Privacy Statement

ILX Management B.V. (“ILX”), registered at Olympisch Stadion 10, 1076 DE Amsterdam, is responsible for the processing of personal data as outlined in this privacy statement. 

This privacy statement aims to provide you with information about our Data Protection Policy with regard to privacy and personal data protection as envisaged in the General Data Protection Regulation (GDPR) (2016/679 of 27 April 2016 – the “Regulation”). 

ILX is an Amsterdam-based fund manager and qualifies both as a data processor (verwerker) and a controller (verantwoordelijke) for the purposes of the Regulation. 

The ILX Data Protection Policy ensures that ILX processes personal data in accordance with the principles of lawfulness, security, transparency, fairness, accuracy, purpose, and storage limitation. 

The data we collect serves a specific, legitimate purpose and is never utilized in ways that deviate from these original intentions, ensuring purpose limitation. 

Our approach to data processing is focused on extracting only the most relevant information needed to fulfill the intended purposes and we make sure that the personal data is treated with utmost fairness and security. ILX actively monitors modifications in legislation related to personal data protection to ensure compliance, and processing data, in a lawful, equitable, and transparent manner. 

What is personal data? 

Personal data encompasses any data that can identify an individual. An individual is considered identifiable if their identity can be reasonably established without disproportionate effort. This includes both data directly identifying a person (e.g., name and address) and data allowing indirect identification of a person (e.g., pseudonymous data, IP addresses, etc.), all of which fall under the category of personal data. 

Personal data and special and/or sensitive personal data processed 

ILX processes your personal data because you provide them to us (e.g. name, telephone number, e-mail address, and date of birth). 

ILX processes your special and/or sensitive personal data (e.g., race, criminal history, financial data, or biometrics) because you willingly shared this information with us.  

Our website and/or services do not intend to collect data from website visitors who are younger than 16 years of age unless they have permission from their parents or guardians. However, please note that we do not have the means to verify the age of our visitors, including whether they are older than 16. Therefore, we strongly encourage parents and guardians to actively engage in and monitor their children’s online activities to ensure that data about them is not collected without the proper consent of parents or guardians. If you are convinced that we have collected personal information about a minor without appropriate permission, please contact us via compliance@ilxfund.com and we will promptly delete this information. 

For what purpose and on what basis do we process personal data?  

ILX only processes data for specific purposes and based on explicit consent from the Data Subject(s), or based on any other legal ground as specified in Article 6 of the Regulation. If we had collected your data, it would have been for one of the following explicit purposes:

  1. Because you are or want to become our business relationship (e.g. client, investor), or business partner. To conduct business with you we will also process business information such as information on legal entities, job titles, and background details. Additionally, ILX may also obtain business-related personal data from external sources, such as compliance tools, the local commercial registry, or, from sources used as part of other legal and compliance checks aimed at preventing corruption, identity theft, financial fraud, money laundering and/or terrorist financing; 
  2. Because you are or want to become an employee of ILX. 
    We process personal information necessary to establish and maintain an employer-employee relationship. This enables us to communicate effectively and fulfill our legal obligations as an employer;
  3. In instances where ILX is legally mandated and obliged to collect and share your data, we will do so. This may involve sharing personal data with entities such as fiscal authorities, local government bodies, and investigative authorities (e.g., the Police, Public Prosecution Department, or the National Privacy Regulator). These actions are taken solely in accordance with legal requirements. 
  4. Because you complete a Contact Form on our website (www.ilxfund.com); This enables us to have contact information of you to address your question or request delivered to us through the Contact Form. 

Any request for your personal data will always specify the purpose for which we collect such data. 

How long do we store personal data? 

ILX retains your personal data only for a duration strictly necessary to fulfill the purposes for which the data is collected and/or as or as mandated by applicable laws, regulations, or relevant regulatory authorities. 

Sharing personal data with third parties 

ILX does not engage in the sale of your information to third parties. We only share it if necessary for fulfilling an agreement or to meet a legal obligation. When we engage third-party companies to process your data on our behalf, we conclude a processor agreement to uphold the same high standards of security and confidentiality for your data. These may include IT service providers, HR service providers, and auditors. ILX remains responsible for these processing operations. 

Cookies, or similar techniques, that we use 

ILX only uses technical, functional, and analytical cookies that uphold your privacy. A cookie is a small text file that is stored on your computer, tablet, or smartphone when you first visit this website. The cookies we use are necessary for the technical operation of the website and to enhance your user experience. They ensure proper website functionality and retain preferences, such as your chosen settings. Additionally, they enable us to optimize our website. You have the option to opt out of cookies by configuring your internet browser to no longer store them. In addition, you can also delete any previously stored information through your browser settings. 

We collect anonymized IP addresses from ILX website visitors to analyze the usage of our website. Messages that we receive from you through our Contact Form are saved, along with your name and email address. Upon using this tool, you consent to us retaining this information. We may use your contact details and the information you provided to contact you, exclusively on ILX business-related matters. Upon your request, we shall delete all messages or contact details associated with you.  

Your rights 

You have the right to access, rectify, or erase your personal data. In addition, you have the right to withdraw your consent for data processing or to object to the processing of your personal data by ILX. Further, you have the right to data portability. This means that you can submit a request to us to transfer the personal data that we hold, in a computer file either to yourself or to an organization referred by you. You can request access, correction, deletion, or data transfer of your personal data or request for withdrawal of your consent or objection to the processing of your personal data by sending an email to: compliance@ilxfund.com  

To verify that the request for access has been made by you, we kindly request you to send a copy of your identification along with your request. Please, ensure to black out your ID photo, passport number, or citizen service number in the provided copy, as this measure is taken to safeguard your privacy. We will respond to your request as soon as possible. 

