Privacy Policy

PRIVACY POLICY



Updated as on February 1, 2019


This is the Privacy Policy for Global Impact Platform, accessible from www.globalimpactplatform.com


PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO VISIT OR USE OUR SERVICES, YOU ARE AGREEING TO THE USE OF THE TECHNOLOGIES FOR THE PURPOSES DESCRIBED IN THIS POLICY. THIS POLICY HAS BEEN UPDATED TO COMPLY WITH THE GENERAL DATA PROTECTION REGULATION (GDPR) EFFECTIVE FROM MAY 25, 2018. 


Phenix Impact Development B.V., a wholly owned entity of Phenix Capital Group B.V., (for the purpose of this policy - “Phenix Capital”, “we”, “our”, “us”) respect your privacy and are committed to protecting it.


GLOBAL IMPACT PLATFORM IS A PRODUCT OF PHENIX CAPITAL. This Privacy Policy (“Policy”) is applicable to this website – www.globalimpactplatform.com (the “Site(s)”) and governs the privacy of its users (for the purpose of this Policy – “visitors”, “customers”, “you”, “your”) who choose to visit the website.


Our Policy provides information with respect to any data or information that relates to or can be associated with an individual and sets out the basis on which any personal data you provide us or we collect from you (“Personal Data” or “Personal Information”), will be shared or processed by us. 


Who are we?

Founded in 2012, Phenix Capital is a leading investment consultant specializing in impact investing headquartered in Amsterdam. The team has 200 years of combined experience in working with pension funds, banks, asset managers and foundations. Phenix Capital has a dedicated team of research analysts focusing exclusively on sourcing and assessing impact investment funds. The Global Impact Platform is a proprietary database providing information on 450+ fund managers and 750+ impact investment strategies. By showing information on open and close funds of fund managers who are active in the space we aim to provide a comprehensive overview of the market. Also know more about us on www.phenixcapital.nl.


How do we collect your data?

When you use or interact with us through our Sites or our services, we may collect your Personal Data and other data, provided to us either voluntarily or via automated means as visitors navigate through our Site.


One or more of the following means may collect this data:


  1. We may ask you to complete surveys for research purposes.
  2. Information you provide by filling in the registration and/or subscription forms.
  3. Data or information our researchers gather from the information publicly available such as regulatory filings, social media, company websites etc. 
  4. If you contact us, we may keep a record of your correspondence with us.
  5. If you register to attend any of our events, we may ask you certain Personal Information and you may be required to create a password. 
  6. If you apply for a job with us and submit a job application with us.
  7. To send you newsletters for keeping you educated and updated on the impact world and to bring to you what new products/services we are bringing.
  8. To carry out our obligations arising with you through you subscription to our services.
  9. To notify you of any updates, changes or new additions to our services at our discretion.
  10. To ensure that content from our Site is useful and presented in the most effective manner for you and your computer/device.
  11. To provide you with information, products or services that you request from us. 
  12. To send invitations for events organized by us, send you email, follow-up questions about your participation in the event and administer interests.
  13. To send surveys in order to support our research and analyze use of, interest in, our products, services or content offered by us.
  14. For promotions to our services and new services being introduced which may be of interest or useful for you.
  15. To better tailor the Site experience to visitors interests, user or customer interests and display content according to user functionality. 
  16. To communicate with visitors and customers by e-mail, telephone, postal mail and/or mobile devices about products or services that may be of interest and that are offered by us, our affiliated companies.
  17. We may share your information with our third parties to provide services contained on our Site. 
  18. We use Google analytics to track number of visits to our site and improve our website. 
  19. We may store your Personal Information in locations (servers or databases with hosting service providers) outside the direct control of Phenix Capital.
  20. We may also transfer or assign such information as necessary in case of change in third party service provider, divestitures, mergers or dissolution.
  21. We may share your Personal Information with third parties that perform support services to facilitate your transactions with Phenix Capital only to the extent necessary for the purpose of processing your payments, refunding your payments or dealing with complaints and queries relating to such payments and refunds.

