Privacy Policy · More Capital Partners

Company: More Capital Partners
Chamber of Commerce: 42166939
Website: www.more-cp.com
Email: stephane@more-cp.com
Registered address: Keizersgracht 572, 1017 EM Amsterdam

Article 1Introduction

1.1More Capital Partners (“MCP”, “we”, “us” or “our”) is committed to protecting the privacy, confidentiality and security of personal information entrusted to us.

1.2This Privacy Policy explains how MCP collects, uses, processes, stores, shares and protects personal data in connection with its website, business activities, professional relationships and commercial services.

1.3MCP processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Dutch GDPR Implementation Act (Uitvoeringswet AVG) and other applicable privacy and data protection legislation.

1.4This Privacy Policy applies to visitors of www.more-cp.com, prospective and existing business clients, representatives of corporate clients, professional contacts and other individuals whose personal data is processed in connection with MCP’s business activities.

1.5MCP operates as an independent commercial intermediary and maintains contractual relationships with regulated financial institutions. The distinction between MCP’s own processing activities and those undertaken by its Financial Partners is explained below.

Article 2Identity of the Data Controller

2.1The data controller responsible for the processing of personal data described in this Privacy Policy is:

More Capital Partners

Registered in the Netherlands

Chamber of Commerce (KvK): 42166939

Registered address: Keizersgracht 572, 1017 EM Amsterdam

Email: stephane@more-cp.com

Website: www.more-cp.com

2.2MCP determines the purposes and means of processing personal data in connection with its own business operations, commercial introductions, relationship management and website activities.

2.3Where personal data is transferred to an independent regulated financial institution, that institution may act as a separate data controller in relation to its own financial services, compliance obligations and client relationships.

2.4Where MCP processes personal data on behalf of another organisation under a specific contractual arrangement, the respective responsibilities shall be determined in accordance with the GDPR and the applicable data processing arrangements.

Article 3Categories of Personal Data

3.1Depending on the nature of the business relationship, MCP may collect and process the following categories of personal data:

a.Identification and contact information

Names, professional titles, business email addresses, telephone numbers, business addresses and other contact details.

b.Professional and business information

Company names, registration details, professional positions, business activities, industry sectors, jurisdictions of operation and information relating to an individual’s role within an organisation.

c.Commercial and financial information

Information voluntarily provided concerning business requirements, foreign exchange exposure, international payment needs, treasury requirements, transaction volumes, financing requirements and other relevant commercial circumstances.

d.Corporate ownership and representation information

Information concerning directors, authorised representatives, shareholders and ultimate beneficial owners, where necessary and lawful in connection with commercial introductions or partner onboarding.

e.Communications and correspondence

Emails, meeting notes, enquiries, business proposals, correspondence and other records of professional communications.

f.Website and technical information

IP addresses, browser type, device information, website usage data, technical logs and information collected through cookies or similar technologies, where applicable.

g.Publicly available professional information

Information obtained from company websites, professional directories, commercial databases, public company registers and other lawful sources relevant to business development activities.

3.2MCP seeks to limit the collection of personal data to information reasonably necessary for specified and legitimate business purposes.

3.3MCP does not routinely request special categories of personal data, such as health information, religious beliefs or biometric identification data.

3.4Where additional identification or verification information is required by a Financial Partner, such information will be processed by MCP only where necessary, lawful and consistent with the applicable arrangements.

Article 4Sources of Personal Data

4.1Financial Partners, Client Data and External Login Platforms

More Capital Partners maintains commercial partnerships with regulated financial institutions, including ALT21 and Corpay, for the provision of foreign exchange, international payments and related financial services.

Where applicable, clients may access secure external login platforms operated by these Financial Partners through links provided on www.more-cp.com. Such platforms are independently operated and may be subject to their own privacy policies, cookie policies and security procedures.

In connection with these partnerships, relevant personal and business information may be securely shared between More Capital Partners and the respective Financial Partner for legitimate purposes, including client onboarding, account administration, compliance procedures and ongoing relationship management, where permitted by applicable data protection law.

More Capital Partners is committed to handling all personal and business information with the utmost care and confidentiality and to implementing appropriate technical and organisational safeguards to protect such information.

The sharing of information with Financial Partners is limited to what is necessary and lawful for the relevant services. Each party remains responsible for its own data processing activities in accordance with applicable data protection legislation.

For further details, please refer to our Privacy Policy and the privacy and cookie policies of the relevant Financial Partner.