How do we protect personal data? 

ILX takes the protection of your data seriously and takes appropriate technical and organisational measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. We ensure that data is securely stored and transmitted from computers to our servers, all of which are based in Europe. Under the law, all European countries provide a baseline of an adequate, appropriate level of data protection. In instances where we work with parties outside of Europe, we will only facilitate data transfer if the level of privacy protection is similar to the level required by the GDPR. Should this not be the case, we will proceed with the transfer of your personal data solely upon your prior explicit consent or we will take additional measures to ensure the required level of protection. If you deem that your data is not properly secured or there are indications of abuse, please contact compliance@ilxfund.com. 

Questions and complaints 

If you have a question, remark or complaint please contact ILX’s Data Privacy Manager at compliance@ilxfund.com. Or you can send a letter to:  

ILX Management B.V. 

Data Privacy Manager 

Olympisch Stadion 10 

1076 DE Amsterdam 

Please be informed, that you have the opportunity to file a complaint with the national supervisory authority, the Dutch Data Protection Authority. This can be done via the following link:  https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons 

Modification of the Privacy Statement 

Any amendments to this Privacy Statement made from time to time will be notified and made available on the ILX website: www.ilxfund.com  

This statement was last updated on 24 November 2023 

Privacy Statement - ILX
The information and documents on this website are intended for professional investors only. Please note that 'professional investors' refers to those who meet the definition of professional, institutional, and/or qualified investors as set out in Article 1:1 of the Financial Supervision Act. By accepting this disclaimer, you declare that you are a professional, qualified, or institutional investor as defined in the Financial Supervision Act and agree to its contents. This disclaimer is in addition to the Disclaimer and is governed by Dutch law.
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AGREEMENT TO TERMS

These Terms and Conditions constitute a legally binding agreement made between you, whether personally or on behalf of an entity (“you”) and [business entity name] (“we,” “us” or “our”), concerning your access to and use of the [website name.com] website as well as any other media form, media channel, mobile website or mobile application related, linked, or otherwise connected thereto (collectively, the “Site”). 
You agree that by accessing the Site, you have read, understood, and agree to be bound by all of these Terms and Conditions. If you do not agree with all of these Terms and Conditions, then you are expressly prohibited from using the Site and you must discontinue use immediately.
Supplemental terms and conditions or documents that may be posted on the Site from time to time are hereby expressly incorporated herein by reference. We reserve the right, in our sole discretion, to make changes or modifications to these Terms and Conditions at any time and for any reason. 
We will alert you about any changes by updating the “Last updated” date of these Terms and Conditions, and you waive any right to receive specific notice of each such change. 

It is your responsibility to periodically review these Terms and Conditions to stay informed of updates. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Terms and Conditions by your continued use of the Site after the date such revised Terms and Conditions are posted.

INTELLECTUAL PROPERTY RIGHTS

Unless otherwise indicated, the Site is our proprietary property and all source code, databases, functionality, software, website designs, audio, video, text, photographs, and graphics on the Site (collectively, the “Content”) and the trademarks, service marks, and logos contained therein (the “Marks”) are owned or controlled by us or licensed to us, and are protected by copyright and trademark laws and various other intellectual property rights and unfair competition laws of the United States, foreign jurisdictions, and international conventions. 

The Content and the Marks are provided on the Site “AS IS” for your information and personal use only. Except as expressly provided in these Terms and Conditions, no part of the Site and no Content or Marks may be copied, reproduced, aggregated, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted, distributed, sold, licensed, or otherwise exploited for any commercial purpose whatsoever, without our express prior written permission.


Provided that you are eligible to use the Site, you are granted a limited license to access and use the Site and to download or print a copy of any portion of the Content to which you have properly gained access solely for your personal, non-commercial use. We reserve all rights not expressly granted to you in and to the Site, the Content and the Marks.


USER REPRESENTATIONS

You may be required to register with the Site. You agree to keep your password confidential and will be responsible for all use of your account and password. We reserve the right to remove, reclaim, or change a username you select if we determine, in our sole discretion, that such username is inappropriate, obscene, or otherwise objectionable.
You may not access or use the Site for any purpose other than that for which we make the Site available. The Site may not be used in connection with any commercial endeavors except those that are specifically endorsed or approved by us. 

PRIVACY POLICY

We care about data privacy and security. Please review our Privacy Policy [CLICK HERE]/posted on the Site]. By using the Site, you agree to be bound by our Privacy Policy, which is incorporated into these Terms and Conditions. Please be advised the Site is hosted in the United States. 
If you access the Site from the European Union, Asia, or any other region of the world with laws or other requirements governing personal data collection, use, or disclosure that differ from applicable laws in the United States, then through your continued use of the Site, you are transferring your data to the United States, and you expressly consent to have your data transferred to and processed in the United States. 
[Further, we do not knowingly accept, request, or solicit information from children or knowingly market to children. Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act, if we receive actual knowledge that anyone under the age of 13 has provided personal information to us without the requisite and verifiable parental consent, we will delete that information from the Site as quickly as is reasonably practical.]
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