[We will use commercially reasonable efforts to safeguard such information. You shall be responsible for maintaining the confidentiality of your subscription data. You shall notify Phenix Capital in a timely manner of any (known or suspected) breach of security, including loss, theft, or unauthorized use or disclosure of your password.]


What type of data do we collect?

Personal Data: For all users we collect the following details- your full name, your email id, your employer/ organization, your job title, your country, your credit card details, your address, your work phone number, your password for the purpose of login to the website, your geography/location, billing information to process your subscription, your IP address any other data or information which may not be Personal Data but may become Personal Data if combined together with another non-personal information. 

Additionally, user-provided information may include the amount and purpose of your investment, investment objectives, the sectors and geographic location of interest to you for impact investing and any other information you provide about your organization and investments available to and searchable by the public on the Site, and this information may be downloaded or exported by the public from the Site.


Non-personal data or other data: We may collect non-personal data which may include certain technical data sent to us from the mobile device, computer used by you, geography, statistics of your activities, survey popular content, traffic source, location data, weblogs and other communication data, search engine query, or any other data collected by cookies. 


Record of correspondence: We may collect and record copies of any correspondence you have/had with Phenix Capital.


How we use the data we collect?

Under the General Data Protection Regulation, we have legitimate business interests “Legitimate Interests” to process your Personal Data and professional information is to research and analyze the investment trends in the impact investing space align and provide necessary infrastructure to the with the UN SDGs.

We use the data collected for the following purposes listed below on the basis of your consent and/or our Legitimate Interests:


Sharing your Personal Data with others:

Phenix Capital takes the privacy of our Users very seriously, and we do not sell, rent, or otherwise provide your personally identifiable information to third parties, except as described in this policy.


Affiliates or subsidiaries: We may share your Personal Information to any member of our group of companies, i.e., Phenix Capital Group, and its subsidiaries or affiliates.


Agents and/or Service Providers/ Third Parties:


Legal Requirements: We may share your Personal Information with third parties as permitted by, or to reasonably comply with applicable laws and regulations or legal request; to protect against fraud, security or any other issues; safety or vital interests of any natural person; to cooperate with law enforcement or regulatory authorities and to protect Phenix Capital’s rights or property. 


Disclaimer

PHENIX CAPITAL IS NOT RESPONSIBLE FOR THE COLLECTION, USAGE AND DISCLOSURE POLICIES AND PRACTICES (INCLUDING THE DATA SECURITY PRACTICES) OF OTHER ORGANIZATIONS, OR ANY OTHER COMPANY, INCLUDING APP DEVELOPERS, APP PROVIDERS, SOCIAL MEDIA PLATFORM PROVIDERS, OPERATING SYSTEM PROVIDERS, WIRELESS SERVICE PROVIDERS OR DEVICE MANUFACTURERS, INCLUDING ANY PERSONAL INFORMATION YOU DISCLOSE TO OTHER ORGANIZATIONS THROUGH OR IN CONNECTION WITH THE APPLICATIONS.


Disclosures

We may provide non-identifiable Personal Information to our third parties/contractors for the purpose of providing and maintaining our services. We use reasonable efforts to limit the use of such shared information solely for this purpose and to use other appropriate confidentiality and security measures. 


International Transfer of data

The hosting facilities for our website is situated in the EU. Any transfers of the to countries outside of the EU will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. 

We may send your Personal Data outside the jurisdiction from which it was collected or originated. Where Personal Data is transferred or accessed outside of a specific jurisdiction, we ensure that appropriate safeguards are in place to comply with the applicable data protection regulations under Article 45 and 46 of the 


General Data Protection Regulation.

You acknowledge that Personal Data that you submit for publication through our Site or services may be available, via the internet, globally. We cannot prevent the use (or misuse) of such Personal Data by others.


Steps we take to protect your data

We limit access to your Personal Information to authorized Phenix Capital employees, agents or third parties. Follow stringent standards of privacy. We maintain reasonable physical, electronic and managerial procedures to safeguard and secure your Personal Information. 

We also use specialized technology such as firewalls and implement controls to authenticate and protect information during transmission through various means, including, where appropriate, encryption.