4.2MCP may also obtain professional contact information from lawful third-party sources, including:

a.Public business registers.

b.Corporate websites.

c.Professional networking platforms.

d.Commercial information providers.

e.Referrals from existing business relationships.

f.Financial Partners and other professional counterparties.

4.3Where personal data has not been obtained directly from the individual concerned, MCP will provide the information required by Article 14 GDPR within the applicable statutory timeframe, unless a lawful exception applies.

Article 5Purposes and Legal Bases for Processing

5.1MCP processes personal data only where a valid legal basis exists under Article 6 GDPR.

5.2Personal data may be processed for the following purposes:

a.Responding to enquiries

To respond to questions, provide requested information and communicate with prospective or existing business contacts.

Legal basis: legitimate interests or taking steps prior to entering into a contract, where applicable.

b.Business development and client acquisition

To identify potential business clients, establish professional relationships and communicate regarding MCP’s commercial services.

Legal basis: legitimate interests, subject to the individual’s rights and applicable direct marketing requirements, or consent where required.

c.Commercial introductions

To understand a Client’s business requirements and facilitate introductions to appropriate Financial Partners.

Legal basis: legitimate interests, contractual necessity where applicable, or consent where appropriate.

d.Client relationship management

To maintain professional relationships, coordinate communications, provide commercial support and manage ongoing engagements.

Legal basis: legitimate interests or contractual necessity, as applicable.

e.Compliance and legal obligations

To comply with applicable legal obligations, respond to lawful requests and maintain legally required records.

Legal basis: compliance with a legal obligation where applicable.

f.Administration and business operations

To manage business records, invoicing, accounting, contractual arrangements and internal administration.

Legal basis: contractual necessity, legal obligations or legitimate interests, as applicable.

g.Website operation and security

To operate, maintain and protect MCP’s website and information systems.

Legal basis: legitimate interests or consent where required for specific technologies.

h.Legal claims and dispute resolution

To establish, exercise or defend legal claims and protect MCP’s legitimate legal interests.

Legal basis: legitimate interests or another applicable legal basis.

5.3Where MCP relies on legitimate interests, those interests may include maintaining professional business relationships, developing its commercial activities, protecting its systems and facilitating requested business services.

5.4MCP will assess the necessity of processing and balance its legitimate interests against the rights and freedoms of affected individuals where required.

5.5Where processing is based on consent, individuals may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Article 6Commercial Introductions and Financial Partners

6.1MCP operates as an independent commercial intermediary, introducing business clients to regulated financial institutions offering foreign exchange, international payments, treasury solutions and other financial products.

6.2In connection with a requested introduction, MCP may share relevant personal and business information with the Financial Partner concerned.

6.3Such information may include:

a.Names and business contact details of authorised representatives.

b.Company identification and registration information.

c.Information concerning business activities and commercial requirements.

d.Relevant information concerning foreign exchange, payment or treasury requirements.

e.Additional documentation where necessary and lawful.

6.4MCP will share personal data only where an appropriate legal basis exists and where the disclosure is necessary and proportionate to the relevant purpose.

6.5Financial Partners may require additional personal data to fulfil their own customer identification, anti-money laundering, sanctions screening, regulatory compliance and risk management obligations.

6.6The relevant Financial Partner is responsible for determining the information required for its own onboarding and regulatory procedures.

6.7Where the Financial Partner acts as an independent data controller, its own privacy policy, contractual documentation and applicable data protection obligations shall govern its processing activities.

6.8MCP does not assume responsibility for the independent data processing activities of Financial Partners, except where MCP has a separate legal responsibility under applicable data protection law.

6.9MCP may assist Clients in communicating with Financial Partners and coordinating documentation, subject to applicable confidentiality, data protection and contractual requirements.

Article 7White-Label Platforms and Third-Party Systems

7.1MCP may provide Clients with access to financial platforms operated by independent Financial Partners through branded login interfaces, referral links or white-label arrangements.

7.2Such platforms may display MCP’s name, logo or other branding while the underlying technology, financial services and associated regulated activities are provided by the relevant Financial Partner.

7.3The presence of MCP branding does not, in itself, mean that MCP operates the underlying platform or acts as the data controller for all personal data processed through it.

7.4The identity and data protection responsibilities of the relevant platform operator shall be determined by the actual processing arrangements and applicable law.

7.5Clients accessing an external financial platform may be subject to the privacy policy, terms of use and data processing arrangements of the relevant Financial Partner.

7.6Where MCP receives or accesses information from a Financial Partner’s platform for legitimate commercial relationship management purposes, MCP will process that information in accordance with this Privacy Policy and applicable law.

