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Privacy statement

This privacy statement describes how Van Lanschot Kempen N.V. (Van Lanschot Kempen) handles personal data. Van Lanschot Kempen holds the shares in Van Lanschot N.V. You will find Van Lanschot N.V.’s privacy statement at www.vanlanschot.nl/privacy (in Dutch only).

1. When may we change this privacy statement?

Van Lanschot Kempen may change this privacy statement. We will always inform you in advance of any major changes.

2. What are personal data?

Personal data are details revealing information about an individual, such as a name, address or telephone number.

3. What does ‘processing personal data’ entail?

This refers to anything that Van Lanschot Kempen may do with personal data, e.g. collecting, viewing, destroying or storing.

4. How we handle personal data

Your privacy is important to us. We comply with all applicable laws and regulations, including the General Data Protection Regulation (GDPR) and its Dutch Act to enact the GDPR. We handle personal data responsibly and with due care, and will never sell personal data to third parties.

5. Does this privacy statement also cover your personal data?

We process personal data of shareholders and their representatives, visitors to our website, interested investors and anyone else interested in Van Lanschot Kempen and/or their representatives. This privacy statement explains what Van Lanschot Kempen can process, including which personal data and for what purposes. The table at the bottom of this page (pdf) shows the categories of personal data that we can process, depending on the situation.

6. How we safeguard personal data

It is crucially important that your and our information is safe and secure, and our security measures comply with relevant standards. The Autoriteit Persoonsgegevens (the Dutch Data Protection Authority, Dutch DPA) supervises all our security measures.

7. How we handle data breaches

A data breach implies that personal data might end up where they do not belong. We report any data breaches to the Dutch DPA, but will not do so if there is no risk to you. We will also inform you when necessary of any risks you might run. Risks include such things as identity theft or fraud. In such cases we will let you know what has happened and what the repercussions are or may be for you. We will also tell you about the measures we have taken to mitigate any adverse consequences.

8. What you may ask of us regarding your personal data

This section describes what your rights are with regards  to your personal data. The law determines which requests we can honour. Please be aware that we cannot always assist you.

You can ask a question by contacting the personal data protection officer at privacyofficer@vanlanschotkempen.com. We will reply as soon as possible. Questions are answered free of charge unless dealing with them constitutes an exceptional burden, for instance if you keep repeating the same question within a short period of time. We will advise you beforehand if we will charge you for dealing with your question.

a. Improving or supplementing personal data

You have the right to ask Van Lanschot Kempen to amend or supplement personal data if these are incorrect or incomplete.

b. Access to personal data

You have the right to ask Van Lanschot Kempen to show you the personal data we have collected about you and to receive a copy of your personal data. You also have the right to ask how we process your personal data, including the purpose of such processing and any categories of personal data.

c. Deleting personal data

You have the right to obtain deletion of your personal data, for instance if the personal data are no longer necessary or if you have withdrawn permission for using your personal data.

d. Objecting to processing of personal data

You have the right to object to certain types of personal data processing. This is only possible if we base such a process on a legitimate interest (we set out when this is the case under ‘9. For what purposes do we process personal data?’), in cases of direct marketing or for personal data informing statistics.

e. Restricting processing

You have the right to ask for a temporary halt to processing of your personal data, for instance if we, at your request, look into the correctness and/or completeness of personal data or if we process personal data without being allowed to. You also have a right to request this if you think you need the data for legal proceedings or if you have objected to processing.

9. For what purposes do we process personal data?

Van Lanschot Kempen processes personal data for many different reasons. Please read on to find out more.

a. Annual and extraordinary general meetings of shareholders

We process personal data related to regular or extraordinary general meetings of Van Lanschot Kempen shareholders, for instance when registering shareholders prior to and for the purpose of voting at such meetings and recording proceedings in minutes. We are permitted to process personal identification details for this purpose as we comply with legal requirements by holding shareholder meetings.

b. Nomination, appointment or reappointment of directors and members of the Statutory, Executive and Supervisory Boards

