Hamster Capital B.V. ("Hamster") enables investors to invest in
early-stage and growth-focused businesses, enables entrepreneurs to raise capital for those
types of businesses from a range of investors, and for venture capitalists raising capital
from Limited Partners, all through its online platform. This Privacy Notice describes what
information Hamster collects and how it is used, and applies to all services that Hamster
offers and all persons that Hamster engages with. Throughout this Privacy Notice users of
the services and other persons with whom we interact will be referred to as "you", and
Hamster will be referred to as "we" or "us".
1. Information That We Collect
We collect information on you in the following ways, and treat
all of this information as your "Personal Data":
- Information you give us. When you
use www.Hamster.com and any of its sub-domains (the "Website"), we may ask you to
provide certain personal information, such as your contact details, banking details, tax
information, demographic information, employment and educational history and, in the
case of entrepreneurs seeking to raise capital through the Hamster platform, information
about you in connection with your business. Much of this information enables us to
comply with our legal obligations or fulfil our contractual arrangements with you and
other parties, and sharing this information may be necessary for us to provide our
services. Please note that, in the case of entrepreneurs who provide us with customer
data, it is your responsibility to ensure that you have the appropriate grounds to do
so, and that this is done in a secure manner.
- Information we get from your use
of our services. Hamster collects information about the services you use and how you use
them, such as when you view and interact with the Website or our advertisements. In
addition, we may gather certain information about you, including details of your
operating system, browser version, domain name and IP address, and the details of any
website from which you accessed the Website. We may also collect your Personal Data when
you interact with our employees on the phone or in person and we record those
conversations, either because we are required to do so under regulation, or for training
purposes so that we can improve our services.
- Cookies. Hamster may set and
access cookies on your computer, which are small files that reside on your computer's
hard drive that generally contain an anonymous unique identifier and are accessible only
by the website that placed them there and not any other sites. To the extent that we
have third-party advertisements on the Website, those third parties may also place, set
and access cookies on your computer. They do this to track how many unique users have
seen a particular advertisement and to provide advertisements that are more relevant to
a given user's interests. We do not have access to these cookies and, other than
allowing them to be served, we play no role in these cookies at all. You can choose to
enable or disable cookies in your web browser. By default, your browser will accept
cookies, but this can be altered. In addition, you may delete cookies that have already
been placed on your hard drive. For further details please consult the help menu in your
browser. Disabling or deleting cookies may prevent you from using the full range of
services available on the Website.
- Information from third parties or
publicly available sources. We may also collect your Personal Data (such as contact
information or purchasing habits) from third parties or publicly available
2. Data Protection Principles
Hamster is committed to protecting the privacy and security of
your Personal Data. Hamster is a "data controller", meaning that we are responsible for
deciding how we hold and use your Personal Data. We will comply with data protection law,
which says that Personal Data must be:
- Used lawfully, fairly and in a
- Collected only for valid purposes
that we have clearly explained to you and not used in any way that is incompatible with
- Relevant to the purposes we have
told you about and limited only to those purposes.
- Accurate and kept up to
- Kept only as long as necessary for
the purposes we have told you about.
- Kept securely.
3. How We Use Information That We Collect
We use the Personal Data that we collect for the following
To comply with our legal or regulatory obligations, we may use
your Personal Data (and if you do not provide this Personal Data we may not be able to
provide our services to you):
- To confirm your identity in order
to create your account and ensure that you are eligible to use the services provided on
- To conduct required anti-money
laundering checks on you, and associated financial crime and fraud monitoring, in
connection with transactions you may conduct through the Website.
- In the case of investors, to
confirm that you are eligible to make investments through the Website in accordance with
To carry out our obligations under our contracts with you or
others, we may use your Personal Data:
- To process and administer payments
in connection with the services provided on the Website.
- In the case of entrepreneurs
seeking capital and certain individuals connected to the fundraising business, to assess
your suitability for and application to fundraise on the Website, to verify and approve
the disclosures you make in your campaign to potential investors, to provide you with
any campaign marketing and PR services, to facilitate the investment transactions, and
exercise any rights that Hamster may have as nominee.
- In the case of investors, to
facilitate any investments you may make, to exercise any rights you may have in
connection with those investments including by Hamster as nominee, and to provide
fundraising businesses with information about the progress of their campaigns and your
investments in their businesses.
- In the case of investors who have
completed investments in fundraising businesses, to provide those businesses with
information to fulfil obligations to you, and ensure compliance with their corporate or
regulatory requirements, such as tax and shareholder reporting.
- In the case of investors who have
been referred to Hamster by an independent financial advisor or wealth manager, to share
information that we hold about you with your financial advisor or wealth manager.
