Privacy beleid

Who we are

HC Partners, located at Danzigerkade 211A 1013 AP Amsterdam, is responsible for the processing of personal data as shown in this privacy statement. Contact details: Danzigerkade 211A 1013 AP Amsterdam 0031613354355 Johann Boven is the Data Protection Officer of HC Partners. He can be reached at HC Partners also refers to the following statement in connection with the sustainable finance disclosure regulation (SFDR), available below the privacy statement.

What personal data we collect and why we collect it

Personal data we process

HC Partners processes your personal data as you use our services and/or because you provide them to us yourself. Below you will find an overview of the personal data that we process: – First and last name – Date of birth – Address information – Phone number – E-mail address – Other personal data you actively provide, for example by creating a profile on this website, in correspondence and by phone .

Special and/or sensitive personal data we process

Our website and/or service does not intend to collect data about website visitors younger than 16 years old unless permission is granted by parents or a guardian. We are however, unable to check whether a visitor is older than 16. Therefore, we advise parents to be involved in the online activities of their children, in order to prevent data on or about minors being collected without parental consent. If you are convinced we have collected personal data on or about a minor without permission, please contact us via, in order for the information to be deleted.

The purpose and on what basis we process personal data

HC Partners processes your personal data for the following purposes: – Sending our newsletter and/or advertising brochure – To be able to call or e-mail you if necessary for us to carry out our services .

Automated decision making

HC Partners takes zero responsibility based on decisions made by automated processing on matters that can have (significant) consequences for people. This concerns decisions that are taken by computer programs or systems, without a person (for example an employee of HC partners) in between.

How long we keep personal data

HC Partners does not store your personal data for longer than is strictly necessary to realize the goals for which your data is collected.

Sharing personal data with third parties

HC Partners only shares personal data to third parties if this is necessary for the execution of our agreement with you or to comply with a legal obligation.

Cookies or similar techniques we use

HC Partners only uses technical and functional cookies. Additionally, analytical cookies that do not infringe on your privacy. A cookie is a small text file that is stored on your computer, tablet or smartphone after your first visit on this website. The cookies we use are necessary for the technical operation of the website and your ease of use. They ensure that the website functions properly and, for example, remember your preferences. Also, we can optimize our website with this. You can opt out of cookies by changing the settings of your internet browser disabling the storage of cookies. In addition, you can also delete all information that has previously been stored through the settings of your browser.

View, modify or delete data

You have the right to view, correct or delete your personal data. In addition, you have the right to withdraw your consent for data processing (if any processing will be done) or to object to the processing of your personal data by HC Partners and you have the right to data portability. This means that you can submit a request to us, for your personal data in our possession, which will be send in a computer file to you or another person/organization named by you. You can request access, correction, deletion, data transfer of your personal data or send a request to withdraw your consent or objection to the processing of your personal data to to be sure that the request for access has been made by you, we ask you to send a copy of your proof of identity with the request. In this copy make sure your passport photo, MRZ (machine readable zone, the strip with numbers at the bottom of the passport), passport number and Citizen Service Number (BSN) are in black. This for the protection your privacy. We will respond to your request as soon as possible, but within four weeks. HC Partners would also like to point out that you have the option to file a complaint to the national supervisory authority, the Dutch Data Protection Authority. You can do this through the following link:

How we protect personal data

HC Partners is serious in the protection of your data and takes appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized modification. If you have the impression that your data is not properly secured or there are indications of misuse, please contact our customer service or through – Security software, such as a virus scanner and firewall. – TLS (formerly SSL) We send data through a secure internet connection. This can be seen by the address bar ‘https’ and the padlock in the address bar.


In order to comply with the sustainable finance disclosure regulation (SFDR)[1], Harbour Capital Partners B.V. (Harbour Capital) makes the following disclosures.

Integration of sustainability risks

A sustainability risk means “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”.

Before any investment decisions are made on behalf of a fund that Harbour Capital manages, an investment decision process is followed which in regard to specific investments includes the approval of the Investment Committee of such fund. Harbour Capital views ESG as a standard topic in the pre-investment process. Part of the investment decisions process is that Harbour Capital assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by Harbour Capital when making investment decisions.

In addition, Harbour Capital pays staff a combination of fixed remuneration and variable remuneration. Variable remuneration for relevant staff also takes into account compliance with all policies and procedures which are in effect within Harbour Capital, including those relating to taking into account sustainability risks on the investment decision making process.

Employees are made aware of the applicable policies and procedures when starting their employment with Harbour Capital.

No consideration of sustainability adverse impacts

In accordance with article 4 sub 1 (b) of the SFDR, Harbour Capital states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR. Given the small size of the organisation of Harbour Capital, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.