Privacy statement

Privacy statement

FMO is committed to protecting the privacy and security of your personal information. This statement applies for the visitors of our website and events, job applicants, customers and other relations.

In this privacy statement we explain why and how we use your personal information, your rights regarding this data, and the protections we have in place to safeguard it. 

 In this privacy statement you can read: 

  1. What personal information we collect, use and store
  2. Why we use your personal data
  3. How FMO collects the information
  4. The legal basis for processing your data
  5. How long FMO keeps your information
  6. With whom FMO shares your information
  7. How we protect your personal data
  8. What privacy rights you have
  9. How and when we update this privacy statement


1. What personal information we collect, use and store

Website analysis

When you visit our website, we will anonymously analyze which pages are visited, how long visitors are on each page, and where visitors leave the website. We cannot see or identify who you are. We also collect information when your browser is providing this to us, such as what time somebody visits the website, what device is being used (such as a tablet, phone, or desktop computer), from which country and other data. This data can also not be linked to you.

Contact or complaint form

Our website offers the possibility to contact us or fill in a complaints form. Information we can collect and use are: your name, e-mail address, region and country, finance needed (amount), your question or complaint.

Events of FMO

From registrants the following data are stored: your name, address, residence details, phone number, e-mail address or other electronic communications, gender and / or age. Sometimes we need specific information to be able to organize the events, such as which seminars you would like to attend, dietary wishes and other information.

Job applicants/candidates:

FMO records personal data of candidates that may be interested in working with FMO. If you apply through our website, we will store the information that you provided us, such as your name, contact details, information in your cv and motivation letter.

Clients, Prospects and Relations:

FMO records contact details, such as names, e-mail address and mobile phone number of our clients and relations. This also includes know your customer data (passport).


2. Why we use your personal data

Subject to applicable law, your personal data may be stored and processed by us or one of our dedicated partners for the following purposes:

Recruitment and selection

  • identifying, screening and evaluating applicants for potential employment;
  • record keeping in relation to recruitment and hiring
  • performing integrity and reliability screenings through an external partner
  • using your information to send an offer and/or contact you about your application
  • storing your CV with your consent for open positions

Clients, Prospects and Relations

  • To be able to contact you and discuss and analyze investment possibilities
  • To send relevant news updates
  • When we do have a contract: to perform the services as agreed in the contract and the administration (tax and financial) in relation to the services
  • As part of our legal obligations we need to screen our customers and its UBOs to prevent fraudulent conduct or behavior, tax fraud, anti-money laundering and anti-terrorism finance.
  • To do audits, and, in case of conflicts, the settlement of the disputes
  • When you are visiting our building, information can be stored such as access times and CCTV coverage

Website, Complaints and Contact Form

  • We use your information to be able to answer your question or contact request
  • To find a solution for complaints and communication about the complaints process, and outcome of your compliant.
  • When you raise a complaint as a whistleblower, we have a strict procedure and will not reveal your identity unless you have provided us with consent
  • To make the website user-friendly and improve the user experience. For analyzing the FMO website is placing cookies on your computer, mobile phone or other device. Some cookies are only placed after you give us explicit consent. Please read our cookie statement for more information about the cookies.
  • For your convenience, we have provided links to certain third-party web sites, and/or videos. If you choose to visit a third party's site, please be aware that the third party's privacy policy, and not FMO's, will govern your activities and any information you disclose while visiting their site. Please consult their privacy statements to know how how they treat your privacy.

Events

  • We use your contact details to send you information about the event (before and after) and to organize the event. Sometimes we organize the event with partners. In that case you are informed in advance on the events information website.

Responding to legal and regulatory requests

  • To comply with lawful requests by public authorities, disclosure requests, or where otherwise required or authorised by applicable laws, court orders, government regulations, or regulatory authorities, such as the Dutch State Bank (DNB)


3.
How FMO collects the information

We collect your personal information from a variety of sources, but in most situations, directly from you. You will usually provide this information through our contact form, information request or when you receive an investment from us.

We may also obtain some information from third parties, e.g., partners with whom we do a joint investment deal, Google searches (as part of our screening obligation) or other means.

In some circumstances, personal information may be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, CCTV).