7.7MCP will not claim ownership or independent regulatory responsibility for financial platforms operated by its Financial Partners solely because such platforms display MCP branding.

Article 8Disclosure of Personal Data

8.1MCP may disclose personal data to third parties where necessary, lawful and proportionate.

8.2Recipients may include:

a.Regulated Financial Partners and commercial counterparties.

b.Professional advisers, including accountants, legal advisers and compliance consultants.

c.Website hosting providers and technical service providers.

d.Email, communication and customer relationship management providers.

e.Administrative, accounting and business support providers.

f.Public authorities, regulators, courts and other competent bodies where required or permitted by law.

8.3MCP will not disclose personal data to unrelated third parties for their independent marketing purposes without an appropriate legal basis.

8.4MCP does not sell personal data to third parties.

8.5Where a service provider processes personal data on MCP’s behalf, MCP will enter into an appropriate data processing agreement where required by Article 28 GDPR.

8.6MCP will take reasonable steps to ensure that personal data is disclosed only to recipients with a legitimate need to receive it.

Article 9International Transfers of Personal Data

9.1MCP operates in an international commercial environment and may maintain relationships with organisations located outside the European Economic Area (“EEA”).

9.2Personal data may be transferred to, stored in or accessed from countries outside the EEA where necessary for legitimate business purposes and permitted under applicable data protection law.

9.3Where such transfers take place, MCP will ensure that an appropriate transfer mechanism is available under Chapter V GDPR.

9.4Appropriate mechanisms may include:

a.An adequacy decision issued by the European Commission.

b.The European Commission’s Standard Contractual Clauses.

c.Other lawful transfer mechanisms or derogations where applicable.

9.5Where required, MCP will assess whether supplementary measures are necessary to provide an appropriate level of protection.

9.6Individuals may request information about applicable transfer safeguards and how to obtain or access them by contacting MCP.

Article 10Data Retention

10.1MCP retains personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required or permitted by law.

10.2Retention periods are determined by reference to:

a.The nature and purpose of the processing.

b.The duration of the relevant business relationship.

c.Applicable statutory retention obligations.

d.Legitimate administrative and compliance requirements.

e.The establishment, exercise or defence of legal claims.

10.3Business contact details and commercial correspondence will be periodically reviewed and deleted or anonymised when no longer necessary.

10.4Personal data relating to unsuccessful commercial enquiries will not be retained indefinitely without an appropriate justification.

10.5Financial and administrative records will be retained for the periods required by applicable Dutch law.

10.6Where personal data is no longer required, MCP will take reasonable steps to delete, anonymise or securely dispose of it.

10.7Specific retention periods or the criteria used to determine them will be made available where required by applicable law.

Article 11Data Security and Confidentiality

11.1MCP is committed to maintaining appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, unlawful disclosure, alteration or destruction.

11.2Such measures may include:

a.Access controls and authentication procedures.

b.Secure communication and data storage arrangements.

c.Appropriate password and account management practices.

d.Restricted access to confidential information.

e.The use of reputable technology and hosting providers.

f.Periodic review of relevant security arrangements.

11.3Access to personal data shall be limited to individuals and service providers who require such access for legitimate business purposes.

11.4MCP shall take reasonable measures to ensure that persons authorised to process personal data are subject to appropriate confidentiality obligations.

11.5Where a personal data breach occurs, MCP will assess its obligations under Articles 33 and 34 GDPR and notify the relevant supervisory authority and affected individuals where legally required.

11.6Although MCP implements appropriate safeguards, no electronic transmission or storage system can be guaranteed to be entirely free from security risks.

Article 12Website Usage and Cookies

12.1The website www.more-cp.com is primarily intended to provide information about MCP, its expertise and its commercial services.

12.2The website does not independently provide facilities for executing foreign exchange transactions, placing payment instructions or entering into regulated financial contracts.

12.3MCP may collect limited technical information necessary for website functionality, security and performance.

12.4The website may use cookies or similar technologies for essential functionality and, where implemented, analytics or other purposes.

12.5Strictly necessary cookies may be used without prior consent where permitted by applicable law.

12.6Non-essential cookies and tracking technologies requiring consent will only be activated after valid consent has been obtained.

12.7Where applicable, visitors will be informed of the categories, purposes, providers and retention periods of cookies used on the website.

12.8Visitors will be able to manage or withdraw cookie consent where legally required.

12.9Further information may be provided through a separate Cookie Policy or cookie preference interface.

Article 13Direct Marketing and Professional Communications

13.1MCP may contact existing and prospective business relationships regarding its commercial services, relevant market developments and professional opportunities where permitted by law.

