Privacy policy
counterpass.io · last updated November 2026
1. Who we are
Counterpass is a product of noLLM B.V., Amsterdam ("we"). We provide counterparty-onboarding software and services to funds and fund administrators, from the Netherlands. For questions about this policy or your data, write to hello@counterpass.io.
2. This website
This website sets no tracking cookies and runs no third-party analytics. If you submit a form, we process the details you enter (name, organisation, email, message) to respond to your request, on the basis of our legitimate interest in handling enquiries. We keep enquiry data no longer than needed to handle and follow up your request.
3. The product
Within the product, Counterpass processes personal data (such as identification documents of directors, signatories, UBOs and investors) on behalf of the client fund, which remains the controller. Processing is governed by a data processing agreement with each client. Product data is hosted in data centres in the European Union.
4. Dutch citizen service numbers
BSN data is processed only where a statutory basis exists, is masked on arrival everywhere else, and is never included in outbound documents, shares or search results.
5. Retention
Product data is retained in line with the client's obligations under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) and the agreement with the client, and deleted or returned at the end of the engagement.
6. Your rights
Under the GDPR you may request access, rectification, erasure, restriction or portability of your personal data, and you may object to processing. For data we hold as controller, contact us directly. For data processed in the product, we refer requests to the client fund as controller and assist it in responding. You can lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
7. Sub-processors and transfers
We use EU-based infrastructure providers under written agreements. We do not transfer product data outside the European Economic Area.
Terms of service
counterpass.io · last updated November 2026
Article 1 · Definitions
"Counterpass", "we": noLLM B.V., Amsterdam, the provider of the Counterpass software and services. "Client": the fund, manager or administrator entering into an agreement with us. "Services": the vault, form-filling, review, collection and related services described in the agreement.
Article 2 · Applicability
These terms apply to all offers, agreements and use of the Services, to the exclusion of the Client's general conditions, unless agreed otherwise in writing.
Article 3 · The Services
Counterpass prepares, organises and tracks responses to counterparty onboarding requests on the Client's instructions. The Services are an obligation of effort, not of result, unless expressly agreed otherwise.
Article 4 · Role of the Client
The Client remains responsible for the accuracy of source documents it provides, for decisions on red-list and review items, and for its own regulatory obligations, including under the Wwft. The Services do not constitute legal or tax advice.
Article 5 · Data protection
Personal data in the product is processed on behalf of the Client under a data processing agreement. The Client remains controller; Counterpass acts as processor.
Article 6 · Confidentiality
Each party keeps the other's confidential information confidential and uses it only for the performance of the agreement. This survives the end of the agreement.
Article 7 · Fees and payment
Fees are as agreed per plan or engagement, exclusive of VAT, payable within 30 days of invoice. We may adjust fees annually with notice.
Article 8 · Availability and support
We make reasonable efforts to keep the Services available and to remedy faults within a reasonable time. Planned maintenance is announced where practicable.
Article 9 · Liability
Our aggregate liability per calendar year is limited to the fees paid by the Client for the Services in that year. We are not liable for indirect damage, including lost profit or regulatory fines, except in case of intent or gross negligence.
Article 10 · Term and termination
Agreements run for the agreed term and renew unless terminated with one month's notice before the end of the term. Either party may terminate for cause on material breach not cured within 14 days. On termination, Client data is returned or deleted in line with the data processing agreement and statutory retention duties.
Article 11 · Governing law and forum
Dutch law applies. Disputes are submitted to the competent court in Amsterdam.
Cookie policy
counterpass.io · last updated November 2026
This website sets no cookies. No analytics cookies, no advertising cookies, no tracking pixels and no third-party embeds that set them. The fonts are included in the pages themselves, so no request leaves your browser to a font service.
If this ever changes, this policy will be updated first and consent will be asked where the law requires it.