Privacy Policy – Global Diversified Fund Management

Last updated: November 2025

1. Who We Are

Global Diversified Fund Management B.V., registered in the Netherlands with the Chamber of Commerce under number 84352795, having its registered address at Beursplein 5, 1012 JW Amsterdam, The Netherlands (“GDFM”, “we”, “our”, or “us”), is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, share, and protect your personal information when you visit our website www.gdfm.nl. We comply with the General Data Protection Regulation (GDPR) and all applicable Dutch data protection laws.

By agreeing to our website Terms and Conditions, you also agree to this Privacy Policy.

2. What Data We Collect

We may collect the following types of data you provide through our website:

– Personal identification information (name, email address, phone number, etc.)
– Company name and position
– IP address
– Browser and device information

We do not collect financial or payment details through our website. We also do not collect sensitive personal data (such as health information) or any personal data from minors.

3. How We Collect Your Data

We may collect and process personal data when you:

– Fill out a contact or service form or register online on our website
– Email or call us
– Contact us through our website
– Use or view our website (e.g., via cookies, analytics, or other tracking tools)
– Provide feedback, complete a survey, or contact customer support
– Sign a service agreement or register for updates or newsletters

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

– Consent: e.g., submitting online forms, accepting analytics cookies
– Contractual necessity: when personal data is needed for providing our services
– Legal obligations
– Legitimate interests: such as communicating with clients or promoting our services

5. How We Use Your Data

We use your personal data to:

– Provide and manage our services
– Respond to your inquiries and communicate with you
– Provide updates, newsletters, and marketing communications (with your consent)
– Improve the performance, security, and functionality of our website
– Comply with legal and regulatory obligations

6. Data Retention

We retain personal data only as long as necessary for the purposes described in this Privacy Policy or as required by law. We generally retain data for a minimum of two years or longer where legally permitted. If data is no longer needed, we securely delete or anonymise it.

7. Sharing Your Data

We do not sell your personal data.

By agreeing to our website’s Terms and Conditions, you consent to us sharing your data with selected third-party service providers, including:

– Analytics providers, such as Google Analytics, to monitor and improve website performance.

These companies act as data processors and may only process your data according to our instructions and applicable laws.

8. Your Rights Under GDPR and Dutch Law

You have the right to:

– Access your personal data (a reasonable fee may apply in limited cases)
– Request correction of inaccurate or incomplete data
– Request erasure of your data, under certain conditions
– Object to or restrict certain types of processing
– Withdraw your consent at any time
– Request data portability, under certain conditions
– Opt out of marketing communications
– File a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

To exercise your rights, please contact us at info@gdfm.nl.
We will respond within one month.

9. Cookies and Tracking Technologies

Cookies are small text files stored on your device that allow us to collect standard internet log information and visitor behavior data. When you visit our website, we may collect information automatically through cookies or similar technologies.

We use the following categories:

– Necessary cookies: Enable core website functions. Cannot be disabled.
– Functional cookies: Facilitate features such as content sharing or feedback tools.
– Analytics cookies: Measure visitor behaviour and website performance.
– Performance cookies: Improve page loading, responsiveness, and usability.
– Advertisement cookies: Provide personalised ads and measure ad campaign effectiveness.

You can manage or disable cookies using your browser settings or via our cookie consent banner.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data from unauthorized access, alteration, disclosure, misuse, or loss. While we take data protection seriously, no system can guarantee absolute security.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The most recent version will always be available on our website. Continued use of the website after any updates constitutes your acceptance of the revised policy.

12. Third-Party Links

Our website may include links to third-party websites. This Privacy Policy applies only to our website. When visiting external sites, we encourage you to review their privacy policies.

13. Contact

If you have questions or concerns about this Privacy Policy or our handling of your personal data, please contact us:

Global Diversified Fund Management B.V.
Beursplein 5
1012 JW Amsterdam
The Netherlands
Email: info@gdfm.nl

If you believe your personal data has been processed unlawfully, you have the right to file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens): https://autoriteitpersoonsgegevens.nl.

We encourage you to contact us first so that we can address your concerns promptly.