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Privacy and Cookie Statement

Privacy legislation is intended to protect the privacy of persons. We at Apple Tree Capital Partners regard this an important value, that is aligned with our belief in an honest, open, and transparent way of doing business and of dealing with our relations. For this reason, we treat the personal data you share with us with diligence and confidentiality. In this privacy statement, we would like to clarify, in the most transparent and accessible manner possible, how and why we collect personal data and how we process and keep it. In case you still have questions after reading this statement, you are always welcome to submit them via

1. Who we are

We are Apple Tree Capital Partners B.V., and we are responsible for the processing of personal data as represented in this Privacy and Cookie Statement. We are established in Vught, on Heikantstraat 35. Our contact details are the following:

Apple Tree Capital Partners

Heikantstraat 35, 5261XM


+31-6-80122641 / +31-6-11782250

2. What personal data do we process and why?

When you visit our website, by contacting us, or because you want to participate or are participating already, we collect personal data: data you provide yourself and data that is automatically collected during your visit to the website.

Apple Tree Capital Partners B.V. has various reasons for processing personal data. In the following, we explain per purpose we process personal data for what personal data we record, why we record personal data, and for how long we keep such data.

In case you contact us

When you contact us about information about a fund or our services, for instance, or to make an appointment with us, or you respond on or via our social media platforms, it may be that you are voluntarily providing us with information that we process to be able to communicate with you, such as your first and last name, address, business name, phone number, e-mail information and/or your social media profile. By providing such information, you grant us permission to process and use the same to reach out to you or to stay in contact. Your data is removed no later than 2 years after the last contact, unless there is a legal obligation to keep such longer. In that case, we will keep the data for as long as is required to comply with the legal obligation.


In case you register to receive information (e-mails)

You can register to receive various types of periodic or one-time bulletins, for example to remain posted on our provision of services, or to receive information such as newsletters or the monthly Fund Insights. In such case, you give your consent to receive information via e-mail or downloads, for example, with the type of information you have registered for.

We will always ask for your permission first, before sending you e-mails with information or marketing communication about our provision of services. For this purpose, we process your first and/or last name and e-mail address after you have granted permission. We need this information to be able to send you e-mails.

At the bottom of each e-mail with information you can find a link via which you can unsubscribe. After unsubscribing, you will no longer receive any e-mails with information and your data will be removed 1 year later at the latest, unless there is a legal obligation to retain it. In such case, we will keep the data for as long as is required to comply with the legal obligation.


If you pose questions via the contact form on our website

You can submit questions to us via our contact form. To be able to respond, we process your first and last name and e-mail address. We keep this data for as long as is necessary for the complete processing of your question and will remove your data at the latest within 1 year after processing.


When you visit our website

When you visit our website, cookies are placed automatically so that we are able to track certain information based on your IP-address. Thereby, we may process the following data: your IP-address, your operating system, browser type and version, your geolocation, which pages of our website you visit, how often you do so, the date and hour of your visit, and mobile information.

We process this data – depending on your cookie settings – to let our website function optimally and to be able to analyze information about visits to our website with the aid of software such as Google Analytics.

See below for more information about our cookie policy.


In case you participate or want to participate in a fund we manage

We process personal data to enter into and to implement agreements for funds we manage, in accordance with our duty of care and legal obligations, and to maintain relations that flow therefrom. By the latter we mean that we want to be able to reach clients or interested parties if this is necessary – for example to transmit legally mandatory information about a fund, to forward personal investment reports, or to transmit changes to the services – and we need their contact details for the purpose. We can also use the personal data to send marketing communications to existing clients about similar products or services of Apple Tree Capital Partners B.V. (except in case you have unsubscribed).

To participate in a fund, you need to fill out a registration form, and a mutation form in case of later changes. As a part of registration, various personal data must be provided, such as name, address, place of residence, e-mail address, and phone number. In addition, the origins of the capital to be invested will be inquired after, as well as a copy of the bank account from where the money for the participation will be transferred, and a copy of your passport, and a few fiscal control questions will be asked. The information requested for is primarily directed at compliance with relevant legislation and regulations, for example with respect to the prevention of money laundering.

Both in case of registration and of mutation forms, your explicit permission is requested to be allowed to process the data provided, for the purpose of the conclusion or modification of the agreement. This privacy statement, to the extent relevant for the entry into or the modification of an agreement, is also provided as an appendix to those forms.

In case not all personal data requested in the relevant forms is filled out, this may entail the impossibility of participating in a fund.

If a participant sells her or his participation, the personal data are removed at the latest 5 years after the sale of the participation. This retention period flows from the requirements in legislation. If a legal obligation pertains, otherwise than stated above, to retain data for any longer, we will keep such for as longs as is required to comply with the legal obligation.


To comply with legislation and regulations

Offering investment funds is subject to legislation and regulations, for example to protect participants, but also, e.g., to prevent money laundering. It is possible we use your personal data to comply with legislation and regulations.


