Website Privacy Policy

Sapinda Holding B.V. or any of its associated companies (see Appendix for an overview with registered numbers and addresses) ("Sapinda" / "we" / "our" / "us") is committed to protecting and respecting your privacy. This policy (together with our Website Terms of Use: /home/terms-of-use, cookies policy: /home/cookie-policy and any other documents referred to in them) sets out our interactions with your personal data when using this website (/home).

Please read the following terms carefully to understand how we will interact with your personal data.

About us

Sapinda Holding B.V. is a private limited company incorporated in the Netherlands under registration number 34355195 with a registered address of Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands. Sapinda is the data controller in respect of your personal data. This means that we are responsible for deciding how your personal data is held and processed.

If you have any questions or require any further information regarding your data and our website please contact us at privacy@sapinda.com, Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands, tel: +31 (0)20 201 4904.

Personal Data and our website

Personal data means any information about a living individual from which that individual can be identified.

Save as set out in our Cookies Policy /home/cookie-policy, Sapinda does not collect any of your personal data through your use of the website. As a result, Sapinda does not process, share, sell, transfer or store any of your personal data through or from the website.

Sapinda instructs a third party company, Emperor, to host and run the Sapinda website. Under Sapinda’s instruction, Emperor collects and processes website usage data, which potentially constitutes personal data. It does this to enable it to optimise the operation of the website. In this arrangement, Sapinda is acting as the data controller and Emperor is acting as the data processor in relation to your personal data, even though Sapinda has no access itself to that personal data.

What information is collected and how it is used

Emperor (which is engaged by Sapinda to host and run our website) collects personal data so that our website can operate effectively and provide you with the best possible service. The information collected by Emperor depends on the context of your interactions with our website. It also depends on the choices you make, for example the functions you use and your privacy settings. You may chose not to provide certain information but if you do, and that information is necessary to provide a particular feature, then you may not be able to use that feature. We will only use your personal data where we have a valid lawful basis to do so.

What information will Emperor collect about you on our behalf?

  • Device and usage data including IP addresses and device identifiers
  • Device event information including crash logs, hardware settings, browser type and browser language

How will Emperor collect information about you?

Personal data may be collected:

  • Automatically and stored in the server logs when you interact with our website
  • From your IP address
  • From cookies and similar technologies

Your use of our website is also subject to Emperor’s privacy policy which can be viewed here: http://emperor.works/cookies/

Why are Emperor processing information about you?

  • To improve user experience of our website, for example to offer you tailored content
  • Protect security of our website and to prevent fraud
  • To analyse the traffic to our website
  • To provide and improve our services

What is the legal basis for processing information about you?

To enable us to pursue our legitimate interests to:

  • understand how our site is used;
  • improve user experience of our site
  • maintain the security of our site; and
  • protect our rights

Our basis for processing personal information through cookies is consent.

More about the information collected and why

We have a duty to process personal data fairly, lawfully and in a manner that you would expect given the nature of our relationship with you. Where we have a legal basis to use your personal data without consent (as set out above), this policy fulfils that duty by giving you appropriate notice and explanation of the way in which your personal data will be used.

Where consent is required for use of your personal data we will ask you to positively opt-in. For example, our website has a cookies banner for your consent to our or a third party’s use of cookies while you use the website. You may withdraw this consent at any time.

Your personal data will only be used for the purposes that it was collected, unless we reasonably consider that it needs to be used for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing your information

You acknowledge that we may share your personal data with your consent or as necessary with selected third party service providers, such as Emperor, and other companies within our group that support us in the performance of the activities set out above. We limit access to your personal data to those third parties who have a business need to access it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We may also share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or otherwise to comply with the law.

We require all our third party service providers and all other companies within our group to take appropriate and stringent security measures to protect your personal data in line with our policies and the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

Storing your information

The personal data that held about you will only be processed and stored within the European Economic Area. We may or a third party may on our behalf transfer your personal data outside the European Economic Area (EEA). If this occurs we will take all steps reasonably necessary to ensure that appropriate measures are in place to ensure your personal data receives an adequate level of protection and is treated in a way consistent with EU and UK laws on data protection. If you require further information about these protective measures, please contact us at privacy@sapinda.com, Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands, tel: +31 (0)20 201 4904.

