Privacy Policy

Introduction

SummitEngine B.V. ("we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains what data we collect, how we use your information, and your rights regarding your personal data when you use our financial advisory services and visit our website at summitengine.pro.

As a company registered in the Netherlands and operating within the European Union, we comply with the General Data Protection Regulation (GDPR) and Dutch data protection laws.

Data Controller Information

SummitEngine B.V. acts as the data controller for the personal information processed under this Privacy Policy. You can contact us regarding any data protection matters:

Data Collection

The data we collect depends on how you interact with our services. We collect personal information through various means to provide our financial advisory services effectively.

Information You Provide Directly

• Contact details (name, email address, phone number, postal address)
• Financial information (income, assets, investment portfolios, tax returns)
• Professional information (occupation, employer, business interests)
• Personal circumstances (family situation, financial goals, risk tolerance)
• Communication records (emails, meeting notes, consultation records)
• Identity verification documents (as required by financial regulations)

Information We Collect Automatically

• Website usage data (pages visited, time spent, click patterns)
• Device information (IP address, browser type, operating system)
• Cookies and tracking technologies (as detailed in our Cookie Policy)
• Referral sources and marketing campaign effectiveness data

How We Use Your Information

We process your personal data based on various legal grounds under GDPR. How we use your data depends on the specific information collected and the context of collection.

Service Provision

We use of your data to provide our financial advisory services, including financial planning, tax optimisation strategies, investment advice, and wealth management solutions. This processing is necessary for the performance of our contract with you.

Legal and Regulatory Compliance

We process personal data to comply with legal obligations, including anti-money laundering requirements, tax reporting obligations, and financial industry regulations applicable in the Netherlands and European Union.

Communication and Support

We use your contact information to respond to enquiries, provide customer support, send service-related notifications, and maintain ongoing communication about your financial planning needs.

Marketing and Analytics

With your consent, we may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your browsing experience, analyse website performance, and deliver personalised content and advertisements. We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use, their purposes, and how to manage them, please refer to our comprehensive Cookie Policy.

Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your data only in the following circumstances:

• With your explicit consent
• To comply with legal obligations or respond to legal requests
• With trusted service providers who assist in delivering our services (subject to strict confidentiality agreements)
• In connection with a business transfer, merger, or acquisition (with appropriate data protection safeguards)
• To protect our rights, property, or safety, or that of our clients or the public

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

• Client financial records: Retained for 7 years after the end of our professional relationship, as required by Dutch financial regulations
• Marketing and website analytics data: Retained for up to 2 years unless you withdraw consent earlier
• Communication records: Retained for the duration of our professional relationship plus 3 years
• Legal and compliance records: Retained as required by applicable laws and regulations

Your Rights

Under GDPR and Dutch data protection law, you have several rights regarding your personal data:

• Right of access: Request copies of your personal data
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your data under certain circumstances
• Right to restrict processing: Request limitation of how we process your data
• Right to data portability: Request transfer of your data in a structured format
• Right to object: Object to processing based on legitimate interests or for marketing purposes
• Right to withdraw consent: Withdraw consent for processing where consent is the legal basis

To exercise any of these rights, please contact us at privacy@summitengine.pro or +31 10 311 3325. We will respond to your request within one month of receipt.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and staff training on data protection
• Secure storage and backup procedures
• Regular monitoring for security breaches

International Data Transfers

We primarily process your data within the European Economic Area (EEA). If we transfer your data outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or adequacy decisions by the European Commission.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your data protection rights, or need to contact us regarding any privacy-related matters, please reach out to us:

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or your local supervisory authority.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by sending you a notification. The "Last Updated" date at the top of this policy indicates when it was last revised.

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your personal information and respect your privacy rights.