Legal statements

Disclaimer

This website contains general information regarding Dasym Holding B.V. and its worldwide affiliates and subsidiaries (collectively, hereinafter: “Dasym”). This information is a general description of Dasym only. Before acting on any information, you should consider the appropriateness of it having regard to your particular objectives, financial situation and needs and seek advice. No information set out on this website constitutes advice, an advertisement, an invitation, a confirmation, an offer or a solicitation, to buy or sell any security or other financial product or to engage in any investment activity, or an offer of any financial service. Some products and/or services mentioned on this website may not be suitable for you and may not be available in all jurisdictions. All securities and financial products or instrument transactions involve risks. Past performance of any product described on this site is not a reliable indication of future performance.

Dasym took the greatest possible care when compiling this website. However, it is possible that the information published is incomplete, incorrect or in breach of the law. In this context, Dasym will accept no liability whatsoever. Dasym has only made the information on the website available for informative purposes and under the explicit condition that you accept that Dasym cannot be held liable for the content of the information or any decisions made on the basis of the information published.

All the information on this website is the property of Dasym. The content may only be used for non-commercial/private purposes. Without the prior permission of Dasym, no part of the content of this website may be reproduced or made available to third parties.

Privacy Statement

With this Privacy Statement, Dasym Managed Accounts BV wants to inform any involved party and any visitor of Dasym.com, which personal data are being processed and why.

This Privacy Statement will be updated from time to time to reflect any changing regulatory requirements, processing practices or new functionalities that we might add. Any such changes to the Privacy Statement will be posted on the relevant website and will be effective upon posting. See the Cookie Policy for more information about the usage of cookies.

1. Introduction

The privacy statement applies to the processing of personal data of:

clients;
business partners;
visitors;
recruitment candidates;
third parties (not falling under the above categories).

The Privacy Statement applies to the following entity:

Dasym Managed Accounts BV: a company incorporated in the Netherlands, registered with the Chamber of Commerce under number 32147379 whose registered office is located at 1411 KC Naarden, Flevolaan 41A (hereinafter DMA);

DMA will process your personal data in a lawful and fair manner and in accordance with the EU General Data Protection Regulation (GDPR). This Privacy Statement explains how we process and protect your personal data and provides you with more information on your rights as a data subject.

2. The personal data we collect and process

The personal data that we collect and process from you may include the following information (any such data hereinafter referred to as “personal data”):

Identity data including name, surname, date of birth, passport number, etc.
Contact data including billing address, email address, phone number.
Usage data such as information that we derive from your visits to our websites, applications, systems and online platforms, such as your IP address, the pages you visit, the browser you are using, the website you have previously visited and the time and duration of your visit.
Marketing data such as information that you provided to us or that we collected as part of your registration for marketing materials such as newsletters and alerts, attending meetings and events.
HR data including information that you provided to us when applying for a job at DMA in order to assess your profile and skills.

Furthermore we might process personal information based on legitimate requests of relevant authorities according to the applicable law in the Netherlands.

Special categories of personal data, as well as personal data related to criminal convictions and offences, are only processed by DMA when permitted under an exception defined by the GDPR.

3. How we collect your personal data

Your personal data may be collected directly from you when you provide it to us, either through a website, social media page, or other means.

4. How do we process your personal data?

Any organization that processes personal data may only do so if there is a legal basis. DMA might process your personal data in the following circumstances:

Processing is necessary for the performance of a task carried out in the public interest.
Processing of your personal data is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract.
Processing of your personal data is necessary to comply with a legal obligation.
Processing of your personal data is necessary for its legitimate interest: when necessary for the interest of DMA or a third party and your fundamental rights are not overridden by such interests. These legitimate interests include organizing our internal operations, handling our matters, ensuring proper administration, ensuring appropriate security, and similar purposes.
Where you have provided your consent to the processing of the personal data.

5. For which purposes do we process your personal data?

Your personal data will be processed for the following purposes:

To communicate effectively with you and conduct our business: to conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you or your company and us.
To communicate with you regarding products and services that may be of interest: amongst others to provide your company and you with updates and offers, where you have chosen to receive these. Where required by law, we will ask for your consent at the time we collect your data to conduct marketing activities. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by visiting Contact.
To handle our HR activities, inform you about job vacancies and opportunities at DMA, handle your job application and assess your eligibility to work for us.
To understand our customers / business partners and to develop our products and services: we or third service providers (e,g, Google Analytics) on our behalf may analyze the personal data we hold in order to better understand our business. In order to ensure that content from our website is presented in the most effective manner for you and for your device, we may pass your data to business partners, suppliers and/ or service providers.
Website tracking: we collect anonymized information about how our website is used. This information is used to optimize the website and to ensure an optimal user experience.
To reorganize or make changes to our business: in the event that we (i) are subject to negotiations for the sale of our business or part thereof to a third party, (ii) are sold to a third party or (iii) undergo a reorganization, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or reorganization, certainly limited to what is required for this purpose and only to the extent allowed under applicable laws. We may also need to transfer your personal data to that reorganized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this policy.

