Privacy Policy
Last Updated: September 12, 2025
This Privacy Policy describes how we collect, use, disclose and protect personal data when you visit or use the website www.3s-capital.com (“the Website”) or otherwise interact with us in connection with our investment funds, services or business relationship. By using the Website or providing us with your personal data, you agree to the terms of this Privacy Policy.
Who We Are
3S Capital Partners B.V. (“3SCP”, “we”, “us”, “our”) is a company governed by the laws of the Netherlands. We are registered with the Dutch Authority for the Financial Markets (AFM) as an Alternative Investment Fund Manager under the “light regime.” We manage three alternative investment funds: FGR 3S UK P2P High-Income Fund, FGR 3S Global Trade Finance Fund, and 3S CT Fund I C.V., a Netherlands-domiciled limited partnership providing professional investors with passively managed exposure to a diversified basket of cryptoassets, including stablecoins.
3SCP is a wholly owned subsidiary of New Digital Holdings Limited (UK), which is majority-owned and controlled by 3S Money Club Limited, an FCA-authorised electronic money institution under the Electronic Money Regulations 2011.
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Personal Data We Collect
We collect personal data about you when you visit our website, contact us, invest in our funds, apply for employment, or otherwise engage with us. Personal data may include your name, address, email address, telephone number, date of birth, identification numbers, bank account or financial details, proof of identity, proof of address, transaction history, investor status, tax information, investment preferences, or other information required for Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF) checks, or regulatory compliance. We may also collect technical and usage data, including IP address, browser type, operating system, device identifiers, pages visited, time and date of access, and cookies or similar technologies.
How We Use Your Personal Data
We use your personal data to inform you about our services, manage investor relations, carry out KYC/AML/CTF and other regulatory duties, process investments, redemption requests, and payments, communicate with you (including handling queries and complaints), for marketing (where you have given consent or as permitted by law), maintain and improve our Website (including for statistical and analytical purposes), manage risks, prevent fraud, and comply with legal, regulatory, or contractual requirements.
Legal Basis for Processing
Our lawful basis for processing your personal data includes the performance of a contract (for example, when you invest or use our services), compliance with legal obligations (such as AML/CTF, tax, financial regulation under Dutch and UK law, including regulations overseen by the AFM and the FCA), legitimate interests (such as ensuring security, preventing fraud, and managing investor relationships), and your consent where necessary (for example, for marketing or optional services).
Disclosure of Personal Data
We may disclose your data to service providers and contractors who assist us in hosting, operating, maintaining, or improving the Website, conducting KYC/AML checks, managing investments, processing payments, handling investor relations, or providing support services. We may share data with regulatory authorities including the AFM, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), the Financial Conduct Authority, tax authorities, auditors, legal advisors, and other governmental or law enforcement bodies where required by law or regulation. We may share personal data with third parties in connection with business transfers or corporate restructuring, provided that the recipients agree to handle your data in accordance with this Privacy Policy or equivalent standards.
International Transfers
Your personal data may be transferred outside the European Economic Area (EEA) where necessary. When this occurs, we ensure that appropriate safeguards are in place in accordance with applicable law, such as using standard contractual clauses, binding corporate rules, or confirming that the destination country offers adequate protection as recognised under EU law.
Retention of Data
We will keep your personal data only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, tax or accounting obligations. Once those purposes have been fulfilled, or when retention is no longer needed, your personal data will be securely deleted, anonymised, or otherwise made irreversibly non-identifiable.
Security
We implement appropriate administrative, technical, and organisational measures to protect your personal data from unauthorised access, use, disclosure, alteration, or destruction, in line with the sensitivity of the data and the risks involved in data processing. Our security measures are designed to comply with applicable legal and regulatory standards, including those under the GDPR and relevant financial regulations in the Netherlands and the UK.
Cookies and Similar Technologies
We use cookies and similar tracking technologies to collect and store information when you visit the Website. Cookies help us operate our Website, analyse trends, track users' movements around the site, and gather demographic information about our user base as a whole. You may refuse or disable cookies via your browser settings, but that may limit some parts of the Website or services. More details are provided in our Cookie Policy (where applicable).
Your Rights
Depending on the jurisdiction where you are located, you have certain rights regarding your personal data under applicable data protection laws. These rights may include the right to access your personal data, to correct inaccurate or incomplete data, to erase your personal data (“right to be forgotten”), to restrict or object to certain processing, to data portability (where data is processed based on consent or contract and in digital format), to withdraw consent (where processing is consent-based), and to lodge a complaint with a supervisory authority. If you wish to exercise any of these rights, you may contact us using the details provided below.
Third-Party Links
The Website may include links to other websites not operated by us. We are not responsible for the privacy practices or content of these external sites. We recommend that you review the privacy policies of any third-party sites you visit.
Children
The website is not aimed at persons under 18. We do not intentionally collect personal data from children under 18. If we find that we have collected data from a child under 18 in a way that conflicts with this Privacy Policy, we will take steps to delete such data.
Changes to this Privacy Policy
We may update this Privacy Policy occasionally to reflect changes in our practices, legal requirements, or applicable laws. When significant changes occur, we will notify you by posting the revised version on the Website with an updated “Last updated” date. You should review this Privacy Policy regularly.
Contact Information
If you have any questions about this Privacy Policy or wish to exercise your rights, you may contact us at:
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Dmitri Peil
3S Capital Partners B.V.
Keizersgracht 555, 1017 DR Amsterdam, The Netherlands
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If you believe that our processing of your personal data breaches any applicable law, you have the right to lodge a complaint with the relevant supervisory authority. This may include the Dutch Data Protection Authority (“Autoriteit Persoonsgegevens”) and/or other authorities relevant to your jurisdiction.