Where we ask you to provide personal information to us on a mandatory basis, we will inform you of this at the time of collection. Should the information be required by the contract or statute, this will be indicated. The failure to provide mandatory information will mean that we cannot carry out certain services. For example, without requested Know Your Customer (KYC) screening information we cannot invest in your company or project.


4. The legal basis for processing your personal data

We are only using your personal data when it is allowed by law. We will use the following grounds:

- Performance of a contract
We may need to collect your personal information to enter a contract with you or to perform the contract that you have with us. For example, when we invest in your company, we need to use personal information for the execution of the deal.
- Consent
Where required to obtain your consent, we always ask you explicitly for that consent. For example, if we want to store your cv for longer than 4 weeks, we will ask you whether we may store it for one year. We only will share your personal information to event partners after consent.
- Legitimate interest
We may use your personal information for our legitimate interests to improve our products and services, for example analysing website behavior.
- Legal obligation
We may process personal information as necessary to comply with our legal obligations, such as processing personal data for screening purposes in accordance with anti-terrorist and money laundry legislation.


5. How long FMO keeps your information

We will store your personal information for as long as is required or reasonably necessary for the purposes for which it was collected, as explained in this Privacy Statement, and in accordance with our Personal Data Retention schedule.

In some circumstances we may have to store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting, or necessary technical requirements. In that case we will follow the retention periods required by law and the personal data retention schedule


6.
With whom FMO shares your information

For the above purposes, personal information may be transferred within or outside of the jurisdiction, either within FMO or to third parties, including, but not limited to:

  • certain third parties including suppliers and service providers. We have in place certain agreed additional safeguards to protect your information and have agreed data processing agreements with our suppliers.
  • FMO may disclose personal information when required by law or court order, or as requested by any government, regulator, or law enforcement authority/agency.
  • Sometimes we organize the event with partners. In that case you are informed about the possible sharing of information to these partners.

Where FMO transfers personal information internally within FMO or to any third party between different jurisdictions, including, but not limited to, transfers outside of the European Economic Area (EEA), and to other jurisdictions that have not been deemed to offer adequate protection, for the purposes outlined in this document, we will take appropriate steps to ensure that there is an adequate level of protection for personal information in place in accordance with applicable legal requirements. (For example, concluding additional contracts or (technical) measures in case of transfers outside the EEA.)


7.
How we protect your personal data

Personal Data held by us will be kept confidential in accordance with Data Protection Laws and applicable FMO policies and procedures.

We will take appropriate security measurements to ensure that Personal Data is kept secure and safe from any loss or unauthorized disclosure or use.

(Suspected) data leaks can be reported through DPO@fmo.nl.


8. What privacy rights you have

You have a number of legal rights in relation to the personal data that we hold about you.

These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you
  • the right to withdraw your consent to our processing of your personal data at any time.
  • in some circumstances, the right to receive some personal data in a structured, commonly-used and machine-readable format and/or to request that we transmit those data to a third party, where this is technically feasible.
  • the right to request that we correct your personal data if it is inaccurate or incomplete,
  • the right to request that we erase your personal data in certain circumstances.
  • the right to request that we restrict our processing of your personal data in certain circumstances.
  • when we are processing on the grounds of legitimate interest, the right to object to the processing, meaning we must stop unless we have an overriding reason which will be communicated to you.

How to exercise of your rights

If you would like to exercise any of these rights, or you have any concerns about how your Personal Data is handled by us, or wish to raise a complaint on how we have handled your Personal Data, you may contact us via email at: DPO@FMO.nl.

Privacy complaints

If you have a complaint, we’d like to hear about it so we can find a solution first. You always have the right to lodge a complaint with the applicable data protection authority.

To protect your privacy, we will take steps to verify your identity before fulfilling your request; this can mean that we ask you to meet us in person in the office or ask you to identify yourself first.


9. How and when we update this privacy statement

FMO can change the privacy statement at any moment. We will make an announcement of these changes on our website. Older versions of our privacy statement will be stored in our archives. To view an older version of the privacy statement, please contact info@fmo.nl.

More information Questions about this privacy statement can be directed to our data privacy officer DPO@fmo.nl.

You can also reach us at the following address:  

FMO - Netherlands Development Finance Company
Privacy Officer/ Compliance department
Anna van Saksenlaan 71
2593 HW The Hague
The Netherlands

Version January 2022