Privacy Policy

Gilde Healthcare Partners BV (“GHP”) collects personal data about you. GHP processes your personal data in compliance with the provisions under the Dutch Data Protection Act (“DDPA”) and the General Data Protection Regulation (“GDPR”), as amended from time to time (collectively “Regulation”). This Data Protection & Privacy Policy (“Policy”) explains how we use any personal data we collect about you.

1. What Personal Data do we collect?
   “Personal Data” is any information relating to you or that we can otherwise link to you. The Personal Data we collect include your name, postal address, e-mail address, phone and fax number, company name, company structure, job title and business affiliations.
2. How do we collect your Personal Data?
   We collect personal data that you voluntarily provide to us, for example when (i) you communicate with us via e-mail or other channels and/or (ii) when you sign up for or ask us to send you newsletters or other (non-marketing) materials. In some cases your Personal Data has been supplemented by information retrieved from other sources, including searches via publicly available search engines, sector-specific newsletters, social media and your employer’s website, for the purpose of confirming your current professional position.
3. How do we use your Personal Data?
   We use the Personal Data we collect for communication purposes, including: (i) to send you newsletters and other information about GHP; and (ii) to maintain our list of contacts. We do not make your Personal Data available to any third party.
4. Why do we process your Personal Data and on what legal basis?
   As set out above we process your Personal Data for communication purposes. We rely on our legitimate interests in maintaining business relationships and communicating with you as a business contact about GHP’s activities. We consider that our legitimate interests are in compliance with the Regulation and your legal rights and freedoms.
5. With whom do we share your personal data?
   In the context of the purposes mentioned above, we may share your personal data with third parties, such as parties that provides CRM services for GHP, including but without limitation Salesforce.

We will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your Personal Data when disclosing your Personal Data to a third party. For example, we will enter into data processing agreements with relevant parties (providing for restrictions on the use of your Personal Data and obligations with respect to the protection and security of your Personal Data).

6. How long do we keep your Personal Data?
   Your Personal Data will be saved for the specified purposes mentioned above for as long as you are a business contact to us. Your personal data will be deleted when it is no longer reasonably required for the specified purposes mentioned above or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data. You can unsubscribe at any time, if you no longer wish to receive communications and invitations from GHP. If you choose to unsubscribe, we will cease to send you such communication and invitations as mentioned above.
7. Cookies
   We use so-called cookies. Cookies do not cause any damage to your computer and do not contain any viruses. Cookies serve to make our website more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies”. They are automatically deleted at the end of your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser the next time you visit our website.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or generally and activate the automatic deletion of cookies when closing the browser. When cookies are deactivated, the functionality of this website may be limited.

8. Data Security
   GHP has implemented appropriate technical and organisational security measures to help protect your Personal Data against loss and to safeguard against access by unauthorised persons.
9. Your Rights
   You have the right to know what Personal Data we process about you and may request a copy. You are also entitled to have incorrect Personal Data about you corrected and you may in some cases ask us to delete your Personal Data. You can also object to certain Personal Data about you being processed and request that processing of your Personal Data be limited. Please note that the limitation or deletion of your Personal Data may mean we will be unable to provide the communications and invitations described above. You also have the right to receive your Personal Data in a machine-readable format and have the data transferred to another party responsible for data processing. If you disagree with how we process your Personal Data, you are also entitled to report this to the Dutch Data Protection Authority.
10. Updates to this Data Protection & Privacy Policy
    This Data Protection & Privacy Policy was last updated in May 2018. We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the changed Data Protection & Privacy Policy on our website or publish it otherwise. The changes will take effect as soon as they are posted on this website.
11. How to contact us
    If you have any questions about how we process your Personal Data, please feel free to contact us at healthcare@gildehealthcare.com.

Sustainable Risk Finance Disclosure Regulation (2019/2088) (the Disclosure Regulation)

Gilde Healthcare Partners B.V. (GHP)makes the following disclosures in accordance with articles 3(1) and 5(1) of the Disclosure Regulation.

Sustainability risk policies

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”. For GHP, sustainability risks are risks which, if they were to materialize, would cause a material negative impact on the value of the portfolios of its alternative investment funds(AIFs).

Before any investment decisions are made on behalf of an AIF, GHPcompletes a process that aims at identifyingthe material risks associated with each proposed investment; these will include relevant sustainability risks.

The investment advisory committeesof GHP aim to assess the identified risks alongside other relevant factors set out in an investmentproposal. Following its assessment, the relevant investment advisory committee advises on the investment having regard to the relevant AIF’s investment policy and objectives. The board of directors of GHP resolves upon investment decisions taking into consideration the advice of the investment advisory committees. It is the intention that throughout the entire process, relevant sustainability risks are identified and assessed using the same process as is applied to other relevant risks affecting the AIFs and investments made on their behalf.

Remuneration policy

GHPpays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account performance criteria including compliance with all policies and procedures(e.g. relating to the impact of sustainability risks on the investment decision making process).

No consideration ofsustainability adverse impacts

With due observance ofarticle 4 sub 1 (b) of the SFDR, GHP declares that it currently does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the SFDR and therefore does not make the disclosures as described in such article. Given the size and scale of the activities of GHPthese considerationsand disclosures would not be proportional.Besides the proportionality, the regulatory technical standards as referred to in article 4 sub 6 and 7 of the SFDR which provide for the content, methodologies and presentation of such disclosures have not yet entered intoforce. GHP will reconsider whether it will or should make disclosures on the adverse impacts of its investment decisions on sustainability factors in the manner as set forth in article 4 sub 1 (a) oftheSFDR once these regulatory technical standards have entered into force.