Privacy policy

This Privacy Policy governs the collection, storage and use of personal information 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 in relation thereto.  Please read this Privacy Policy carefully.

This Privacy Policy was last updated on 24 May 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 of your personal data, 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 General Data Protection Regulation (Regulation 2016/679) (“GDPR“); (ii) any additional national legislation and (iii) other applicable privacy laws.

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 (“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: when you decide to register on the Website we collect your e-mail address. Other possible information we may at any point in time collect an process from you is: full name (first and last name), e-mail address, country of residence, telephone number national register number, bank account number and any other information necessary for know your customer or anty money laundering purposes. Identification data are always provided by yourself via the Website or otherwise.

IP addresses of Website visitors are also collected but are only used for statistical and reporting purposes as further described in our Cookie Policy. IP addresses are not linked to any personal information.

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          Purposes of the processing of personal data

INCOFIN processes your personal data for the following purposes:

  • to make the Website available to you
  • to provide you with the services or the information that you request or which is adapted to your needs (newsletters, direct marketing, etc);
  • for evaluating and improving our Website;
  • to serve as evidence;
  • for establishing, exercising, defending and safeguarding the rights of INCOFIN or the persons it may represent, for example in disputes;
  • to arrive at aggregated information that no longer includes personal data for statistical and reporting purposes.

1.2          Legal basis for the processing of personal data

We base the processing of your personal data on one or more of the following legal grounds:

  • your consent: your consent may be requested in connection with the use of your personal data for certain purposes; in such a case you can withdraw your consent at any time;
  • to be able to conclude an agreement: when in the process of becoming an investee of one of the funds managed or advised by us, we may have to process certain data due to our statutory obligations in order to assess whether you can actually be accepted as investee;
  • to be able to execute an agreement correctly: in case you are an investee of one of the funds managed or advised by us shareholder of INCOFIN, we must be able to supply you with information regarding your the associated rights and obligations in certain cases;
  • for the realization of a legitimate interest: INCOFIN may process your data in order to function as a company and to fulfill its corporate purpose; this is called “legitimate interest”; 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.

What are your rights?

1.1          Access, rectification, erasure, portability and objection rights

When your personal data is processed you have the following rights:

  • the right to access the data that we process about you;
  • the right to request us to update or correct any outdated or inaccurate personal data that we hold about you;
  • the right to erasure of and restriction of processing of your personal data within the boundaries specified in the privacy legislation;
  • the right to request that we transfer your data to a third party within the limits specified in the privacy legislation;
  • in case INCOFIN processes your data for its legitimate interests, you have the right to oppose such processing of your personal data; in this case INCOFIN may only proceed with the processing of your data if compelling legitimate grounds apply and after careful consideration of your interests and the interests of INCOFIN;
  • if your personal data are processed for direct marketing you have the right to object to such processing and INCOFIN must further refrain from processing your personal data for these purposes.

If you wish to exercise any of the above rights, please contact us:

  • by mail: Incofin, Sneeuwbeslaan 20 postbus 2, 2610 Wilrijk
  • via e-mail:
  • Via phone: 03 829 25 36
  • Via fax: 03 740 78 28

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: Incofin, Sneeuwbeslaan 20 postbus 2, 2610 Wilrijk
  • By email at:
  • Via phone: 03 829 25 36
  • Via fax: 03 740 78 28

You can also lodge a complaint to the Commission for the Protection of Privacy 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 we share your personal data

Except in the cases specified below we will not disclose, sell or rent your personal data to any third party. We may only share personal data with (affiliated) companies who perform data processing activities on our behalf.

We may disclose your personal information with third parties 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.

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. For example, you are an investee of any of the funds managed or advised by INCOFIN, your personal details will be kept as long as you remain an investee.

The starting point for storing personal data is the legal retention period. Such a period is often up to 10 years after the end of an agreement or 5 years after the last processing for which the information was originally obtained. If the law does not prescribe a period, the archiving may be shorter. The storage may also be longer we have to be able to use the data for proof purposes in a legal procedure.

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.

You also have an important role to play in securing your personal data, e.g. by keeping your PC up-to-date and keeping your login data confidential and secure.

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:

Phone:              03 829 25 36


Post:                Incofin, Sneeuwbeslaan 20 postbus 2, 2610 Wilrijk