Website visitors below 16 years of age

We do not have the intention to collect information from website visitors younger than 16, unless they have permission from parents or custodian. We cannot check, however, whether a visitor is older than 16. We therefore advise parents to be involved in the on-line activities of their children, so as to prevent that information is collected on children without parental consent. If you believe that we have collected personal data about a minor without this permission, please contact us via, and we will remove this information.

3. For how long do we keep your personal data?

Personal data is not kept for any longer than is necessary within our legal obligations, than we deem required for a sound and efficient administration, and to be able to inform you in case of changes to our funds or provision of services. We have clearly described above per purpose for how long we keep data. After this retention period, personal data is destroyed. The law may prescribe a different retention period. If this is the case, we will observe the prescribed legal retention term.

4. Cookie Statement

Cookies are tiny text files containing data and at times unique identifiers. These are downloaded on your computer or mobile device when you visit our website. Your browser sends the cookies back to the website every time that the same visitor returns, so that the website can recognize the visitor and can adapt possible information and the lay-out of the website to the visitor. A cookie often contains a randomly generated number that is stored on the device of the user and many cookies are removed automatically after the visitor stops using the website. Cookies make using websites easier and have an impact on many of the valuable components of websites.

We use cookies to enable pleasant navigation through the website. We use cookies in addition to the collection of information about your use of our website, for example about your preferences. We do this to adapt your visit to our website to your preferences and to analyze and improve the use of our website.

Our website uses the following cookies:

  • Essential cookies: these cookies enable core functionalities, such as security, identity checks, and network management. These are necessary cookies that you do not need to grant permission for.

  • Functional cookies: these cookies collect data to keep track of choices of users so as to improve and personalize the experience.

  • Analytic cookies: these cookies help us understand how visitors handle our website, to discover errors, and to carry out better overall analyses.

  • Marketing cookies: these cookies are used to keep track of the efficacy of advertisements in order to offer a more relevant service and to display ads that align with your interests.


Managing your cookies

If you have granted us permission to use cookies, we will place a cookie on your device to memorize this for the next time you visit our website.

If you do not accept the use of cookies, this may affect your user experience, because possibly not all functionalities of the website will be available to you.

If you want to withdraw your permission of the use of cookies, you can do so at any time. It is possible via your browser settings:

  • Deactivate the use of cookies in the browser of your PC or device;

  • Remove the cookies from our website that were stored on your browser.

For more information about and help with the removal of cookies, you can consult the ‘Help’ page of your browser.


This Cookie Statement does not regard the web links on our website that refer to different websites. We encourage you to read the Privacy Statements on the relevant websites you visit.


If you have questions about our Cookie Policy, you are always welcome to send an e-mail to

5. The sharing of personal data with third parties

We only share your personal data with partners and third parties if this is necessary for the implementation of the agreement and our services, and in order to comply with a possible legal obligation. Included in the first category, for example, are our administrator and e-mail provider. Included in the second category, for instance, are oversight agencies or authorities.


Except to the extent described in this Privacy Statement, we do not share your personal data with third parties without your permission.

With companies that process your data by our order, we conclude a processor agreement to facilitate the same level of security and to protect the confidentiality of your data. We remain responsible for these processing operations. It regards the following parties:

  • AssetCare Fund Services: administrator of the fund;

  • miWebb: E-mail Service Provider;

  • vBoxx: cloud-service provider;

  • Google Analytics: we use Google Analytics to keep track of how visitors use the website. We do not allow Google to use the Analytics data obtained for different Google services.


If we ever decide to transfer or sell a part or the whole of our company, we may share your personal data in relation that that sale.

6. Your rights under the GDPR

Under the General Data Protection Regulation (GDPR), you have the right to peruse, correct, or remove your personal data. Under the right of perusal, you can receive a copy of your personal data that we have collected, as well as information about the purpose of the processing of this personal data and with whom your data was shared. You have the right to withdraw permission granted for data processing or to object against the processing of your personal data by Apple Tree Capital Partners B.V.

You also are entitled to data transferability. That means that you can submit a request to have the personal data we have from you forwarded, in a computer file, to you or a different organization as specified by you.

In order to exercise one of these rights, you can send an e-mail to To make sure that we are receiving a request from the right person, we ask to attach a copy of your ID to your request. To protect your privacy, it is important that you redact your picture, the MRZ (machine readable zone, the bar with numbers at the bottom of the passport), the passport number and your social security number (BSN) on this copy.

Some rights within the GDPR are subject to restrictions, such as legal requirements. If your request is rejected, we will let you know.

7. Questions, comments, or complaints

If you have questions, comments, or complaints about our privacy policy or specific instances of the processing of personal data by Apple Tree Capital Partners B.V. you are always welcome to send us an e-mail at

We also point out to you that you have the option of submitting a complaint to the national oversight authority, 'Autoriteit Persoonsgegevens'. You can do so via the following link:

8. Modifications and updates

We periodically update our Privacy and Cookie Statement. This version is dated 11-07-2022.

We advise you to periodically check this Statement for changes. But we will also announce material changes in this spot, and thereby accordingly modify the date of the latest update.

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