Privacy Policy

This Privacy Policy explains how XPNT Capital Management (“XPNT”, “we”, or “us”) uses the personal data it collects or generates in relation to this website, our communications, our business activities, and our recruitment process.

XPNT collects and uses certain personal data. XPNT is responsible for ensuring that it uses personal data in compliance with applicable data protection laws, including the General Data Protection Regulation (“GDPR”). We respect the privacy of our contacts, applicants, counterparties, and other individuals whose personal data we process, and we are committed to keeping that data secure. This Privacy Policy governs the handling of personal data by XPNT in the course of carrying on its business activities.

Definitions

In this Privacy Policy:

“XPNT”, “we” or “us” means XPNT Capital Management.

“Personal Data” means any information relating to an identified or identifiable natural person. In addition to factual information, it includes expressions of opinion about an individual and indications of our intentions, or those of another person, in relation to an individual.

The categories of information covered by this Privacy Policy

This Privacy Policy concerns the following categories of information that we collect about you:

A. Information we receive through our website;
B. Information we receive when you contact us for business, professional, or investor-related purposes;
C. Information we receive in connection with recruitment and job applications; and/or
D. Information we receive from third parties or public sources.

The types of personal data we collect

In relation to the categories described above, we may collect and process the following personal data about you.

Information that you provide to XPNT

This includes information about you that you provide to us by completing forms or by communicating with us, whether face-to-face, by phone, by email, through our website, or otherwise.

Depending on the nature of your interaction with us, this may include:

  • first name and last name
  • employer or organisation
  • job title or position
  • email address
  • phone number
  • business address
  • city, postcode, and country
  • any other information you choose to share with us which may be considered personal data

Information that we collect or generate about you

This may include:

  • correspondence and related communications data
  • website usage data
  • records of your contact history with us
  • internal notes relating to enquiries, communications, or business interactions
  • technical information generated through use of our website or IT systems
  • call recordings and related data, where calls are recorded

Recruitment and applicant data

If you apply for a role with XPNT, we may collect and process personal data relating to your application, including:

  • contact details
  • CV or résumé
  • cover letter or application materials
  • education and employment history
  • correspondence relating to your application
  • interview notes and internal assessment notes
  • reference information, where applicable and appropriate
  • call recordings and related data, where interviews or calls are recorded
  • any other information you choose to provide in connection with your application

We use this data to assess your suitability for a role, communicate with you about the recruitment process, keep records relating to that process, and protect our legitimate interests in running an effective recruitment process.

Information we obtain from other sources

This may include information from public websites and other public sources, information received from advisers, intermediaries, professional contacts, service providers, or references, and other information that is relevant to our business activities.

Where relevant to future business activities, this may also include information obtained for legal, regulatory, due diligence, or compliance purposes.

How we use your information

Your personal data may be stored and processed by us for the following purposes:

  • to communicate with you and respond to enquiries
  • to provide you with information about XPNT and our business activities
  • to manage our relationships with professional contacts, counterparties, service providers, and other business contacts
  • for general business administration, including accountancy, audit, legal, compliance, risk management, and administration of IT systems
  • to maintain, review, improve, and secure our website and systems, including monitoring for potential disruptions or cyber attacks
  • to understand your interests in our business and communications
  • to manage and administer our business
  • to assess, process, and manage job applications and recruitment activities
  • to communicate with applicants and evaluate suitability for current or future roles
  • to record calls or interviews where appropriate for record-keeping, training, assessment, compliance, or security purposes
  • to comply with legal and regulatory obligations and internal policies and procedures

Legal bases for processing

When we use personal data, we make sure that the processing complies with applicable law. Depending on the circumstances, we may process personal data on one or more of the following bases:

  • the processing is necessary to take steps prior to entering into a contract or to perform contractual obligations
  • the processing is necessary for compliance with legal and regulatory obligations
  • the processing is necessary to establish, exercise, or defend legal rights or legal claims
  • you have provided consent, where consent is the appropriate legal basis
  • the processing is necessary for our legitimate interests, such as:
    • effectively managing and administering our business
    • maintaining compliance with internal policies and procedures
    • communicating with business contacts and applicants
    • maintaining the security of our systems and information
    • managing recruitment processes and evaluating candidates
    • recording calls or interviews where appropriate for legitimate business purposes
    • ensuring the proper operation and improvement of our website and communications

We take steps to ensure that personal data is accessed only by people who need to do so for the purposes described in this Privacy Policy.

