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Privacy Policy

This Privacy Policy sets out how we collect, use and protect your personal information. ‘Personal information’ is information which directly identifies or is capable of identifying a specific person. For the purposes of data protection law we will be a controller of your personal information. This means we make decisions about how and why your information is used and have a duty to ensure your rights are protected. The data controller, as defined under the General Data Protection Regulation (“GDPR”) as it forms part of the law of England and Wales by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”) is Passion Capital Investments II LLP (ICO registration number ZA482913) or Passion Capital Investments LLP (ICO registration number ZA061454). Our website www.passioncapital.com contains links to the websites of portfolio companies and third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend you check these policies before you submit any personal information to these websites. If you have any questions about this Privacy Policy or our use of your information you can contact us at [email protected] or by post at Second Floor, Laxmi, The Tanneries, 57 Bermondsey Street, London SE1 3XJ.

About This Privacy PolicyRisks

“Sustainability Risks” is defined in Article 2(22) SFDR as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment”.

Sustainability Risks include (but are not limited to):

  • Environmental risks, such as the impact of drought or flooding on operations of portfolio companies;
  • Social risks, such as the impact of “laddish” culture within a portfolio company; and
  • Governance risks, such as poor leadership and controls by founders within portfolio companies.
Integration of sustainability risks in the investment process

We take your privacy seriously and are committed to maintaining the privacy and security of information you provide to us, and the choices you have regarding our collection and use of your information. This Privacy Policy explains how we collect, store and use that personal information and sets out our approach to UK GDPR and other relevant UK laws. By making an application to us (to invest or for investment), meeting with us and/or by visiting our website you are accepting and consenting to the practices described in this Privacy Policy.

General Storage And Security Of Your Personal Information

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). By making an application and/or by using the website and/or providing us with any information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In respect of information received from you, we use strict procedures and security features set out in our Data Protection Compliance Policy to protect our paper based and computerised systems from loss and misuse. Our staff receive data protection training and access to personal data is restricted to only when it is absolutely necessary and then under strict guidelines as to what use may be made of the personal information. Unless specified in more detail below, we will keep your information stored on our systems for as long as it takes to provide the services to you. The personal information we hold about business contacts may be shared with: professional advisors; and/or companies who hold or process personal information on our behalf, or cloud based products such as Microsoft 365. The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you. We will not store your information for longer than is reasonably necessary or required by law. We regularly review what data we have and delete that which is no longer necessary. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.

What Information We Collect

As a part of our day to day operations we meet large numbers of business contacts at meetings and receive emails about investment opportunities. We are likely to receive and store personal information on those we meet. If you have had contact with us, for example through making an application, emailing us or meeting a colleague, it is likely that we will want to make a note of that email or meeting and may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details. When you interact with our website or online forms, we may also automatically collect the following information about your visit. This is primarily to help us better understand how people use our digital platforms to enable us create better content and more relevant communications: your browser type, versions and plug-ins, and your operating system; your journey through our digital platform, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information; and/or information collected in any forms you complete.

How And Why We Store Your Personal Information

We will collect and store this personal information for the purposes of: allowing you to participate as an investor in any of our funds, and performing our contractual responsibilities and complying with applicable legislation in respect of those funds; maintaining a record of contacts; providing periodic business updates; drawing to your attention working opportunities which may be of mutual benefit to us as described below; and/or organising meetings with you. The legal basis for collecting and storing such personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.

Sensitive Or Special Category Personal Data

We do not routinely request sensitive or special category personal data, such as information on race, religion, political views and your mental or physical health. However, the exception to that is to allow us to measure our progress on diversity and inclusion and in that case we may ask certain categories of our contacts (primarily our portfolio companies) to provide certain sensitive data metrics on a fully anonymized and fully optional basis.

Updates

We may update this Privacy Policy at any time. We encourage users to check this page frequently for any changes to stay informed about how we are helping to protect the personal information we collect.

Where To Make A Complaint

If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the above address. If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office at the following address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/email/ This Privacy Policy was last updated on 2 April 2024