- To provide you with information
about your account, including any campaigns you have created and any investments or
payments you have made or have indicated an interest in making.
- To facilitate the participation of
you or your business in any supplemental programmes that Hamster may offer.
We have a legitimate interest in ensuring that the Website and
our services operate effectively, and to do this we may use your Personal Data:
- To monitor, improve and administer
the Website and the services provided on the Website.
- To contact you to ensure customer
satisfaction in respect of our role as a service provider and assist you in getting the
best value from our services.
- To respond to customer support or
other enquiries requesting information. We may also intercept, record and/or monitor any
communication(s) (including telephone calls or other electronic communications) between
you and us. We may do so in order to resolve queries in the future and for the purposes
of ensuring security, staff training and complying with our regulatory and legal
responsibilities. In the case of communications by email you should note that, as emails
are not encrypted (and may therefore be intercepted by third parties) and as the
identity of the sender cannot be confirmed, you must NOT provide your security details
We also have a legitimate interest in communicating with you and
others, facilitating communications between you and others, publicising our business,
supporting industry research, and making sure that marketing, advertising, PR, and content
we provide is effective, so we may use your Personal Data:
- To enable us to conduct surveys
and analysis, aggregate user profiles, identify other potential customers, or enable us
or third party academics to conduct research.
- To advertise, publicise and
promote our business, and to measure, understand, or improve the effectiveness of
advertising we provide to you and others.
- In the case of individuals or
businesses that have indicated an interest in Hamster or the businesses fundraising on
the Website, to contact you to provide you with information about us or fundraising
businesses, and on other selected products and services that we think may be of interest
to you (unless you have asked us not to do so).
- To create and share informative
content about our business or the industry in which we operate, including contacting you
about reports we publish and new products we launch.
- In the case of our commercial and
investment partners providing goods or services to investors or entrepreneurs, to pass
on information in relation to those goods or services.
- In the case of journalists who are
working in the sector in which we operate or related sectors, to provide you with news
and updates about our business, businesses that are fundraising on our Website and other
relevant industry information.
- In the case of referred investors,
to inform the party that has referred you that you have joined Hamster.
- In the case of investors who have
completed investments in fundraising businesses, to enable those businesses to contact
you with news of developments in the business and keep you informed as to your
In certain other circumstances we may seek your consent to use
your Personal Data. In this case we will ask you to confirm your agreement to your Personal
Data being processed for a specific purpose, either through the Website of by another
4. Transparency and Choice
Users of the Website can manage the kinds of emails received from
us by visiting the "Notifications" tab in your Hamster account. To unsubscribe from
emails you can also use the 'unsubscribe' link on the emails we send you. For non-users of
the Website, please notify us using the contact details below if you no longer wish to
receive our updates.
You may, through the Website, alter your cookie preferences and
your preferences for other monitoring, analysis or tracking activity we conduct, based on
industry-standard classifications. This can be accessed by visiting the "Cookies &
Marketing Preferences" tab in your Hamster account. The categories are: 'strictly
necessary', 'performance', 'functionality and profile', and 'targeting' cookies. Making
alterations to these preferences will determine which category of cookies we may place and
access on your computer and the other monitoring, analysis or tracking activity we conduct.
It is important to note that disabling or making changes to these preferences may prevent
you from using the full range of services available on the Website.
5. Accuracy and Retention of Personal Data
If you see that any of your Personal Data that is included in the
"Profile" section of your Hamster account is inaccurate, please revise or update it using
the Website. Alternatively, if you believe that any of the Personal Data we hold about you
is inaccurate, you may notify us using the contact details below in order to correct
It is your responsibility to ensure that any Personal Data you
have provided to us remains accurate and to notify us (either through the Website or using
the contact details below) if there are any changes in your Personal Data.
We will retain your Personal Data to fulfil the purposes outlined
in this Privacy Notice as long as you use the Hamster platform, and for at least six years
after that to comply with the legal and regulatory recordkeeping obligations we have.
6. Information That We Share
Any Personal Data that we collect will not be disclosed to any
third parties by Hamster and its affiliates, except under the following
- We may disclose certain of your
Personal Data to third party service providers solely in the course of their provision
of services to Hamster, and will take reasonable precautions to ensure that these
service providers are obliged to keep your Personal Data secure and confidential, in
compliance with relevant legal requirements. In some instances, your Personal Data may
be transferred outside the European Economic Area; if this is the case we will take
steps to ensure that the transfer is protected by safeguards provided under EU and UK
law, such as model contract clauses or the EU-US Privacy Shield. For more information on
these safeguards, please notify us using the contact information provided in
- We may disclose certain of your
Personal Data if we, in good faith, believe that we are required to do so by law,
regulation or the order of court or other legitimate government body or arbitration
panel. This includes, among other things, any Personal Data that may be requested by a
Tax Office and/ or a financial regulator.
