Financierings-Maatschappij voor Ontwikkelingslanden N.V. (FMO) is the data controller of the personal data processed as described in this statement. You can find the FMO contact details on the last page of this statement.
In this privacy statement we explain why and how we use your personal information, your rights regarding this data, and the protections we have in place to safeguard it.
In this privacy statement you can read:
- What personal information we collect, use and store
- Why we use your personal data and our legal grounds for processing
- How FMO collects the information
- How long FMO keeps your information
- With whom FMO shares your information
- How we protect your personal data
- What privacy rights you have
- How and when we update this privacy statement
1. What personal information we collect, use and store
Website analysis
When you visit our website, we will anonymously analyze which pages are visited, how long visitors are on each page, and where visitors leave the website. We cannot see or identify who you are. We also collect information when your browser is providing this to us, such as what time somebody visits the website, what device is being used (such as a tablet, phone, or desktop computer), from which country and other data. This data can also not be linked to you directly.
Contact or complaint form
Our website offers the possibility to contact us or fill in a complaints form. Information we can collect and use are: your name, e-mail address, company that you work for, region and country, finance needed (amount), your question or complaint.
Events of FMO
From registrants the following data are stored: your name, address, residence details, phone number, e-mail address or other electronic communications, gender and / or age. Sometimes we need specific information to be able to organize the events, such as which seminars you would like to attend, dietary wishes and other information.
Clients, Prospects and Relations:
You may contact us for enquiries into investment opportunities, e.g. by submitting a business proposal through our contact form on the website. We may also be processing personal data of contact persons or other individuals related to clients, prospects or other relations of FMO, should they contact us. FMO records contact details, such as names, e-mail address and mobile phone number of any of these individuals. This may also include Know Your Customer data (passport). Please read here how your personal data is used in our KYC, KYS and investment process. .
2. Why we use your personal data and our legal grounds for processing
Subject to applicable law, your personal data may be stored and processed by us or one of our dedicated partners as explained in this paragraph. Schedule 1 includes a detailed overview of personal data processed, of the purposes and the legal ground for processing:
Clients, Prospects and Relations
- To be able to contact you and discuss and analyze investment possibilities
- To send relevant news updates and engage with you and/or the company you work for
- To prepare for entering into a contract with you or the company you work for. As part of our legal obligations we need to screen our suppliers, customers, its UBOs and other relevant representatives to prevent fraudulent conduct or behavior, tax fraud, anti-money laundering and anti-terrorism finance.
- To do audits, and, in case of conflicts, the settlement of the disputes
We process the personal data for the above purposes on the basis of the legal ground compliance with legal obligations that FMO is subject to (e.g. for the screening of our suppliers, customers and its UBO’s and other relevant individuals - the WWFT, to perform audits to verify compliance with our legal obligations and/or FMO policies), to enter into a contract with you or to perform the contract we have with you (e.g. to be able to respond to your requests as submitted, to build a relationship with you, to use personal information for the execution of the deal when we invest in your company) or because it is in our or your legitimate interests to do so without your right to e.g. privacy prevailing.
Website visitors
- We use your information to be able to answer your question or request when you contact us via the website.
- When you have submitted a business proposal, we use the contact details you have provided to contact you for further enquiries and to discuss your proposal.
- To provide you with a process for submitting complaints. If you do, then we process your personal data to find a solution for complaints and communication about the complaints process, and outcome of your complaint.
- When you raise a complaint as a whistleblower, we have a strict procedure and will not reveal your identity unless you have provided us with consent.
- To maintain our website (including solving performance issues and testing) and to make the website more user-friendly, to keep it relevant and improve the user experience. For analyzing the use of the FMO website, we are placing cookies on your computer, mobile phone or other device. Some cookies are only placed after you give us explicit consent. Please read our Cookie Statement for more information about the cookies we use.