Disclosure of your information to third parties

We may share your personal data within XPNT for the purposes described above.

We may also share your personal data outside XPNT for the following purposes:

  • with service providers, agents, contractors, or advisers who provide services to us, such as website hosting, IT support, legal, accounting, compliance, communications, or recruitment-related services
  • with professional advisers, auditors, or other counterparties where necessary for our business operations
  • to the extent required by law or regulation, including where we are under a legal obligation to disclose personal data or where disclosure is necessary to establish, exercise, or defend our legal rights
  • in connection with a corporate transaction, investment, restructuring, sale of assets, or similar event, in which case personal data may be disclosed for due diligence purposes
  • where otherwise permitted or required by applicable law

Personal data will only be shared with third parties where there is an appropriate legal basis for doing so.

International transfers of personal data

XPNT is based in the Netherlands. In some cases, personal data may be processed by service providers or advisers located outside the European Economic Area (“EEA”), or may otherwise be transferred outside the EEA.

Where we transfer personal data outside the EEA, we will ensure that it is protected and transferred in a manner consistent with applicable legal requirements. This may be done, for example, by relying on:

  • an adequacy decision of the European Commission
  • contractual safeguards, such as standard contractual clauses approved by the European Commission
  • another lawful transfer mechanism or safeguard permitted under applicable law

How we safeguard your information

We maintain appropriate technical and organisational measures to protect personal data and our information systems.

Appropriate controls, such as restricted access, are applied to our systems and records. Access to personal data is limited to those persons who need it for legitimate business or operational purposes. Physical and digital access to personal data is restricted where appropriate.

People working for or on behalf of XPNT are expected to comply with applicable confidentiality, security, and data protection obligations. Unauthorised use or disclosure of personal data is prohibited and may result in disciplinary or contractual consequences.

When you contact us about your data or your dealings with us, we may ask for information to verify your identity before providing access or taking action on your request.

How long we keep your personal data

How long we retain personal data will vary depending on the purpose for which it was collected, the nature of the relationship, and any legal or regulatory obligations that apply.

In general, we will retain personal data:

  • for as long as necessary for the purpose for which it was collected
  • for as long as necessary to manage our relationship with you
  • for as long as required by applicable law, regulation, or legitimate business needs

Recruitment data retention

If you apply for a role with XPNT, we will retain your application data for as long as reasonably necessary to manage the recruitment process and maintain appropriate records relating to that process.

If your application is unsuccessful, we may retain your application data for a limited period after the end of the recruitment process, for example to evaluate candidates for future roles, to handle follow-up questions, or to protect our legal interests, unless applicable law requires otherwise or you validly object or request deletion where applicable.

If you join XPNT, relevant application data may become part of your personnel file, to the extent permitted by law.

Your rights

In the circumstances set out under applicable data protection law, you may have the following rights, and in many cases you can exercise them free of charge:

  • the right to obtain information regarding the processing of your personal data and access to the personal data we hold about you
  • the right to withdraw your consent at any time where we rely on consent as the legal basis for processing
  • in some circumstances, the right to receive certain personal data in a structured, commonly used, and machine-readable format and/or request that we transmit those data to a third party where technically feasible
  • the right to request that we rectify inaccurate or incomplete personal data
  • the right to request erasure of your personal data in certain circumstances
  • the right to object to, or request restriction of, our processing of your personal data in certain circumstances
  • the right to lodge a complaint with the competent data protection authority if you believe your rights have been infringed

You can exercise your rights by contacting us using the details below.

Questions and concerns

If you have any questions or concerns about XPNT’s handling of your personal data, or about this Privacy Policy, please contact:

daniel@xpntcapital.com

If you are not satisfied with our response, you may lodge a complaint with the competent data protection authority, including in the Netherlands the Autoriteit Persoonsgegevens, where applicable.