Capital Circle

Privacy

Privacy Statement

This privacy statement applies to:
KOM Group B.V. (Chamber of Commerce no. 58526382), based in Delft, and
KOM Group Security Trustee Foundation (Chamber of Commerce no. 65696190).

KOM Group B.V. (operating under the name Capital Circle) and the KOM Group Security Trustee Foundation are joint controllers for the processing of personal data, as detailed in this privacy statement.

Contact Information

KOM Group B.V.
Bahialaan 100 unit 4.13
3065 WC Rotterdam
🌐 www.capitalcircle.nl
📧 info@capitalcircle.nl
📞 +31 (0)15 760 00 19

In this statement, "we" refers to both KOM Group B.V. and the Security Trustee Foundation. Where only one party is mentioned, the provisions apply solely to that party.

Personal Data We Process

We process your personal data because you are interested in and/or use our services as a (prospective) investor, project owner, or otherwise maintain a (business) relationship with us and/or visit our website.

We may process the following data, depending on the nature of our relationship:

  • First and last name
  • Gender
  • Date and place of birth
  • Address
  • Chamber of Commerce number
  • Telephone number
  • Email address
  • IP address
  • Other data you actively provide, such as through account creation, correspondence, or phone calls
  • Internet browser and device type
  • Bank account number
  • Copy of ID (for project owners, with BSN and photo redacted)

Providing certain data is a necessary condition to enter into an agreement with us, especially if you are a project owner or investor.

Special or Sensitive Personal Data

We process the following sensitive data:

  • Creditworthiness checks for project owners

If you wish to obtain a loan via Capital Circle, we conduct a creditworthiness check to protect you, our investors, and ourselves, and to prevent unaffordable obligations or misuse.

This includes:

  • Verification of the data you provide
  • A personal interview
  • Online checks, including insolvency records
  • A background screening by our payment service provider, GoCredible B.V., to assess criminal records or sanctions listings. Only essential data is shared with GoCredible for this specific purpose. The outcome shared with us is simply: approved / not approved.

Purposes and Legal Grounds for Processing

We process your data for the following purposes:

  • To enter into and fulfil agreements with you (Article 6(1)(b) GDPR)
  • To inform you of new projects or services via newsletters or direct marketing, based on:
    • our legitimate interest (Article 6(1)(f) GDPR),
    • previous service provision (Article 11.7(3) Dutch Telecommunications Act), or
    • your consent (Article 6(1)(a) GDPR)
  • To conduct credit checks (Article 6(1)(f) GDPR), or with your consent if performed by a third party (Article 6(1)(a) GDPR)
  • To communicate with you about services and updates (Article 6(1)(b)/(f) GDPR)
  • To provide account creation options
  • If you apply for a job with us
  • To analyse your website behaviour to improve our platform and offerings (Article 6(1)(f) GDPR)
  • To comply with legal obligations such as those under financial supervision or tax laws (Article 6(1)(c) GDPR)

Automated Decision-Making

Capital Circle does not use fully automated decision-making that produces legal or similarly significant effects.

Retention Periods

We retain personal data only as long as necessary for the intended purpose:

  • Investors and project owners: for the duration of the relationship and up to five years thereafter
  • Prospective investors: while the account is active and up to two years thereafter
  • Prospective project owners (no agreement reached): up to two years
  • Suppliers and similar parties: duration of relationship and up to two years thereafter
  • Job applicants: up to four weeks after rejection, or up to one year if consent is given to retain data for future vacancies

Sharing Personal Data with Third Parties

We share your data with third parties only when necessary to fulfil our agreement or legal obligations. We enter into processing agreements with parties who process data on our behalf to ensure data security and confidentiality.

Examples include:

  • Payment service providers such as OPP (with your consent)
  • Collection agencies, bailiffs, or lawyers acting on behalf of the Security Trustee Foundation (based on legitimate interest)

We remain the sole data controller even when using processors such as:

  • IT/cloud service providers
  • Software vendors
  • Marketing agencies

Credit Check via EDR

If you wish to become a project owner, we will share your data with Economic Data Resources B.V. (EDR). EDR will assess your creditworthiness and use your data to verify your business details and management history.

More information about EDR and your rights (including access, correction, objection, and deletion) is available here:
🔗 https://www.edrcreditservices.nl/privacy-statement

Cookies or Similar Technologies

Capital Circle uses functional and analytical cookies. These are small text files stored in your browser when you visit our site. They help ensure proper functionality and remember your preferences.

Upon first visit, you were informed of these cookies and asked for consent.

You can disable cookies via your browser settings or delete previously stored cookies.

Access, Modification, or Deletion of Data

You have the right to:

  • Access, correct, or delete your personal data
  • Withdraw consent at any time (if applicable)
  • Object to data processing (Article 21 GDPR)
  • Request data portability (if processing is based on consent or contract and automated)

Send your request to: info@kapitaalopmaat.nl

To verify your identity, we may ask for a copy of your ID. Please black out your photo, MRZ, passport number, and BSN for your privacy.

We will respond within four weeks.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):
🔗 https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens/tip-ons

Data Security

We take data security seriously and implement appropriate measures to prevent misuse, loss, unauthorised access, and disclosure.

If you suspect your data is not adequately protected, please contact our support team or email us at info@capitalcircle.nl.