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 Policy

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.

Your Rights

We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:

where data is processed on the basis of consent, the right to withdraw that consent;
the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal data;
the right to have inaccurate data rectified;
the right to object to your data being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
the right to restrict how your personal information is used; and
the right to be forgotten, which allows you to have your data erased in certain circumstances (though this is not an absolute right and may not apply if we need to retain or continue using the information for a lawful reason).

If you would like to exercise your rights, please contact us at [email protected]

Sometimes you may be asked to provide proof of identity before we show you your personal information so that we can prevent unauthorised access.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request).

We cannot absolutely guarantee the security of the internet or external networks or your own device. Accordingly any online communications (e.g. information provided by email or through our website) are at your own risk. You accept the inherent security risks of providing information online over the internet and will not hold us responsible for any breach of security unless this is due to our negligence or wilful default.

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

No.	Mandatory PAI Indicator	Commentary
1	GHG emissions (scope 1, 2 and 3)	Carbon footprinting will be included in the EDCI annual submission. PCI II will therefore see this information and trends, and will react accordingly, but with the flexibility to pass on this information to investors in a bespoke way.
2	GHG intensity	Arguably not a useful metric for companies at a very early stage because we know and expect that GHG intensity will rise over the first few years of operations. It will be more useful to encourage companies to be the best in their sector in terms of intensity as they mature.
3	Exposure to companies active in the fossil fuel sector	This will not be relevant because PCI II funds do not invest in fossil fuel companies.
4	Share of non-renewable energy production	Production will not be relevant because PCI II funds do not invest in fossil fuel companies.
4	Share of non-renewable energy consumption	Consumption will be included in the EDCI annual submission. PCI II will therefore see this information and trends, and will react accordingly, but with the flexibility to pass on this information to investors in a bespoke way.
5	Energy consumption intensity per high impact climate sector	This will probably not be relevant because PCI II funds invest primarily in fintech companies, not in high impact climate companies.
6	Negative impact on biodiversity	This will probably not be relevant because PCI II funds invest primarily in fintech companies
7	Emission to water	This will probably not be relevant because PCI II funds invest primarily in fintech companies
8	Hazardous waste ratio	This will not be relevant because PCI II funds do not invest in companies generating hazardous waste.
9	Violations of UN Global Compact principles and OECD Guidelines for Multinationals	Arguably not a useful metric for companies at a very early stage because both regimes are aimed at larger organisations. We believe in setting ESG policies and goals that fit the size of the company.
10	Mechanisms to monitor UN Global Compact principles and OECD Guidelines for Multinationals	Arguably not a useful metric for companies at a very early stage because both regimes are aimed at larger organisations. We believe in setting ESG policies and goals that fit the size of the company.
11	Unadjusted gender pay gap	Arguably not a useful metric for companies at a very early stage because the small number of employees will not yield useful data. UK gender pay gap reporting becomes mandatory once companies have 250 employees. We believe in setting ESG policies and goals that fit the size of the company.
12	Board gender diversity	Board diversity will be included in the EDCI annual submission. PCI II will therefore see this information and trends, and will react accordingly, but with the flexibility to pass on this information to investors in a bespoke way.
13	Exposure to controversial weapons	This will not be relevant because PCI II funds do not invest in controversial weapons

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