Privacy

Who is responsible

Rare Context is run by Wilmake B.V., a private limited company being incorporated in the Netherlands. Wilmake B.V. is the controller of your personal data under the General Data Protection Regulation (GDPR).

Wilmake B.V. i.o. (in formation), Brouwersgracht 238, Amsterdam, the Netherlands.

Questions about privacy go to Jan Wilmake at hello@rarecontext.com.

What we collect

When you send the request form

We store what you send and a few details about where it came from:

• who you are: the role you pick, such as allocator or owner;
• your name and email address;
• your organization, if you give it;
• the asset class you pick;
• your message;
• the page you sent it from and its kind, such as an asset page or a ranking, and the asset or owner you asked about, if any;
• the country your connection comes from. Cloudflare works this out from your IP address. We store the country, not the IP address;
• the date and time.

If we write to each other afterwards, we keep that conversation too.

When you only browse

We do not log who visits. There are no accounts, no analytics and no advertising.

Our host, Cloudflare, handles your IP address to deliver pages and to block attacks. We do not receive or keep it. Request logging for our site (Cloudflare Workers Logs and Logpush) is switched off, and our pages carry no Cloudflare Web Analytics script. Cloudflare shows us only totals, such as the number of requests per day.

Cloudflare asks your browser to report connections to our site that fail (Network Error Logging). Successful visits are never reported. The reports go to Cloudflare, which uses them to run its network.

Our fonts are served from our own site. Your browser connects to no one else when you read our pages.

Why we use it, and on what legal basis

• To answer you. We read your request, reply and follow up. The legal basis is taking steps you ask for before a possible agreement (Article 6(1)(b) GDPR), and our legitimate interest in answering business enquiries (Article 6(1)(f)).
• To look for a match. We compare what you look for or own with our data and with other requests. A person decides whether a match makes sense. We make no automated decisions about you with legal or similar effect. The legal basis is our legitimate interest in making useful introductions (Article 6(1)(f)).
• To introduce you. We share your name, organization and what you told us with another party only after you agree. The legal basis is your consent (Article 6(1)(a)). You can withdraw it at any time.
• To keep the form safe. The country and a hidden field help us spot spam. The legal basis is our legitimate interest in a working form (Article 6(1)(f)).
• To meet legal duties. If a request leads to an agreement, tax law requires us to keep some records (Article 6(1)(c)).

We do not use your data for marketing to others. We do not sell it.

Who else handles it

These companies process your data for us. They may use it only on our instructions.

• Cloudflare, Inc. (United States) hosts the site, runs the form and stores requests in Cloudflare Workers KV. Cloudflare may keep copies in data centres around the world. Cloudflare Email Routing also receives email sent to hello@rarecontext.com and forwards it to our mailbox, without storing it.
• Attio (United Kingdom) runs our customer relationship system, where we track requests and introductions.
• Anthropic (United States) provides Claude, the AI assistant we use to draft replies and suggest matches from your request. A person reads every draft and sends every message.
• Fastmail Pty Ltd (Australia) hosts our mailbox and stores the emails we exchange with you. Fastmail keeps its main servers in the United States and may also process data in other countries, such as Australia, India and the Netherlands.

We share your data with no one else, unless the law requires it.

Data outside Europe

Cloudflare and Anthropic are based in the United States. Attio is based in the United Kingdom. Fastmail is based in Australia and stores email in the United States.

The United Kingdom has an adequacy decision from the European Commission. For the United States we rely on the EU–US Data Privacy Framework where the company is certified under it, and otherwise on the European Commission's Standard Contractual Clauses. Australia has no adequacy decision. For Fastmail we rely on the Standard Contractual Clauses in its data protection agreement.

How long we keep it

• The copy of your request in Cloudflare: 24 months after you sent it. A scheduled job checks every day and deletes older requests automatically.
• A request that leads nowhere, in our CRM and mailbox: 24 months after our last contact. Then we delete it.
• An ongoing relationship: as long as it lasts, then 24 months.
• Records tax law requires, such as agreements and invoices: seven years.

If you ask us to delete your data sooner, we do, unless the law makes us keep it.

Cookies

We set no cookies, and Cloudflare adds none to our pages or our form. We use no tracking pixels, analytics or advertising tools. That is why there is no cookie banner.

If Cloudflare suspects an attack, it may ask your browser to pass a security check. It then sets a cookie that remembers you passed it. That cookie is strictly necessary for security and is not used to track you.

If you appear in our data

We publish data about assets and the organizations behind them, taken from public registers and open datasets. We aim to leave private individuals out: our collectors skip holders whose names read as a person. Some registers still name people, for example as a sole trader or a contact.

If you find your name on Rare Context, write to us and we remove it. You can also object to our use of it at any time.

We also keep business contact details of people at investors and asset owners, taken from public sources such as company websites and registers. We do this out of legitimate interest, to contact them about relevant introductions. When we first write to you, we say where we found your details. If you object, we stop.

Your rights

Under the GDPR you can ask us to:

• show you the personal data we hold about you;
• correct it;
• delete it;
• limit how we use it;
• send it to you, or to someone else, in a common format.

You can also object to uses based on our legitimate interest, and withdraw consent you gave.

Email hello@rarecontext.com. It costs nothing. We may ask you to confirm who you are. We answer within one month. If a request is complex, we may take two more months, and we tell you why.

You can complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens, or to the authority where you live. We would like the chance to solve it first.

Changes

When we change this notice, we update the date at the top. If a change matters for how we use data you already sent, we tell you by email.

See also our terms of use and data licence.