrum for example shares data with Google via Google Analytics, so that Quadrum can measure its website performance. 

If you are an investor with us, Quadrum for example shares data with parties that process personal data on behalf of Quadrum, insofar as this is necessary for the performance of our agreement with you, maintaining accurate records and complying with legal obligations. A corresponding processor agreement has been concluded with each of these service providers. This concerns, among others: 

• IT and cloud suppliers, such as Microsoft Inc. (Microsoft) (for email, document storage and collaboration environments).
• Suppliers of investor and administration systems, such as Salesforce Inc. (Salesforce) (for relationship management and CRM) and Fundrbird B.V. (for fund administration and investor portals).
• Compliance service providers, such as Regulatory Lab B.V. (RegLab) and Trustmoore Netherlands B.V. (Trustmoore) who support us in complying with legal obligations, including Wwft/KYC and reporting obligations. 

Finally, we may share your data with other entities that are part of the Quadrum group for internal administration, risk management, and reporting. 
 

Quadrum uses functional cookies. A cookie is a small text file that is stored in the browser of your computer, tablet or smartphone when you visit this website for the first time. Quadrum uses cookies with a purely technical functionality. These ensure that the website works properly and can for example remember your preference settings. We can also optimise our website with this. 

You have several rights when we process your data:

• Right of access: You have the right to know whether and if so, which personal data we process about you and in what way. You can also request a copy of this data.
• Right to rectification: If your personal data is incorrect, you can request correction.
• Right to erasure: In some cases you can ask us to delete your personal data.
• Right to restriction of processing: You can ask us to (temporarily) stop using your personal data in certain cases.
• Right to data portability: You can ask us to receive your personal data that you have provided to us in a structured, common and machine-readable form and to transfer it to another organisation.
• Right to object: In specific situations you can object to the processing of your personal data, for example when we process it on the basis of a legitimate interest.
• Right to withdraw consent: If we process your personal data on the basis of your consent, you can withdraw this consent at any time. This does not affect the lawfulness of the processing prior to the withdrawal. 

You can send a request to info@quadrum-capital.nl. Quadrum will respond to your request as soon as possible, but no later than within four weeks. In this context, Quadrum may ask you to provide additional information with which Quadrum can verify your identity, to prevent personal data from being provided to the wrong person. This may for example concern your name, address and place of residence or other data necessary to establish your identity with reasonable certainty. Quadrum uses this data exclusively for verification purposes and does not retain it longer than necessary. 

Finally, you have the right to file a complaint with a supervisory authority. In the Netherlands, this can be done with the Dutch Data Protection Authority via https://autoriteitpersoonsgegevens.nl/. 

Quadrum takes the protection of your data extremely seriously and takes appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modifications. 

Personal data are in principle not transferred to countries outside the European Union. If in exceptional cases there is a transfer, this is done in accordance with the GDPR. For more information about the appropriate safeguards we have implemented to ensure that the transfer takes place in accordance with the GDPR, you can contact Quadrum's Privacy Officer via the contact details in section 10 below. 

A data subject who believes that Quadrum is acting in breach of this statement or the GDPR may contact Quadrum's Privacy Officer via: 

Quadrum Fund Management B.V.  
Attn: Privacy Officer 
Wierdensestraat 2A 
7607 GH Almelo 
T: 085 -273 83 18 
E: info@quadrum-capital.nl 

 This statement was last amended on 27 May 2026.