DMA will retain your data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law, such as the Dutch Archives Act (Archiefwet). For personal data processed during a job application, DMA will include the personal data of hired candidates in the personnel file. If DMA does not hire you, it will retain your personal data, including your application details, for up to 4 weeks after the completion of the recruitment process, unless you have given consent to retain your data for a longer period (up to a maximum of 1 year).

6. Exchange of your personal data

Any personal data we collect from you, may also be transferred to third parties both based inside and outside the European Union, in order to execute a processing agreement, based upon your consent or because required by applicable law and regulations. This only occurs when the provision of personal data is compatible with the purpose for which the data was originally collected.

DMA ensures that personal data is only transferred to third countries (countries outside the EU/EER) where an adequate level of data protection is guaranteed. In cases where a third country cannot provide such protection, personal data will only be transferred if the European Commission has issued an adequacy decision, or if DMA applies the Standard Contractual Clauses approved by the European Commission to safeguard the data.

Automated individual decision-making, including profiling

DMA does not engage in automated individual decision-making, including profiling.

Security

DMA secures your personal data through various technical and organizational measures, such as firewalls, secured servers, and data processing agreements with third parties.

7. Social media and other websites

If you share content from DMA’s website, applications, systems and online platforms via social media, your personal data will be visible to the visitors of your personal pages on these social media websites. We are not responsible or liable for any processing of your personal data via such media platforms.

DMA’s website, applications, systems and online platforms may provide references – including hyperlinks – to websites, channels, social media or other external content from other companies/persons. DMA is not responsible or liable for any processing of your personal data via these websites, channels or media. This Privacy Statement does not apply to the use of such websites, channels or media.

8. Your rights

Subject to the terms and conditions provided for by the applicable law, you may contact DMA to exercise the following rights:

You have a right to be informed about how we process your personal data.
You have a right to access your personal data
You have a right to receive confirmation as to whether or not your personal data is processed, and where that is the case, you can access your personal data.
You always have the right to have your personal data corrected. This allows you to rectify or correct, inaccurate or incorrect personal data DMA processes.
You have the right to have your personal data erased. This allows you to permanently delete personal data which DMA processes. DMA is not always obliged to delete your personal data at your request – this right only applies in the situations and to the extent provided for by law.
You have the right to restrict the processing of personal data related to you. This allows you to freeze the use of your personal data by DMA, without deleting it. DMA is not always obliged to limit your personal data at your request – this right only applies in the situations and to the extent provided for by law.
You always have the right to withdraw your consent whenever the processing of your personal data takes place on the basis of your consent.
You have the right to object at any time to the processing of your personal data. DMA shall no longer process your personal data unless DMA demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of your, exercise or defense of legal claims.
You always have the right to object to the processing of your personal data for direct marketing purposes. You can withdraw your consent or change your preferences regarding newsletters, alerts and invites at any time by clicking the “unsubscribe” or “change profile” button at the bottom of our newsletters, invitations or through one of our websites or our online platforms.
You have the right to data portability. This allows you to easily move, copy or transfer your personal data from one controller to another. This right may only be exercised whenever the processing takes place on the basis of an agreement with you.

Should you have any questions or complaints about this Privacy Statement or if you wish to exercise any of your rights in respect of your personal data processed, please send your request to:

info@dasym.com
Alternatively, you may send it by post to the address provided by DMA.

If you believe that your rights as a data subject have been infringed, please be aware that you have the right to lodge a complaint with the relevant supervisory authority. This will be the Autoriteit Persoonsgegevens (for the Netherlands).

Cookie Policy

With this Cookie Policy, DMA wants to inform any visitors which cookies are being used and why. This Cookie Policy will be updated from time to time to reflect any changing regulatory requirements, processing practices or new functionalities that we might add. Any such changes to the Cookie Policy will be posted on the website and will be effective upon posting. See our Privacy Statement for more information about our policies regarding the processing of personal data.

1. What are cookies?

Cookies are small text files that are placed on your computer or mobile device when visiting one of our websites and which will store certain user information. Cookies are composed of unique codes that will help to recognize you when visiting our website again and may enhance your user experience. There are different types of cookies, distinguished according to functionality, source and/or storage period.