- For your convenience, we have provided links to certain third-party websites, and/or videos. If you choose to visit a third party’s site, please be aware that the third party’s privacy policy, and not FMO’s, will govern your activities and any information you disclose while visiting their site. Please consult their privacy policies to know how they treat your privacy.
We process the personal data for the above purposes on the basis of the legal ground compliance with legal obligations that FMO is subject to, on the basis of your consent or because it is in our legitimate interests to do so without your right to e.g. privacy prevailing.
Participants of events
- When you contact us to register to participate in an event organized by us, we will use these contact details to send you information about the event (before and after) and to organize the event. Sometimes we organize the event with partners. In that case you will be informed in advance on the events information website.
- We may record these events to make these available for re-use and other participants, which may include use of your image/contribution to the events, as applicable. We will inform participants when an event is being recorded.
- We will also use your contact details to inform you of other events that you may be interested in, unless you have indicated that you do not wish to receive any such information. We may also ask you for your feedback on the event that you participated in.
We process the personal data for the above purposes to enter into a contract with you or to perform the contract upon your request to participate in an event. The recording of the event is in our legitimate interests as we would like to offer other participants also the opportunity to view the event. Your right to privacy does not prevail in this case. You can decide not to contribute actively or, if online, to not join with camera. Using your data to inform you of other events is also in our legitimate interests to build and/or maintain a relationship with the participants of our events. You right to privacy does not prevail; you can always let us know if you do not wish to receive any such information.
Visitors of our offices
- We will be processing personal data of you when you visit our offices. The personal data processed includes contact data (you will be asked for you name and contact details when entering), access times and camera recordings. The purpose of this is to facilitate your access to the FMO offices and for FMO to protect the office location and its staff working there.
It is in our legitimate interests to protect our offices and our staff, so for safety and security reasons, we need to register who is or was in the building.
All individuals
- We may also use the personal data categories of above listed individuals to comply with requests (including informal investigations) or demands of regulatory authorities, government authorities and other bodies having jurisdiction over us (e.g. the Dutch Central Bank).
We process the personal data for the above purposes on the basis of the legal ground compliance with legal obligations that FMO is subject to – where it concerns formal requests, subpoena’s or orders. Where it concerns informal investigations, we process the personal data because it is in our legitimate interests to do so for the protection of FMO and the financial sector, whereby we carefully balance our rights with your right to e.g. privacy and only where in the specific case your right to e.g. privacy will not prevail.
3. How FMO collects the information
We collect your personal information from a variety of sources, but in most situations, directly from you. You will usually provide this information through our contact form, information request or when you receive an investment from us.
We may also obtain some information from third parties, e.g., partners with whom we do a joint investment deal, Google searches (as part of our screening obligation) or other means.
In some circumstances, personal information may be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, CCTV).
Where we ask you to provide personal information to us on a mandatory basis, we will inform you of this at the time of collection. Should the information be required by the contract or statute, this will be indicated. The failure to provide mandatory information will mean that we cannot carry out certain services. For example, without requested Know Your Customer (KYC) screening information we cannot invest in your company or project.
4. How long FMO keeps your information
We will store your personal information for as long as is required or reasonably necessary for the purposes for which it was collected, as explained in this Privacy Statement. Schedule 1 to this Statement includes an overview of the applicable retention terms. If we no longer need the personal data for the purposes for which it was collected, we may still retain the data for archiving, for handling complaints or for use in legal proceedings or to comply with the requests of competent legal authorities, for historical or scientific research, or for statistical purposes.
5. With whom FMO shares your information
For the above purposes, personal information may be transferred within or outside of the jurisdiction, either within FMO or to third parties, including, but not limited to:
- certain third parties including suppliers and service providers. We have in place certain agreed additional safeguards to protect your information and have agreed data processing agreements with our suppliers.
- FMO may disclose personal information when required by law or court order, or as requested by any government, regulator, or law enforcement authority/agency.
- Sometimes we organize the event with partners. In that case you are informed about the possible sharing of information with these partners.
