Privacy Policy

Introduction

Treviox B.V. ("we", "our", "us", or "Treviox") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website treviox.world or use our wealth management services.

As a financial services provider operating in the Netherlands, we comply with the General Data Protection Regulation (GDPR), the Dutch Data Protection Act (UAVG), and other applicable privacy laws. Treviox acts as the Data Controller for the personal data we process.

Data Collection

The data we collect includes personal information that you voluntarily provide to us, information automatically collected through your use of our services, and information obtained from third-party sources as permitted by law. We collect this information to provide our wealth management services effectively and maintain our client relationships.

Information You Provide: When you contact us, request our services, or engage with our website, we may collect:

• Personal identification information (name, address, date of birth, nationality)
• Contact details (email address, phone number, postal address)
• Financial information (income, assets, investment objectives, risk tolerance)
• Professional information (occupation, employer, business interests)
• Communication records and preferences
• Documentation required for regulatory compliance (ID verification, source of funds)

Automatically Collected Information: When you visit our website, we may automatically collect:

• Device information (IP address, browser type, operating system)
• Website usage data (pages visited, time spent, click patterns)
• Cookies and similar tracking technologies (see our Cookie Policy)
• Location data (general geographic location based on IP address)

How We Use Your Information

We explain how we use your information to provide our wealth management services and fulfill our legal obligations. The use of your data is always based on a lawful basis under GDPR, including contract performance, legitimate interests, legal obligations, and consent where applicable.

Service Provision: We use your personal information to:

• Provide wealth management and financial advisory services
• Assess your financial needs and investment suitability
• Manage your investment portfolios and accounts
• Process transactions and maintain accurate records
• Communicate with you about your investments and our services
• Provide customer support and respond to inquiries

Legal and Regulatory Compliance: We process your data to:

• Comply with anti-money laundering (AML) and know-your-customer (KYC) requirements
• Meet regulatory reporting obligations
• Prevent fraud and financial crime
• Maintain proper books and records as required by law
• Respond to regulatory inquiries and legal proceedings

Business Operations: We may use your information to:

• Improve our services and develop new offerings
• Conduct risk management and internal audits
• Analyze website usage and optimize user experience
• Send relevant marketing communications (with your consent)

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal bases:

• Contract Performance: Processing necessary to perform our wealth management services
• Legal Obligation: Compliance with financial services regulations, AML/KYC requirements
• Legitimate Interests: Risk management, fraud prevention, business development
• Consent: Marketing communications, optional data processing
• Vital Interests: Protection of life or physical safety in emergency situations

Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: Trusted third parties who assist in providing our services (custodians, technology providers, professional advisors)
• Regulatory Authorities: Financial regulators, tax authorities, and law enforcement when legally required
• Legal Proceedings: Courts, arbitrators, and legal counsel in connection with legal matters
• Business Transfers: In connection with mergers, acquisitions, or asset sales (with appropriate safeguards)
• Emergency Situations: To protect the safety and security of individuals or prevent fraud

All third parties with whom we share your data are bound by appropriate confidentiality and data protection obligations.

Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with our legal and regulatory obligations. Our data retention periods are based on:

• Active Client Relationships: Throughout the duration of our service relationship
• Regulatory Requirements: Minimum 7 years after relationship termination (as required by Dutch financial regulations)
• Legal Claims: Until the expiration of applicable limitation periods
• Marketing Data: Until consent is withdrawn or legitimate interests no longer apply

After the retention period expires, we securely delete or anonymize your personal data unless longer retention is required by law.

International Data Transfers

Your personal data is primarily processed within the European Economic Area (EEA). When we transfer data outside the EEA, we ensure appropriate safeguards are in place, including:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules
• Your explicit consent for specific transfers

Your Rights

Under GDPR and Dutch data protection law, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Correct inaccurate or incomplete personal data
• Right to Erasure: Request deletion of your personal data (subject to legal obligations)
• Right to Restrict Processing: Limit how we use your personal data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Withdraw consent for processing based on consent
• Right to Lodge a Complaint: File a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

Please note that some rights may be limited by our legal and regulatory obligations in the financial services sector.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit and at rest
• Multi-factor authentication and access controls
• Regular security assessments and penetration testing
• Employee training on data protection and security
• Incident response and breach notification procedures
• Secure disposal of data and equipment

While we strive to protect your personal data, no method of transmission or storage is 100% secure. We encourage you to take steps to protect your own information, such as using strong passwords and keeping your login credentials confidential.

Cookies and Tracking

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyze website usage. For detailed information about our use of cookies, please refer to our Cookie Policy.

You can manage your cookie preferences through your browser settings or our cookie consent banner when you first visit our website.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make significant changes, we will:

• Post the updated Privacy Policy on our website
• Update the "Last updated" date at the top of this policy
• Notify you of material changes via email or website notice
• Obtain your consent for changes that materially expand our use of your personal data

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Contact Information

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or need to contact us regarding your personal data, please contact us using the information below:

We will respond to your privacy-related inquiries within 30 days of receipt, or sooner as required by applicable law.

Regulatory Information

Treviox B.V. is a Dutch company registered with the Chamber of Commerce (KvK) under number 60483972. Our VAT number is NL892106743B01. We operate under the supervision of relevant Dutch and European financial authorities.

If you believe we have not handled your personal data in accordance with this Privacy Policy or applicable law, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.