Your personal data will only be retained for as long as is necessary to fulfil the purposes it was collected it for, including for the purposes of satisfying any legal, accounting or reporting obligations. For example, we may retain some of your personal data for 6 years for legal reasons.

Unless we inform you otherwise (or you request that we erase your personal data) your personal data will be retained for as long as you continue to use the website. If you do not use the website for 6 years then your information will be deleted. In some circumstances your personal data may be anonymised so that it can no longer be associated with you (and you cannot be identified from it), in which case such information may be used without further notice to you.

Children’s information

We do not knowingly collect information from children under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent please contact us at privacy@sapinda.com, Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands, tel: +31 (0)20 201 4904.

Keeping your information secure

All information that you provide through our website is stored on secure servers. We have put in place appropriate measures to protect the security of your information.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the information transmitted to our site and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.

Your rights

Although Sapinda does not itself hold or process your personal data, we have set out your rights as an individual under data protection law below. Individuals have the right to access information held about them and to request its rectification or deletion in some circumstances. This right is subject to any data being held about the individual and certain conditions. A summary of your rights under the law are set out below:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data held about you and to check that it is being processed lawfully.

Request correction or erasure of your personal data (unless there is a legal right to retain it). You also have the right to ask for it to be deleted or removed where you have exercised your right to object to processing (see below).

Object to processing of your personal data where such processing relies on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object if we are processing your personal data for direct marketing purposes.

Request the restriction of processing of your personal data. This enables you to ask for suspension of the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal data to another party.

Change your data processing preferences at any time.

You should be aware that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of the website you may not be able to use the website as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

If you want to exercise any of the above rights, please contact us at, Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands, tel: 31 (0)20 201 4904 or by emailing us at privacy@sapinda.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, a reasonable fee may be charged if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data are not disclosed to any person who has no right to receive it.

In the limited circumstances where we are relying on your consent as the legal basis to process your personal data for a particular purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact privacy@sapinda.com, Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands, tel: +31 (0)20 201 4904.

Once we know that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Other websites

Our website may contain links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

Changes to this Privacy Policy

We keep our privacy policy under regular review and will post any updates on this webpage. This privacy policy was last updated in July 2018.

How to contact us and complaints

If you have any questions about this privacy policy or how we handle your personal data please contact us at privacy@sapinda.com, Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands, tel: +31 (0)20 201 4904.

If for any reason you are not happy with the way that we have handled your personal data, please contact us at privacy@sapinda.com, Schiphol Boulevard 127, G4.02, Schiphol, the Netherlands, tel: +31 (0)20 201 4904. If you are still not happy, you have the right to make a make a complaint to the Information Commissioner’s Office see: https://ico.org.uk/global/contact-us/.

Appendix: Overview Sapinda Holding B.V. Group Associated Companies

Sapinda International Services B.V. 59011548 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Sapinda International Services B.V. UK FC032165 6th floor 23 Savile Row, London W1S2ET
Sapinda International Services B.V. German Branche HRB 165531 B Friedrichstrasse 95, 16t 10117 Berlin, Germany
Sapinda Services Suisse AG CHE-392.855.726 Dufourstrasse 7, 8702 Zollikon
Sapinda Asia Pacific Holding Limited 2013823 201382337th Floor Two IFC 8 Finance Street, Central, Hong Kong
Sapinda ME I B.V. 63469057 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Sapinda ME II B.V. 63466155 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Sapinda Middle East WLL (Bahrain) 93506-1  
Centrics Oil & Gas Finance B.V. 60004851 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Civitas Properties Finance B.V. 69978549 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Civitas Properties Investment B.V. 69987998 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Degros Holding B.V. 70317569 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Degros Investment B.V. 70316155 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Kore Coal Investment B.V. 58762175 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Kore Coal Finance B.V. 53347161 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
La Perla Fashion Finance B.V. 71102191 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
La Perla Fashion Investment B.V. 71100261 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
La Perla Fashion Holding N.V. 66809681 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Voltaire Investment B.V. 71797300 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol
Voltaire Finance B.V 71800611 Schiphol Boulevard 127, G4.02, 1118 BG Schiphol