Where FMO transfers personal information internally within FMO or to any third party between different jurisdictions, including, but not limited to, transfers outside of the European Economic Area (EEA), and to other jurisdictions that have not been deemed to offer adequate protection, for the purposes outlined in this document, we will take appropriate steps to ensure that there is an adequate level of protection for personal information in place in accordance with applicable legal requirements. (For example, concluding additional contracts or (technical) measures in case of transfers outside the EEA.)
6. How we protect your personal data
Personal Data held by us will be kept confidential in accordance with data protection laws and applicable FMO policies and procedures.
We will take appropriate security measurements to ensure that personal data is kept secure and safe from any loss or unauthorized disclosure or use.
(Suspected) data breaches can be reported through DPO@fmo.nl)
7. What privacy rights you have
You have a number of legal rights in relation to the personal data that we hold about you.
These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you
- the right to withdraw your consent to our processing of your personal data at any time
- in some circumstances, the right to receive some personal data in a structured, commonly-used and machine-readable format and/or to request that we transmit those data to a third party, where this is technically feasible
- the right to request that we correct your personal data if it is inaccurate or incomplete
- the right to request that we erase your personal data in certain circumstances
- the right to request that we restrict our processing of your personal data in certain circumstances
- when we are processing on the grounds of legitimate interest, the right to object to the processing, meaning we must stop unless we have an overriding reason which will be communicated to you
- you also have the right not to be subject to decisions which are based solely on automated processing, unless e.g. sufficient suitable measures have been implemented to safeguard your rights, including the right to obtain human intervention as required.
How to exercise your rights
If you would like to exercise any of these rights, or if you have any concerns about how your personal data is handled by us, or wish to raise a complaint on how we have handled your personal data, you may contact us via email at: DPO@fmo.nl.
Privacy complaints
If you have a complaint, we’d like to hear about it so we can try to find a solution first. You always have the right to lodge a complaint with the applicable data protection authority. For the Netherlands, this is the Autoriteit Persoonsgegevens (T: +31 88 - 1805 250 or https://autoriteitpersoonsgegevens.nl/nl/meldingsformulier-klachten).
To protect your privacy, we will take steps to verify your identity before fulfilling your request; this can mean that we ask you to meet us in person in the office or ask you to identify yourself first.
8. How and when we update this privacy statement
FMO can change the privacy statement at any moment. We will make an announcement of these changes on our website. Older versions of our privacy statement will be stored in our archives. To view an older version of the privacy statement, please contact info@fmo.nl.
Questions about this privacy statement can be directed to our Data Protection Officer DPO@fmo.nl.
You can also reach us at the following address:
FMO - Netherlands Development Finance Company
Privacy Officer/ Compliance department
Anna van Saksenlaan 71
2593 HW The Hague
The Netherlands
Version February 2024
Schedule 1 Overview of our processing of personal data, purposes and legal grounds and applicable retention periods.
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Type of individual |
Type of personal data |
Activity / purpose of the processing of personal data |
Lawful basis for the processing of personal data |
Retention period |
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Website visitor
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Contact data – content of complaint or request and related communication – business proposals and any other content of documents shared by website visitor.
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When you have submitted a request or a complaint, we use your information to be able to answer your question or contact request and to find a solution for complaints and communication about the complaints process, and outcome of your complaint. Reviewing and assessing submitted business or other proposals.
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It is necessary in our legitimate interests and in those of the website visitor to communicate with us and to receive a response to requests/complaints. In view of the limited amount and sensitivity of the personal data, the right to privacy of the visitor does not prevail.
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Personal data part of a communication file, like contact forms you submit via our website, and your registration to events are kept for two years after the submission of your personal data. If you have submitted a complaint, the underlying data may be retained for longer, usually for 5 years after the objection, the complaint or the lawsuit has been settled or 7 years after the end of the transactions to which your data relates if you use the Independent Complaint Mechanism (ICM) procedure to submit your complaint.
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Information on how you use our website, technical and usage data |
To maintain our website (including solving performance issues and testing) and to make the website more user-friendly, to keep it relevant and improve the user experience.
