Privacy Policy

Snijder & Associates B.V.

Last updated: 7 January 2026

1. Introduction

Snijder & Associates B.V. (“S&A”, “we”, “us”, or “our”) is committed to protecting the privacy and personal data of its clients, business partners, website visitors, and other stakeholders. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Dutch privacy laws.

This Privacy Policy applies to all personal data processed by S&A in the course of providing management services and investment-related activities, as well as through our website www.snijderbv.com.

2. Data Controller

The data controller responsible for the processing of personal data is:

Snijder & Associates B.V.
Balistraat 84
2585XW Den Haag, The Netherlands
Chamber of Commerce (KvK): 69959080
Email: info@snijderbv.com

3. Personal Data We Process

We may process the following categories of personal data:

3.1 Clients and Business Contacts

Identification data (name, title, date of birth)
Contact details (email address, telephone number, postal address)
Professional information (company name, position, business activities)
Financial and transactional data
Investment-related information
Compliance data (e.g. KYC, AML, UBO information)
Correspondence and communications

3.2 Website Visitors

IP address
Browser type and version
Device information
Website usage data (pages visited, time spent)
Cookies and similar technologies

4. Purposes and Legal Bases for Processing

Olmar processes personal data only where permitted under GDPR. Processing is carried out for the following purposes and legal bases:

Purpose Legal Basis

Provision of management and investment services Performance of a contract

Client onboarding, KYC, AML, and compliance obligations. Legal obligation

Communication with clients and partners Legitimate interest

Financial administration and reporting Legal obligation

Website operation, security, and improvement Legitimate interest

Marketing and relationship management (where applicable) Consent or legitimate interest

5. Disclosure of Personal Data

Personal data may be shared with third parties only where necessary, including:

Professional advisors (legal, tax, audit)
Financial institutions and custodians
IT service providers and hosting providers
Regulatory authorities or supervisory bodies
Other third parties where required by law

All third parties are required to maintain appropriate confidentiality and data protection safeguards.

6. International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), Olmar ensures that appropriate safeguards are in place, such as EU Standard Contractual Clauses or transfers to countries recognized by the European Commission as providing an adequate level of data protection.

7. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including statutory retention periods, regulatory requirements, and legitimate business needs.

8. Data Subject Rights

Under the GDPR, data subjects have the following rights:

Right of access
Right to rectification
Right to erasure (right to be forgotten)
Right to restriction of processing
Right to data portability
Right to object to processing
Right to withdraw consent at any time (where applicable)
Right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens)

Requests can be submitted via: info@snijderbv.com

9. Security Measures

S&A implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or destruction. These measures include access controls, encryption, secure IT infrastructure, and staff confidentiality obligations.

10. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to ensure proper functioning and to improve user experience.

11. Changes to This Privacy Policy

S&A reserves the right to amend this Privacy Policy at any time. Updates will be published on www.snijderbv.com and will become effective upon publication.

12. Contact

For questions regarding this Privacy Policy or the processing of personal data, please contact: