Privacy Policy

Zenth Capital B.V. respects the privacy of its participants, contacts and website visitors and ensures that all personal data is handled with strict confidentiality and security in accordance with the GDPR.

Article 1

Data Controller

The data controller responsible for the processing of personal data via this website and in the context of fund management is:

Entity: Zenth Capital B.V.
Acting as: Manager of Zenth Capital Fund
Email address: invest@zenthcapital.nl
Correspondence: Kamervoort 187, 6851 EE Huissen

Article 2

What personal data do we process?

We process personal data solely to the extent necessary for our services, communication or statutory obligations:

Contact and intake details: First and last name, email address, phone number, investor category (private, family office, holding) and any explanatory notes provided when requesting an introductory meeting or documentation.
Customer due diligence data (AML / KYC): If you become a participant: identity documents, citizen service number (BSN) where required by law, source of wealth, UBO declarations, and sanction and PEP screenings.
Financial transaction data: Bank account number (IBAN), deposits, unit balance, and tax residency.
Technical server data: IP address (anonymized), browser type, date and time of visit for the security of our web infrastructure.

Article 3

Purposes and legal bases of processing

We process your data on the basis of the following GDPR legal bases:

Necessary for the performance of a contract (art. 6(1)(b) GDPR): For processing your subscription, administration of your units, and access to the participant portal.
Statutory obligation (art. 6(1)(c) GDPR): Complying with regulatory obligations, including the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), the Sanctions Act, and tax reporting requirements (such as FATCA/CRS).
Legitimate interest (art. 6(1)(f) GDPR): For securing our systems, responding to exploratory inquiries, and improving the quality of our website.
Consent (art. 6(1)(a) GDPR): When you explicitly request to receive periodic newsletters or updates.

Article 4

Sharing data with third parties

We never sell your data to third parties. Data is shared exclusively with professional partners to the extent strictly necessary for the performance of fund management:

Stichting Bewaarder (Stichting Bewaarder Zenth Funds) for the purpose of asset segregation;
AssetCare Fund Services B.V. for the participant register and NAV administration;
Rabobank and the broker/custodian (Interactive Brokers Ireland Limited);
Auditors, legal advisors, and supervisory authorities (such as the AFM or the Dutch Tax and Customs Administration) where required by law.

We conclude data processing agreements with all external processors to ensure that your data is protected according to the same high standards.

Article 5

Retention periods

We do not retain your data longer than necessary for the purposes for which it was collected:

Exploratory contact inquiries that do not lead to an investment are deleted within 12 months at the latest.
Customer and identification files of participants are retained for at least 5 years after termination of the relationship in accordance with the AML/Wwft.
Tax and administrative transaction records are retained for the statutory tax retention period of 7 years.

Article 6

Security of your data

We apply strict technical and organizational measures to safeguard personal data against loss, misuse, or unauthorized access. This includes end-to-end encryption (TLS 1.3), two-factor authentication for managers and participants, regular security audits, and strict access control restrictions.

Article 7

Your privacy rights

Under the GDPR, you have the following rights regarding your personal data:

Right of access to the personal data we process concerning you;
Right to rectification or completion of inaccurate data;
Right to erasure ('right to be forgotten'), to the extent not conflicting with statutory retention obligations;
Right to restriction of processing and right to object;
Right to data portability.

You may submit a request via invest@zenthcapital.nl. We will respond to your request within four weeks.

Article 8

Complaints and supervisory authority

If you believe that we are not processing your personal data in accordance with the law, please contact us. You also have the right at all times to submit a complaint to the Dutch supervisory authority: the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) via www.autoriteitpersoonsgegevens.nl.