2. Regarding their functionality

Necessary or essential cookies: are cookies that are necessary for the optimal operation of the website and enable you to use the features of our website.

Functional cookies: ensure that the website functions properly. Examples of these are cookies that remember your login details, that ensure the security of your login details, that ensure the uniformity of the layout of the website.

Analytical cookies: are used for analytical purposes, i.e. to measure visits to the website. These cookies show how the website is used. For example, we know how many times a particular page is read, how much time someone spends on our website, etc. Statistical analyses are made from the information we receive and these analyses enable us to improve the structure, navigation and content of our website, to enhance the functionality and user experience of our website and associated services. We also use this data to enhance our service offering (by tailoring and adapting the content of our website with topics that are relevant to our visitors).

3. Regarding their source

First-party cookies: are created and managed by DMA.

Third-party cookies: are created and managed by third parties and materialize when visiting the website. The cookies will send information regarding your visit to third parties.

Social media cookies: are third party cookies that allow you to directly share content from the website on social media, such as X, Facebook, LinkedIn, YouTube or Spotify by using the respective buttons. Through these buttons, the social media may collect information about you and track your activities across websites to build a user profile, even if you make no use of these buttons. Because the privacy and cookie statements of social media, such as X, Facebook, LinkedIn, YouTube or Spotify are often subject to change, we advise to regularly consult the privacy and cookie policies of the social media in question.

4. Regarding their storage period

Session cookies: the information is only temporarily stored in your browser or application and session cookies expire as soon as you close your browser or application.

Permanent cookies: remain on your computer or mobile device, even if you close the browser or the application. Permanent cookies store information between different visits to the website and make it possible to recognize you during subsequent visits to our website. This data allows the website to recognize you as a returning visitor and to respond accordingly, for example by saving your language preferences. Permanent cookies remain on your device until their end date is reached, until a new cookie is installed, or until you delete them in your settings of your browser or application (their lifespan is determined by the website).

5. Which cookies do we use?

DMA uses essential cookies. Given the fact that these cookies are essential for the technical functioning of our website, these cookies are placed as soon as you access our website. You cannot disable these cookies if you want to read our website.

DMA uses functional cookies. These cookies are installed if you consent by clicking on our website's cookie notice.

DMA uses analytical cookies for analytical purposes and to enhance the functionality and user-experience of our website. The permission of every visitor is required for the placement of these cookies which implies that you can refuse to place these cookies.

6. Managing cookies

You can enable or disable functional or analytical cookies at any time by amending the cookie settings of your browser. How to do this can be found in the help-function of your browser. In your browser you can view and delete the current cookies on your computer or mobile device and choose not to accept them in the future.

Google Chrome: browser > Chrome-menu > settings > Privacy and security > Content settings > cookies

Internet Explorer: browser > Tools > Internet options > Privacy:

Set the protection level with the slider
Click on ‘Advanced’ and set the protection level manually

Microsoft Edge: browser > menu > settings > site permissions > cookies and site data

Firefox: Menu > Options > Privacy & Security > Cookies and Site Data

Safari: Preferences > Privacy > Remove all website data or Details

Questions or complaints?

Should you have any questions or complaints about this Cookie Policy, please send your request to:

info@dasym.com
Alternatively, you may send it by post to the address provided by DMA.

Regulatory Disclosures

The name “Dasym” refers to Dasym Holding B.V. and its worldwide affiliates and subsidiaries. Dasym only carries on regulated activities in those countries it is authorized to do so. Dasym Managed Accounts B.V. is authorized by the Netherlands Authority for the Financial Markets and the Dutch Central Bank to carry out investment services in the Netherlands and a number of other EU jurisdictions, subject to regulation in the Netherlands and the regions in which it operates. Dasym Public Markets is a trade name of Dasym Managed Accounts B.V. Dasym Investment Strategies B.V. is registered as an exempt manager of alternative investment funds with the Netherlands Authority for the Financial Markets and the Dutch Central Bank. Dasym SICAV is an undertaking for collective investments in transferable securities (UCITS) with multiple sub-funds incorporated under Luxembourg law and authorized by the Luxembourg Commission de Surveillance du Secteur Financier pursuant to Article 129 of the law 17 December 2010 relating to undertakings for collective investment. The distribution of Dasym SICAV outside Luxembourg is subject to local legislation of the country of distribution. Dasym SICAV is distributed by Dasym Managed Accounts B.V. If you are considering a transaction in Dasym SICAV, then carefully consider the funds’ investment objectives, risk factors, charges and expenses before investing. This and other information can be found in the funds’ prospectus and the key investor information document, which may be obtained free of charge at the registered office of Dasym SICAV. Investors should read the prospectus and the key investor information document carefully before investing.