13.2Such communications may be based on an existing business relationship, a legitimate interest or consent, depending on the circumstances and applicable electronic marketing requirements.

13.3Where prior consent is required, MCP will obtain such consent before sending the relevant marketing communications.

13.4MCP will respect objections to direct marketing and provide appropriate opportunities to unsubscribe or opt out.

13.5Individuals may object at any time to the processing of their personal data for direct marketing purposes.

13.6Following a valid objection, MCP will cease processing the relevant personal data for direct marketing purposes.

Article 14Rights of Data Subjects

14.1Individuals whose personal data is processed by MCP have rights under the GDPR, subject to applicable conditions and limitations.

14.2These rights may include:

Right of access: the right to request confirmation of whether personal data is being processed and to obtain access to that data.

Right to rectification: the right to request correction of inaccurate personal data and completion of incomplete information.

Right to erasure: the right to request deletion of personal data where the legal requirements are satisfied.

Right to restriction: the right to request restriction of processing in certain circumstances.

Right to data portability: the right to receive certain personal data in a structured, commonly used and machine-readable format and, where applicable, transmit it to another controller.

Right to object: the right to object to certain processing activities, including processing based on legitimate interests.

Right to withdraw consent: the right to withdraw consent at any time where processing is based on consent.

Right concerning automated decision-making: the right not to be subject to certain solely automated decisions producing legal or similarly significant effects, subject to applicable exceptions.

14.3Requests to exercise these rights may be submitted to MCP using the contact information provided in this Privacy Policy.

14.4MCP may request additional information where reasonably necessary to verify the identity of the person submitting a request.

14.5MCP will respond without undue delay and generally within one month of receiving a valid request, subject to any extension permitted by the GDPR.

14.6Where MCP cannot fully comply with a request, it will provide an explanation in accordance with applicable law.

Article 15Automated Decision-Making and Profiling

15.1MCP does not itself undertake solely automated decision-making producing legal or similarly significant effects on individuals in connection with its commercial introduction and relationship management activities.

15.2MCP may use ordinary business software to organise professional contacts, manage correspondence and support commercial operations.

15.3Independent Financial Partners may conduct their own automated assessments, sanctions screening, fraud monitoring, credit assessments or other compliance procedures.

15.4Such processing by Financial Partners is governed by their respective privacy policies and applicable legal obligations.

15.5Where MCP introduces automated decision-making activities of its own that fall within Article 22 GDPR, this Privacy Policy will be updated as required.

Article 16Provision of Personal Data

16.1Individuals are generally not legally required to provide personal data merely to browse MCP’s informational website.

16.2Certain personal data may be necessary to respond to enquiries, establish professional relationships or provide requested commercial services.

16.3Where required information is not provided, MCP may be unable to respond fully to a request or facilitate a commercial introduction.

16.4Independent Financial Partners may impose additional identification, verification and documentation requirements before providing regulated financial services.

16.5Such requirements are determined by the relevant Financial Partner and applicable law.

Article 17Third-Party Websites and External Platforms

17.1MCP’s website may contain links to independent third-party websites, financial platforms and other external services.

17.2Such websites and platforms may be operated by Financial Partners or other independent organisations.

17.3MCP does not control the independent privacy practices of third-party organisations.

17.4Visitors are encouraged to review the relevant third party’s privacy policy and contractual terms before submitting personal data.

17.5Where MCP shares personal data with a third party, MCP remains responsible for ensuring that its own disclosure complies with applicable data protection law.

Article 18Complaints and Supervisory Authority

18.1MCP is committed to addressing privacy-related enquiries and concerns fairly and within a reasonable timeframe.

18.2Individuals who have questions or concerns about the processing of their personal data may contact MCP using the details below.

18.3MCP will investigate privacy-related complaints and respond in accordance with its legal obligations.

18.4Individuals also have the right to lodge a complaint with the competent data protection supervisory authority.

In the Netherlands, the relevant authority is:

Autoriteit Persoonsgegevens

Website: www.autoriteitpersoonsgegevens.nl

18.5Nothing in this Privacy Policy restricts an individual’s statutory rights under applicable data protection legislation.

Article 19Changes to This Privacy Policy

19.1MCP may update this Privacy Policy from time to time to reflect changes in legislation, business activities, technology, contractual arrangements or data processing practices.

19.2The most recent version will be published on www.more-cp.com.

19.3The current version of this Privacy Policy is the version published on www.more-cp.com and indicates when it became applicable.

19.4Where material changes require additional notification or consent under applicable law, MCP will take appropriate steps to fulfil those requirements.