1. General

1.1. This privacy declaration is issued by Alterfin CV, whose registered office is located at 1210 Brussels, Liefdadigheidsstraat 18-26, and which is registered with the Crossroads Bank for Enterprises under number 0453.804.602 ("Alterfin").

1.2. Alterfin is a cooperative that has been mobilising capital in Belgium for investment in developing countries since 1994. Alterfin aims to improve the livelihoods and living conditions of socially and economically disadvantaged people and communities, mainly in rural areas of low- and middle-income countries around the world. To do this, Alterfin provides financial and non-financial services to its partners by:

(i) mobilising funds mainly from individual investors and socially responsible institutions;

(ii) structuring and promoting ethical and sustainable investments;

(iii) collaborating in a targeted way with organisations that share the same values.

In this way, Alterfin contributes to the United Nations Sustainable Development Goals.

1.3. Through this privacy declaration, Alterfin informs all interested parties about the way in which it handles the personal data of its co-workers, visitors, service providers and partners (hereinafter referred to as "You"). Alterfin reserves the right to modify this privacy declaration at any time. Please consult it regularly.

Legal framework

2.1. Alterfin actsas the responsible controller of personal data which (i) relates to You and/or (ii) relates to other natural persons, but which has been provided by You or on your behalf ("Personal Data" or "Data").

As Data Controller, we respect your right to privacy and process Personal Data in accordance with applicable data protection laws and as described in this declaration, namely:

(i) Regulation (EU) 2016/679 of April 27th, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation);

(ii) any other applicable regulations on the protection of privacy and the processing of personal data; (together or individually, the "Data Protection Legislation").

If you have any questions about how we collect, store and use your Personal Data or if you have any other privacy-related questions, please email us at

3. Personal Data

We collect and process your Data only for the purposes described in this Declaration. Your Data may have been provided to us by You, or collected by Alterfin, in a number of ways.

When You browse our website (hereinafter the "Website"), become a shareholder or subscribe to our newsletter via the online form, we may collect, use and store the following Personal Data:

  • electronic identification data: only if You decide to provide identification information via the Website when You subscribe to our newsletter (sent quarterly), such as your name, first name and e-mailaddress. We process this Data in order to keep You informed and to share with You news about Alterfin, our activities, our partners and our actions. You can unsubscribe from this newsletter at any time;
  • visual content (photos and/or videos): during mass events that we organise, in particular during our general meetings of shareholders, workshops, seminars, events on the Website, we may take certain photos and/or videos of the event as well as of You. This visual content can be used by Alterfin for promotional purposes, during marketing campaigns;
  • identification data as a shareholder: when you become a shareholder of Alterfin, we collect the following personal data: your first name, surname, date of birth, gender, national registration number, home address, preferred language for contact, bank details and telephone number; and
  • cookies and similar technologies: this is data relating to your access to the Website, any personalised settings and your browsing behaviour. We collect this information by automated means when You browse the Website. You will be asked to consent to the use of cookies via a cookie banner. Cookies are necessary to optimise navigation and your browsing experience.

4. Legal basis for processing your Data

Alterfin collects and processes Your Data on the basis of one of the following legal grounds:

4.1. Preparation and execution of the contract concluded with Alterfin: when You wish to become a shareholder, we must process a certain amount of identification and banking data in order to carry out your registration in the shareholder register. We then process your Personal Data in order to keep You informed of decisions taken by Alterfin concerning certain investments, to inform You of the general meetings of shareholders, to raise the necessary funds and to proceed with the distribution of the dividend if it is applicable;

4.2. Your free, explicit, unambiguous and active consent: we seek Your consent to send electronic communications for marketing purposes. This consent may be given by any means, including, but not limited to, by post, e-mail, online or offline consent form or verbally. By consenting to receive these electronic communications, You will receive newsletters, information brochures, e-mail or other marketing content to inform You about:

  • our activities, those of our partners, possible partnerships and/or the activities of organisations active in the same sector;
  • our events and agenda.

4.3. Fulfilment of our legal obligations: Alterfin processes some of your Personal Data, such as your name, first name, national registration number in order to comply with the legislative framework applicable to it, in particular in the following areas:

  • the law of 18 September 2017 on the prevention of money laundering and terrorist financing and the restriction of the use of cash ("Anti-Money Laundering Law");
  • Article 145/33 of the Income Tax Act annexed to the Royal Decree of February 26th,1964 coordinating the legal provisions relating to income tax, published in the Belgian Official Gazette of April 10th, 1964 (tax benefits for gifts)

4.4. Our legitimate interest: where the processing of your Data is not strictly necessary for any of the above reasons, we may also process your Data for the realisation and fulfilment of our legitimate interests. In such cases, however, Alterfin will always strive to maintain a fair balance between the need to process your Data and the protection of your privacy. Whenever this is the case, Alterfin will keep You informed of the type of legitimate interest we are pursuing and provide You with transparent information about the processing operations and your rights. In particular, we may process your Personal Data for the following reasons:

  • photos and/or video in which You appear for promotional purposes, direct marketing, reporting to clients, publication on the Alterfin website, use in our annual reports, on social networks or for communication to third parties;
  • to evaluate the quality of our services and activities with our shareholders in order to continuously improve them and to answer your questions in this respect;
  • to understand your needs and to improve our products and services and the user experience of our platform;
  • to evaluate and improve our Website and its use in order to continually improve its content, measure performance and improve our communication with You;
  • conductstatistical studies on the use of our Website.

