Privacy Policy
1. Data Controller
Stroom Capital Management B.V. (Herengracht 450, 2e verdieping, 1012 JS Amsterdam) is the data controller for personal data processed through stroomcap.com. You can contact us at [email protected] for any data-protection matter, including to exercise the rights described below.
2. Personal Data We Process
We process the following categories of personal data:
- Identity and contact data you submit (name, email, phone, employer, role);
- Communications content (messages, requests);
- Technical data collected automatically (IP address, browser, OS, pages visited);
- Usage and analytics data, where you have given consent.
3. Purposes and Legal Bases (Article 6 GDPR)
| Purpose | Legal basis |
|---|---|
| Responding to your inquiries | Pre-contract steps / legitimate interest (Art. 6(1)(b)/(f)) |
| Operating and securing the Service | Legitimate interest (Art. 6(1)(f)) |
| Legal compliance | Legal obligation (Art. 6(1)(c)) |
| Marketing (where applicable) | Consent (Art. 6(1)(a)) |
| Analytics cookies | Consent (ePrivacy + Art. 6(1)(a)) |
4. Recipients and Transfers
Personal data is shared only with processors acting on our behalf under Art. 28 GDPR data-processing agreements (hosting, email delivery, analytics). Where data is transferred outside the EU/EEA, we rely on Standard Contractual Clauses (Art. 46) and assess additional safeguards as required by the Schrems II ruling.
5. Retention
We retain personal data only for as long as necessary for the purposes described. Inquiry-form data is retained 24 months after last contact. Server access logs are retained 90 days.
6. Your GDPR Rights
- Right of access (Art. 15) — confirm whether we process your data and obtain a copy;
- Right to rectification (Art. 16);
- Right to erasure / "right to be forgotten" (Art. 17), subject to limited exceptions;
- Right to restriction of processing (Art. 18);
- Right to data portability (Art. 20);
- Right to object (Art. 21), including to direct marketing without further conditions;
- Right not to be subject to automated decision-making (Art. 22). We do not engage in automated decision-making with legal effects.
To exercise any right, email [email protected]. We respond within one month, extendable by two further months for complex requests.
7. Right to Lodge a Complaint
You have the right to lodge a complaint with your national supervisory authority. A list of EU/EEA authorities is available at edpb.europa.eu.
8. Cookies
See our Cookie Policy. Non-essential cookies are not set without your prior consent (ePrivacy Directive).
9. Security
We implement technical and organisational measures appropriate to the risk, including TLS in transit, encrypted storage, restricted access, and regular review.
10. Changes
Material changes will be reflected by an updated "Last updated" date. Where required, we will request renewed consent.
11. Contact
Stroom Capital Management B.V.Herengracht 450, 2e verdieping, 1012 JS Amsterdam
Email: [email protected]
Phone: +31 20 261 4830