However, it cannot be assured that these security measures will prevent any unauthorized interception of or access to your Personal Information and you hereby agree not to hold the Phenix Capital liable for use of your Personal Information obtained in any unauthorized manner.


Retention and destruction of your Personal Data

We take all due reasonable steps to ensure the accuracy of the information we hold about you. We will not use your Personal Information unless it is accurate and up to date to the best of our knowledge.


We will only retain your up-to-date Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting (billing/taxation related), research or reporting requirements. To determine the appropriate retention period for Personal Data, we take into consideration the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means and the applicable legal requirements.


Your Personal Data for any purpose will not be stored with Phenix Capital for longer than it is necessary for the purpose it was collected for. 


In certain cases it is not possible for us to specify in advance the periods for which your Personal Data will be retained. In such cases, we will continue to review the requirement of keeping such data and upon a decision that it is no longer necessary for the processing purposes, we will delete the data.


We may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.


An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to us at info@globalimpactplatform.nl. If you request us to remove the data, we will respond to their request within 30 days.


Your rights:


  1. Right to Information and Access to the Personal Information being used 
  2. Right to consent
  3. Right to withdraw consent
  4. Right to object to direct marketing
  5. Right to rectification and erasure – You may ask us to correct any errors or delete your Personal Information (whole or in parts) that we hold
  6. Right to object or restrict our processing of your information
  7. Request a copy of your Personal Information

Opt-out: You may opt out from receiving email communications or text messages from us at any time by emailing us at info@globalimpactplatform.com or by clicking “Unsubscribe” on our Site.


Please note that you cannot opt-out of receiving service messages from Phenix Capital whilst you are contractually liable to receive those services. You can only opt-out to receive such messages once you have cancelled or stopped receiving such services from us.


Cookie Policy:

When you visit the Site, we may send one or more “Cookies” - small text/data files - to your computer to uniquely identify your browser, remember some specific information on the Site and let the Phenix Capital help you log in faster and enhance your navigation through the Site. To know more, please refer to our Cookie Policy.


Security

Although we will use our reasonable commercial efforts to protect your Personal Information, we cannot guarantee the security to such information. This is due to the fact that the transmission of data over the internet is never 100% secure. After receiving your data we use strict security measures to try to protect it against loss, misuse, unauthorized alterations or interception when transferred electronically. We maintain physical, electronic and procedural safeguards including the use of encryption technologies to protect your confidential information. 


Changes to the Policy

We reserve the full right and sole discretion to amend, update, change or modify this Privacy Policy at any time, with or without prior notice to the user. The revised Policy shall be effective immediately, once posted on the Site. If any material changes are made, you will be informed/ or notified at our sole discretion by either of the following method - on our website, by newsletter, by blog post, by email or any other method we deem fit for such information. You are required to visit our website periodically to review our Policy and learn or any revisions. If you visit any other site referred on the Site, it shall be governed by the privacy policy of such sites visited. Our Privacy Policy only governs this Site does not cover any other sites referred by it.


Dispute Resolution & Governing Law

If you feel that the Phenix Capital is not abiding by its posted privacy policy, you should contact us by email at info@globalimpactplatform.com

By accessing this Site, you and Phenix Capital agree that all matters relating to your access to, or use of this Site shall be governed by and construed in accordance with the laws of The Netherlands, without giving effect to any principles of conflicts of law. All disputes regarding this privacy policy will also be resolved under the law of The Netherlands.


Links to other websites

We are not responsible for the privacy policies of any sites linked to or from the Site or any site that you use to access this Site. Please consult the respective privacy policies associated with these sites for more information on their privacy policies and for instructions on how to opt-out of certain practices. This Privacy Policy does not apply to, and we cannot control the activities of, such other web sites.


Contact Information:

If you have questions or comments about this Privacy Policy, please contact us at info@globalimpactplatform.com

Alternatively, if you have questions or comments please send them to us at:

Phenix Capital

Barbara Strozzilaan 101,

1083 HN Amsterdam


or, email to


info@globalimpactplatform.com