5. With whom do we share your Data?

We will not disclose, sell or lent your personal information to third parties unless You have previously consented. If You consent but later change Your mind, You may contact us and we will cease any such activity.

We may disclose Personal Data to the following categories of recipients (in any event, only where necessary for the performance of their functions):

  • To our staff (including employees and external consultants);
  • To our shareholders;
  • To a government agency, regulatory bodies and law enforcement officials or agencies where required for the purposes set out above, or where required for the lawful protection of our legitimate interests in accordance with applicable laws;
  • To our partners or third party funds, as part of required anti-money laundering and anti-terrorist financing checks, in accordance with applicable laws;
  • To subcontractors: we may use third party contracted companies and external service providers (referred to as "Subcontractors") to provide some of our services. In this case, Personal Data will be shared with these Subcontractors to enable them to continue to provide their services to us. Subcontractors are permitted to use the Data only for the purposes specified by us. In addition, they are contractually bound to process your Data only in accordance with this privacy policy and in compliance with applicable dataprotection laws. Specifically, we use the services of the following processors:
  • The host of our Website; and
  • Technology and IT service providers.

The Data is provided to Processors on the basis of Article 28 (1) GDPR or, alternatively, on the basis of our legitimate interests in the economic and technical benefits of using specialist Processors and on the basis of circumstances in which your rights and interests in the protection of your Personal Data are not prejudiced (see Article 6 (1) (f) GDPR).

6. International Transfers

When we transfer the Personal Data we collect about You to Subcontractors located in countries outside the European Economic Area and they do not offer an adequate level of protection, we ensure that appropriate data transfer tools are used.

7. Declarations and guarantees

7.1. You guarantee that You are entitled (on behalf of the person concerned) to transmit your Personal Data to Alterfin, for example your own, those of your employees, consultants, partners, etc. You also guarantee, in so far as necessary, that You have obtained the necessary consent for the aforementioned transfer of Personal Data and that You will hold Alterfin harmless for any claim in this regard.

7.2. You are aware that any breach of this clause will be considered as serious misconduct.

8. Rights

8.1. The Data Protection Legislation gives everyone a number of rights in relation to their Personal Data. You may exercise the following rights with respect to your Personal Data freely:

(i) the right to access and request a copy of your Data

(ii) the right to rectification of your obsolete or incorrect Data, the right to request that it be updated;

(iii) the right to request the erasure of your Data provided that the conditions of Article 17 ofthe GDPR are met;

(iv) the right torestrict the processing of Personal Data where the conditions of Article 18 ofthe GDPR are met;

(v) the right toportability of Personal Data to third parties to the extent that the conditions of Article 20 of the GDPR apply to You;

(vi) the right to object to the processing of Personal Data, to the extent that the requirements of Article 21 of the GDPR are met;

(vii) the right to revoke your consent;

(viii) the right to lodge a complaint with the Data Protection Authority ("Privacy Commission") either by post at Drukpersstraat 35, 1000 Brussels, or by e-mail at, or by telephone at +32 2 274 48 00.

8.2. You can exercise the aforementioned rights and ask your other questions by sending awritten, dated and signed request to Alterfin CV, Kunstlaan, 7-8, 1210 Brusselsor by e-mail to

9.     Duration

Alterfin processes Personal Data for as long as it is necessary for the purposes for which it is processed, as stipulated by the applicable regulations, and may do so for up to 10 years after the end of the contract that You conclude with Alterfin.

10.  Registration and security

10.1. The Personal Data is stored at Alterfin or, if applicable, at its IT service provider, whichis located in the EU.

10.2. Alterfin engages itself to take (to have taken) all reasonable measures to ensure the security of the Personal Data against loss, destruction, alteration or unauthorised access by means of security measures and an adequate security policy.

10.3. You acknowledge and accept the fact that sending and saving Personal Data is never without risk and, consequently, that the damage that You may suffer as a result of illegitimate use of the Personal Data by third parties is never attributable to Alterfin.

10.4. If Yoususpect that a data leak has occurred, You are invited to inform Alterfin immediately (and at the latest within 2 hours) by telephone on 02/5385862 andby e-mail at

11.  Dissociability

11.1. If any provision of this Privacy Statement is held to be unlawful or unenforceable, such provision shall be replaced to the extent necessary to make it lawful or enforceable, preserving as far as possible the original meaning of the provision.

11.2. Wherever possible, the provisions of this privacy declaration will be interpreted so as to be valid and enforceable under applicable law. If any provision(s) of this privacy declaration is (are) held to be invalid, illegal or unenforceable, in whole or in part, the remainder of the relevant provision(s) and this privacy declaration shall continue in effect as if such invalid, illegal or unenforceable provision(s) had never been included.

12.  Applicable law

12.1. You agree that the entire relationship between You and Alterfin with respect to Personal Data and privacy considerations is governed exclusively by Belgian law.

12.2. Any dispute relating to the Personal Data shall fall under the exclusive jurisdiction of the courts of Brussels, to the exclusion of any other court.


Last update: March 2024