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Sprinque Finance B.V.End-Customer Privacy Statement

This is the Sprinque Finance B.V. end-customer privacy statement. As provided in the agreement between an end-customer and the relevant merchant, such merchant assigns its receivables against the relevant end-customer in connection with the use of Pay by invoice (the Receivables) to Sprinque B.V., who subsequently assigns those Receivables to Sprinque Finance B.V. (Sprinque Finance).

 

This end-customer privacy statement is meant for persons whose personal data are provided to

Sprinque Finance in connection with the assignment of the Receivables as described above. Data relating to a company under certain circumstances qualify as personal data. This is the case in the event of small companies with a sole or few proprietor(s) and/or name giver(s). Data in relation to contact persons and representatives of a company also qualify as personal data.

 

This end-customer privacy statement explains how Sprinque B.V. and Sprinque Finance use your personal data. This is required under the General Data Protection Regulation. Sharing these personal data with Sprinque Finance has no material implications for you. The administration of the Receivables is still managed by Sprinque B.V. on behalf of Sprinque Finance.

 

Joint responsibility

Sprinque B.V. and Sprinque Finance are jointly responsible for processing your personal data in

connection with the Receivables. Sprinque B.V.’s registered office is at Prinsengracht 526-H, 1017 KJ Amsterdam, the Netherlands, Chamber of Commerce 81977050. Sprinque Finance's registered office is at De Lairessestraat 145 A, 1075 HJ Amsterdam, the Netherlands, Chamber of Commerce 89647319.

Sprinque B.V. and Sprinque Finance have entered into an agreement covering their joint responsibility under the GDPR. You can request more information about this by sending an email to legal@sprinque.com.

Sprinque B.V. is the main point of contact regarding the data processing activities described in this end-customer privacy statement. For questions or comments about the processing of your personal data by Sprinque B.V. and Sprinque Finance, you can contact Sprinque B.V. via legal@sprinque.com.

Purposes of the data processing

Sprinque Finance is the creditor of the Receivables and processes your personal data in that context. In addition, Sprinque Finance may request Sprinque to provide data in relation to ultimate beneficial owners, directors and representatives of an end-customer to comply with statutory sanction regulations. These data will then be processed by its management, Trustmoore Netherlands B.V.

Sprinque B.V. manages the complete administration of your use of Sprinque B.V.’s services, collects and invoices the Receivables and conducts all communication with you. In this context, Sprinque processes the name and address details of your company (which in some circumstances qualify as personal data), other contact details, details of your order, information about payments, any correspondence and other communication for this purpose.

Sprinque Finance, as a creditor, may independently dispose of the Receivables and may, for example, pledge the Receivables to third parties. In such case, your data may also be provided to those third parties insofar necessary to, for example, collect pledged Receivables. Sprinque Finance may also retransfer the Receivables to Sprinque B.V. or transfer them to a third party for collection purposes, or outsource the debt collection to another party than Sprinque B.V., for example if you fail to meet your payment obligations.

 

Based on its legitimate interests, Sprinque Finance may decide to outsource the administration of the Receivables to a third party other than Sprinque B.V. Sprinque B.V. is then no longer jointly responsible for the processing of your personal data. If this situation arises, Sprinque Finance will inform you accordingly.

 

Sprinque B.V. and Sprinque Finance also process your data if necessary to establish, exercise or

defend their rights or to comply with legal obligations.

Payments to and by Stichting Sprinque

Sprinque Finance has outsourced the receipt of your payments and the making of return payments to Stichting Sprinque. This means that your name, address, place of residence, IBAN and (return) amounts can in some cases also be processed by Stichting Sprinque and its management, Trustmoore Netherlands B.V. For the processing of these data, Stichting Sprinque and its management Trustmoore Netherlands B.V. are independently responsible. Stichting Sprinque is established at De Lairessestraat 145 A, 1075 HJ Amsterdam, the Netherlands, Chamber of Commerce 89660684.

Sprinque B.V. is also the point of contact for the processing of your personal data by Stichting Sprinque and you can contact Sprinque B.V. via legal@sprinque.com.

Legal basis

The legal basis for the processing of your personal data by Sprinque B.V., Sprinque Finance and

Stichting Sprinque is the legitimate interest of Sprinque Finance to properly collect payment of the Receivables, to otherwise enforce or sell Receivables and to determine and defend its legal position. In addition, the processing of your personal data is necessary to comply with legal obligations, such as statutory sanction regulations and the obligation to keep your personal data for certain legal retention periods.

Third parties

Sprinque B.V., Sprinque Finance and Stichting Sprinque will disclose your personal data to third parties as follows:

  1. to service providers, such as accountants or debt collection agencies, for the purposes mentioned above;

  2. to third parties to whom the Receivables have been assigned, transferred or pledged. In such cases, these parties will only receive personal data insofar necessary to dispose of the Receivables, manage the payment obligations and the collections of payments;

  3. if Sprinque Finance requests Sprinque to provide data in relation to ultimate beneficial owners, directors and representatives of an end-customer to comply with statutory sanction regulations, these data will be processed by its management, Trustmoore Netherlands B.V.;

  4. in the cases mentioned under ‘Payments to and by Stichting Sprinque': the data mentioned are visible to the management of Stichting Sprinque, Trustmoore Netherlands B.V.;

  5. where there is a statutory duty to share the data;

  6. to third parties acting as processors on behalf of Sprinque B.V., Sprinque Finance or Stichting Sprinque within the meaning of the GDPR; or

  7. with your consent or otherwise in compliance with GDPR.

Sprinque B.V., Sprinque Finance and Stichting Sprinque will not provide your personal data to third parties located outside the EEA without an adequate protection level of personal data.

 

Retention period

Your personal data will be stored for no longer than is necessary for the purposes mentioned above. This means your personal data will in general be stored for 2 years after the Receivables have been paid, or longer where necessary to comply with statutory requirements.

Your rights

You have the right to request access to your personal information and, under certain circumstances, to have your personal data corrected, deleted and/or blocked. You can also request that the processing of your personal data be restricted and you can request a machine-readable version of your personal data for storage elsewhere.

 

You also have the right to object to your personal data being processed in connection with your

personal circumstances which outweigh the legitimate interests of the parties responsible for your processing as set out above .

 

You can file a complaint with the Dutch Data Protection Authority about how your personal data are processed at any time via https://autoriteitpersoonsgegevens.nl/.

Contact

If you wish to exercise any of the above rights or if anything is unclear, please contact

legal@sprinque.com.

Dated: 1 May 2023

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