We process personal data of Van Lanschot Kempen Board and Supervisory Board members related to their nomination, appointment and reappointment, for instance for the purpose of regulatory screening. We are allowed to process these personal identification data and personal details, as this is a legal requirement.

c. Communication with existing and potential shareholders, and other interested parties

We process personal data of existing and potential shareholders in Van Lanschot Kempen in order to be able to communicate with them. We also process personal data of people interested in Van Lanschot Kempen – e.g. journalists – to be able to send them information periodically, such as media and press releases about Van Lanschot Kempen. We are permitted under law to process personal identification data for this purpose, as it is in our legitimate company interest to communicate with such persons. An individual has the right to object, for personal reasons, to us processing personal data based on this interest.

d. Promotion and marketing

Van Lanschot Kempen’s promotion and marketing activities, such as roadshows, mainly aim to reach potential new shareholders and to maintain relations with existing shareholders, by Investor Relations for instance. We are permitted to process personal identification data and electronic identification data for such promotion and marketing activities; we have a company interest in promotion and marketing, as these support Van Lanschot Kempen’s corporate activities. An individual has the right to object, for personal reasons, to us processing personal data based on this interest. There is more on how you can object under ‘8. What you may ask of us regarding your personal data’.

e. Secretarial office for Stichting Administratiekantoor and Stichting Pref C

We process the personal data of the directors of Stichting Administratiekantoor van gewone aandelen A Van Lanschot Kempen and Stichting Preferente aandelen C Van Lanschot Kempen for the purpose of running their secretarial offices. We have a company interest in the smooth operation of both companies, which are independent of Van Lanschot Kempen. An individual has the right to object, for personal reasons, to us processing personal data based on this interest.

f. Complying with legal obligations

We process personal data in order to comply with certain legal obligations. Read on for more information.

  • Legal data-keeping requirements
    We are legally obliged to keep certain personal data, e.g. personal data included in the annual report, in documentation related to general and extraordinary meetings of shareholders, and documentation on screening directors and Supervisory Board members.

  • Disclosure requirements and information requests
    We are legally obliged to pass on personal data in our possession to a government body, a tax authority, a regulator or officers of the law, either at our own initiative or on request. The Dutch authorities may subsequently share such personal data provided by us with other domestic or foreign authorities. Foreign legislation may also require us to disclose information to foreign authorities.

g. To ensure the security and integrity of the financial sector and to prevent and counteract fraud

Fraud investigations are another way to ensure the security and integrity of the financial sector, and third parties may be invited to help conduct such investigations, e.g. lawyers or forensic accountants. We are permitted to process personal data for this purpose as we are obliged under law to conduct our business safely and with integrity, and because this is in the legitimate interest of our shareholders, the financial sector, our employees and ourselves as a company.

10. Disclosure of personal data to third parties

We may give your personal data to third parties but will only do so to make Van Lanschot Kempen’s corporate processes more efficient. We use an independent party to receive voting instructions from shareholders looking to vote at our general or extraordinary meetings of shareholders. Van Lanschot employees will conduct the activities as described in this privacy statement, as Van Lanschot Kempen does not actually have any employees.

11. How long we keep personal data

We observe maximum periods for keeping personal data, as listed in the table at the bottom of this page (pdf). Personal data are destroyed after these maximum periods. These retention periods can only be extended in the event of an ongoing complaint, procedure or – legal or regulatory – investigation into the individual. Personal data kept at third parties are subject to the same retention periods. Our cookie statement lists the retention periods applicable to the different types of cookies.

12. Cookies

Read our cookie statement to find out how we handle your personal data processed through cookies.

13. Questions and complaints

For general questions, remarks or complaints about this privacy statement, please contact the personal data protection officer at privacyofficer@vanlanschotkempen.com.

If you feel your rights have been violated by Van Lanschot Kempen, you can file a complaint with the Dutch DPA.

You can address any other questions you may have to Investor Relations, Mondays through Fridays between 8.30 am and 5.00 pm.
Telephone: +31 20 354 4590
Email: investorrelations@vanlanschotkempen.com

 

14. Where to find more information on privacy

For more general information about privacy, please consult the Dutch DPA’s website.

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