- We may tell you in one of the
agreements that you enter into with us (for example the Membership Agreement that you
will enter into when signing up to the Website) or otherwise on the Website that we will
disclose certain of your Personal Data in connection with a transaction you conduct
through the Website. We may also tell you how we will use or disclose your Personal Data
when you provide information to us in certain other circumstances (for example if we are
collecting information about a potential fundraise on behalf of a fundraising
- We may disclose certain of your
Personal Data to third party academics to conduct research.
- In the event that we intend to
enter into a major corporate transaction, such as a sale of control of our or another
business on a stock exchange, we may disclose certain of your Personal Data to potential
buyers, underwriters or advisors. If we do this, we will take reasonable precautions to
ensure that the recipients of your Personal Data are obliged to keep it secure and
confidential, in compliance with relevant legal requirements.
- We may, from time to time, expand,
reduce or sell our business, and this may involve the transfer of certain divisions or
the whole business to other parties. Your Personal Data will, where it is relevant to
any division so transferred, be transferred along with that division and the new owner
or newly controlling party will, under the terms of this Privacy Notice, be permitted to
use your Personal Data for the purposes for which it was supplied by you.
7. Your Rights
You may have the right to request the following actions regarding
your Personal Data, which will be fulfilled in accordance with applicable data protection
- If you wish to raise an objection
to the processing of your Personal Data or wish it to be deleted you may do so by
notifying us using the contact details below. It may be possible for us to restrict
processing of your Personal Data, or to delete it so long as we can still comply with
our legal, regulatory and contractual obligations.
- If you wish to object to direct
marketing please notify us using the contact details below or, in the case of emails, if
you are a user of the Website you can go to the "Profile" section as set out above and
you may also use the 'unsubscribe' feature which you can find on our emails. To ensure
that we respect your request we may retain your contact details on a suppression
- Where we have processed
information with your consent then you may notify us using the contact details below to
withdraw that consent at any time. Withdrawing your consent will not affect the
lawfulness of any processing we conducted prior to your withdrawal, nor will it affect
processing of your information conducted in reliance on lawful processing grounds other
- If you would like to receive a
portable copy of the Personal Data you have provided to us, please notify us using the
contact details below.
- If you have created a Hamster
account, you can see some of the Personal Data we hold about you in the "Profile"
section of your account. If you wish to see a copy of all of your Personal Data that we
hold, please notify us using the contact details below. A request for a copy of your
Personal Data will generally be fulfilled free of charge, but we may charge a reasonable
fee if the request is manifestly unfounded, excessive, or repetitive, or if you request
multiple copies of the same information.
- If you have concerns about how we
collect and use your data, please contact us. If you are dissatisfied with our response,
you may have the right to raise your concern with the Dutch
Data Protection Agency (Dutch DPA)
8. Security of Your Personal Data
We endeavour to take all reasonable steps to protect your
Personal Data, including the use of encryption technology, which you can read more
about here. We also
require that all Hamster employees undergo mandatory data protection training. However, we
cannot guarantee the security of any Personal Data you disclose online. In using the
Website, you accept the inherent security implications of engaging in transactions online
over the internet, and you agree that you will not hold us responsible for any breach of
security unless we have been grossly negligent or in wilful default.
From time to time we may update this Privacy Notice. We will post
any Privacy Notice changes on this page and, if the changes are significant, we will provide
a more prominent notice (such as an email notification of Privacy Notice changes).
10. Communicating With Us
If you want to make a notification to us, or have any questions
about this Privacy Notice, you can reach us by sending a letter to:
Hamster Capital B.V.
or by sending an email to firstname.lastname@example.org
11. Cookies Preferences
Cookies are text files containing small amounts of information,
which your computer or mobile device downloads when you visit a website. When you return to
websites - or visit websites that use the same cookies - they recognise these cookies and
therefore your browsing device.
The type of cookie used on Hamster can be put into 1 of 4
categories, based on the International Chamber of Commerce guide to cookie categories:
Strictly Necessary, Performance, Functionality & Profile and Targeting.
Performance more information about cookie categories
Functionality and profile more information about cookie
Targeting more information about cookie categories
Strictly necessary more information about cookie
Occasionally your personal data may be used to allow Hamster to
better understand our audience and deliver more relevant advertising to you or people like
This may mean securely sharing some of your data with other
advertisers or platforms. Your information will be fully encrypted and used strictly in line