Sustainable Finance Disclosure Statement

The EU Sustainable Finance Disclosure Regulation (SFDR) aims to make the sustainability impact of financial market participants and products more comparable and better understandable for involved parties. Therefore, Dasym is obliged to have a Sustainable Finance Disclosure on its website. The SFDR is one of the many initiatives, which fall under the European Green Deal and EU Sustainable Finance Action Plan.

Dasym is a regulated boutique investment firm, offering tailor-made investment services. This focus on a tailored approach allows Dasym to service clients’ wishes in sustainability investments, preferences on ESG or Sustainable Development Goals or any feasible mix in asset portfolio. Dasym does not explicitly position itself as a sustainable asset manager, nor has Dasym included the consideration of adverse sustainability impacts in its investment policy.

Most of our current clients have a similar approach towards sustainability. As our clients have a long-term goal on capital preservation, their first priority is performance within the given risk appetite. Therefore Dasym implements ESG integration in the following way in its investment decision-making process: Dasym incorporates, if possible due to the type of investments, material environmental, social, and governance data and insights into investment making decisions, alongside traditional financial information, with the objective of improving the long-term financial outcomes of funds, portfolios and mandates.

Dasym may recommend sustainable investment products when these do not have outsized impact on risk adjusted returns. When potential clients have a full sustainability investment philosophy, Dasym welcomes them to engage with us, as Dasym can tailor their needs and ambitions with our independent, tailor-made asset management approach.

For our investment professionals who are involved with investments that promote environmental and social characteristics, specific targets aimed at responsible investing are incorporated.

Shareholder Engagement Policy

This Engagement Policy has been adopted by Dasym Managed Accounts B.V. to demonstrate compliance with the relevant regulatory requirements as prescribed under the Shareholder Rights Directive II, and relevant local transpositions across the European Union. The Shareholder Rights Directive II aims to promote shareholder engagement and improve stewardship practices across the European Union.

Please contact us if you would like to learn more about our Shareholder Engagement Policy.

Remuneration Policy

Dasym Managed Accounts B.V. (‘Dasym’) has a remuneration policy which abides by the national and international rules and regulations regarding sound remuneration principles. In implementing this policy Dasym has applied the proportionality principles which are commensurate with the size, complexity and nature of the organization[1].

This remuneration policy applies to persons who are employed by or otherwise in a relationship of authority to Dasym or related entities, including members of the Board of Directors and managers.

The remuneration policy is designed in such a way that:

It ties in with the Dasym’s culture and strategy, objectives, values and long-term interests of the company and its stakeholders.
It is ethical, sound and sustainable, in line with the Dasym’s risk appetite, risk management strategy and risk profile, contributes to robust and effective risk management, and does not encourage the taking of more risks than is acceptable to the business.
It takes account of the interests of clients and is designed to ensure that clients are treated in such a manner that their interests are not harmed in the short, medium and long term.
Performance by employees and by the Dasym itself are measured based on both financial and non-financial indicators.
Remuneration practices do not contain any incentives that might prompt individuals to put their own interests before that of Dasym or its clients.
It does not pose a threat to the solid capital base of Dasym.

The remuneration policy provides for measures for adjusting and reclaiming already awarded variable remuneration (malus and claw-back measures).

The governance of the remuneration policy provides for the following:

Approval of remuneration policy, yearly remuneration, and the identification of identified staff is the responsibility of the management of Dasym.
Oversight and review of the remuneration policy by the Compliance Officer who is independent of the business line.
A yearly risk analysis of the remuneration policy by Compliance which is subsequently reported to management.
Assistance by Human Resources in the identification of identified staff and annual reporting to Compliance concerning the working and effectiveness of the remuneration policy.

Given its size and non-complex structure, Dasym does not have a remuneration committee.

Key remuneration figures for 2023:

The number of employees with a total annual remuneration (fixed and variable) of €1 million or more for 2023 was 0.
The number of employees that received a variable compensation regarding their performance in 2023 was 34.

[1] Article 1:117, sub 2 Dutch Act on Financial Supervision (Wft).

Complaints Procedure

If you wish to file a complaint about Dasym Managed Accounts B.V., we recommend reviewing our Complaints Procedure. It outlines the submission process and explains how we handle complaints. For any questions, please feel free to contact us.