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With your consent as required (cookies). It is necessary in our legitimate interests to be publicly visible and to maintain and improve our brand / business through our website.
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Read our Cookie Statement for specific retention terms per cookie. Information about your use of our website will be retained for 1 year. |
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Participant of events |
Contact details, details of event, recordings of events. |
To facilitate your participation of the relevant event and to organize the event (offline, online or in recorded version). We record the events in order to make these available for re-use and other participants. This may include use of your image/contribution to the event, as applicable.
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Performance of a contract or to take steps to enter into such agreement, upon your request to participate in an event. The recording of the event is in our legitimate interests to do so (for re-use), without the right of participants prevailing. Participants can decide to not contribute actively or to not join with camera. |
Personal data part of a communication file, like contact forms you submit via our website, and your registration to events are kept for two years after the submission of your personal data. Images and video recordings will be retained, where applicable with your permission, for five years after the recording has been made.
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To send you information about other events that may interest you, unless you have indicated that you do not wish to receive any such updates. To contact you for your feedback on the event that you participated in. |
We update you on other events because it is in our legitimate interest to maintain and build a relationship with the participants of our events, without your right to privacy prevailing as you can always let us know that you do not wish to receive this information or any requests for your feedback of the event.
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We will retain your contact details during the time that FMO sends you relevant news updates and for 24 months thereafter. |
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Visitor of our offices
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Contact data, access times and camera recordings.
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To facilitate your access to the FMO office and for FMO to protect the office location and its staff working there. |
Legitimate interests – to protect our offices and our staff, so for safety and security reasons, we need to register who accesses our offices.
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We keep CCTV camera recordings for only four weeks. Data related to visitor registration is kept for one year after your visit. |
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Clients, prospects and relations: these include contact persons of a (potential) client, supplier or business partner, authorized persons, UBO’s or other individuals related to clients, suppliers, prospects and relations.
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Contact data – content of submitted request, business proposals and any other content of documents shared by the individual. Additional information about the relevant individual such as their position in/ ownership in companies, financial information and passport copies. |
To be able to contact you and to discuss and analyze investment possibilities. To send relevant news updates and engage with you and/or the company you work for. To do audits, and, in case of conflicts, the settlement of the disputes
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We process the personal data because it is in our legitimate interests to do so to
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Personal data part of a communication file, like contact forms you submit via our website are kept for two years after the submission of your personal data. The information related to the relationship with clients, suppliers and relations shall generally be retained for ten years following the termination of the relevant agreement, the end of your business relationship with FMO or of that of the company you work for, or the end of the financial transaction the financial records relate to. If you, or the company you work for, are one of our prospects, and we have decided to not enter into an agreement, we will retain your details for five years after that decision. We may retain your contact details during the time that FMO sends you relevant news updates and for 24 months thereafter.
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To prepare for entering into a contract with the individual or the company they work for and to perform screenings.
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As part of our legal obligations we need to screen our suppliers, customers and its UBOs to prevent fraudulent conduct or behavior, tax fraud, anti-money laundering and anti-terrorism finance.
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We usually retain personal data that is obtained to comply with the customer or supplier due diligence requirements for five years following the end of your business relationship with FMO or of that of the company you work for. |
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All individuals |
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We may also use the personal data categories of above listed individuals to comply with requests (including informal investigations) or demands of regulatory authorities, government authorities and other bodies having jurisdiction over us (e.g. the Dutch Central Bank).
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We process the personal data for the above purposes on the basis of the legal ground compliance with legal obligations that FMO is subject to – where it concerns formal requests, subpoena’s or orders.
Where it concerns informal investigations, we process the personal data because it is in our legitimate interests to do so for the protection of FMO and the financial sector, whereby we carefully balance our rights with your right to e.g. privacy and only where in the specific case your right to e.g. privacy will not prevail. |
In the situation in which specific records fall under the scope of inquiries/ investigations by regulators or
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