Privacy policy

This privacy policy governs the collection, storage and use of personal information which may be collected by INCOFIN, via our website at [•] (“Website“). It provides you with details about the personal information we collect from you, how and why we use your personal information and your rights to control personal information we hold about you.  Please read this privacy policy carefully.

This privacy policy was last updated on 20 February 2018.

Who we are

Incofin Investment Management Comm. VA (‘INCOFIN’ or ‘we’), ‘Commanditaire Vennootschap op Aandelen’ (limited partnership with share capital) having its registered office at  2610 Antwerp, Sneeuwbeslaan 20, Belgium and registered in the register of legal entities of Antwerp with company registration number 0815.870.958 and VAT number BE 0815.870.958 (e-mail:

As a data controller, we respect your right to privacy and will only process personal information you provide to us in accordance with applicable data protection laws, which include (i) the EC Data Protection Directive (Directive 95/46/EC), as transposed into national law by the relevant EU Member States, and as will be replaced by the General Data Protection Regulation (Regulation 2016/679) on 25 May 2018 (“GDPR“); and (ii) other applicable privacy laws.

We do not and will not knowingly collect information from any unsupervised child under the age of 16.

The personal information we collect about you

When you access and browse the Website (including when you submit personal information to us through data entry fields on the website), we may collect the following information (called together ‘personal data’) from you:

  • Cookies: this covers data on when you access the Website, any personalized settings, and your browsing behaviour.

We collect this information through automated means as you browse the Website. You will be asked to consent to the use of cookies through a Cookie Banner. Cookies are necessary to optimize navigation and your browsing experience. For more information see our Cookie Policy.

  • Identification data: should it be possible to register on the Website and you decide to register, we may collect the following data: full name (first and last name), e-mail address, IP address, country of residence, telephone number. This identification data are provided by yourself when registering in the Website.

For which purposes and on which legal basis we process your personal data

We (or third party data processors acting on our behalf) may collect, store and use your personal data listed above for the following purposes:

1.1          For the management of the account

INCOFIN must process your personal data for the following purposes:

  • to make the Website available to you
  • to help you create your account, if applicable
  • to provide you with the services that you request, if applicable

1.2          For the legitimate interests of INCOFIN

INCOFIN may also process your data for the realization of its legitimate interests. To this end, INCOFIN strives to maintain a fair balance between the need to process data and the preservation of your rights and freedoms, including the protection of your privacy:

  • to provide you with content which is tailored to your individual needs;
  • to evaluate and improve our Website;
  • we may also collect anonymised details about visitors to our website for the purposes of aggregate statistics or reporting purposes, as further described in our Cookie Policy.

1.3          Other

Subject to obtaining your prior consent in a specific way, INCOFIN may process your personal electronic contact data, i.e. your mobile phone number and e-mail address, in order to send you personalized information, advertisements or proposals, through direct marketing or newsletters.

How we share your personal data

We will not disclose, sell or rent your personal data to any third party. We may only share personal data with affiliates who perform data processing activities on our behalf.

We may disclose your personal information where we are required to do so (i) by applicable law, (ii) by a governmental body, (iii) by a law enforcement agency or (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity.

In accordance with the principles set out below, we will delete personal data once it is no longer required to fulfil the purposes outlined in this Privacy Policy, unless their retention would remain required for other fundamental purposes, including but not limited to complying with our legal obligations, handling claims and resolving disputes.

For the retention period of any cookies used on this Website we refer to our Cookie Policy.

What are your rights?

1.1          Access, rectification, erasure, portability and objection rights

For all the purposes defined here above, you have the following rights as a data subject:

  • the right to ask us to provide you with copies of personal information that we hold about you at any time, which include the right to ask us: whether we process your personal data, for what purposes; the categories of data; the recipients to whom the data are shared;
  • the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge;
  • the right to erasure within the limits afforded by data protection legislation.
  • the right to data portability within the limits afforded by data protection legislation.

Where INCOFIN processes your data for its legitimate interests, you have the right to object to the processing of your personal data. However, according to its legitimate interests, INCOFIN may continue to process your data after a careful balancing of your interests with the ones of INCOFIN.

1.2          Right to lodge a complaint

  • In the event of a conflict concerning the processing of your personal data, you can contact us:
  • By mail:
  • By email at service:
  • By phone at number [•] ;
  • By fax to the number [•] ;

You can also lodge a complaint to the Privacy Commission either by post at rue de la Presse 35, 1000 Brussels, or by e-mail at or by phone at +32 2 274 48 00.

How long do we keep your personal data?

INCOFIN will not store your personal data beyond the time necessary for the performance of the purposes for which the data is processed. Specifically, INCOFIN distinguishes between a retention period and an archiving period:

  • The retention period is the maximum period of use of your personal data for specific purposes: all data is kept during [•] ;
  • The archiving period meets INCOFIN’s legal obligations as well as the legal need to retain your data beyond the retention period for evidentiary purposes or to respond to requests for information from the competent authorities, in particular: account information is retained for up to [•] years after it is closed

How do we protect your personal data?

INCOFIN has taken appropriate technical and organisational measures to safeguard and protect your personal data, against unauthorized or unlawful processing and against accidental destruction, loss, access, misuses, damage and any other unlawful forms of processing of the personal data in our possession.

Updates to our Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in our personal data practices. We will post a prominent notice on our Website to notify you of any significant changes to our Privacy Policy and indicate at the top of the notice the date at which it was last amended.

How to contact us?

If you have any questions or comments about this Privacy Policy or about how we collect, store and use your personal information, or if you would like to exercise your rights, or to update the information we have about you or your preferences, please contact us here:

Telephone:                    03 829 25 36


Post:                            Sneeuwbeslaan 20, pb 2, 2610 Wilrijk