EXTERNAL PRIVACY POLICY

May 2018

1. Definitions
2. Key policy principles
3. Data collection
4. Why does Balderton Capital collect your personal data?
5. Accurate Data
6. Access and rectification
7. Timely Processing
8. Data Security
9. Data Compliance Officer (DCO)
10. Use of personal data for direct marketing purposes
11. Use of cookies or similar devices
12. Disclosure of personal data
13. Disclosures outside the EU/EEA
14. Your choices and your rights
15. Contact

Balderton Capital respects your privacy. This Data Protection Policy (the Policy) describes how we process personal data, which personal data we collect and why we collect it, with whom we share this personal data, how we protect it, and the choices you can make about how we use your personal data.

This Policy applies to any personal data collected, held or processed by or on behalf of Balderton Capital, relating to any individual in his or her dealings with Balderton Capital as investee, stakeholder or member of the general public

The scope of this Policy also includes all the websites, sponsored social media platforms and any other online initiatives that are owned by Balderton Capital, where personal data is processed. Unless an express consent is required by the data privacy laws of your country, by using our media platforms, you consent to the collection and use of your personal information by us as described in this Policy. If you chose not to provide us with your personal information, in most cases, we will not be able to provide you with information about Balderton Capital

The requirements of this Policy are in addition to, not in substitution for, any other requirements under the applicable data protection laws and regulations. In case of conflict between the applicable data protection laws and regulations and the provisions of this Policy, the applicable data protection laws and regulations shall prevail.

Balderton Capital may amend this Policy at any point in time. Please check this Policy periodically by emailing [email protected] to obtain an up to date copy to inform yourself of any changes.

1.Definitions

1.1 In this Policy, the following terms shall have the following meanings:

Data Controller means the organisation which determines the purposes for which, and the manner in which, any Personal Data is Processed. For the purposes of this Policy, the Data Controller(s) is Balderton Capital.
Data Processor means the individual and/or organisation which Processes Personal Data on behalf of the Data Controller.
Data Compliance Officer or DCO means the data compliance officer nominated by Balderton Capital to be the contact point for data compliance, but without the obligations of a Data Protection Officer applicable under the GDP Regulation 2016
Data Subjects means all individuals about whom Balderton Capital holds Personal Data.
EEA means the European Economic Area (which is composed of the EU Member States and Iceland, Norway, and Liechtenstein).
Personal Data is any data relating to a living individual which allows the individual to be identified, whether from the data alone, or in combination with other information. A description of the Personal Data Processed by Balderton Capital is set out below.
Processing means any operation or set of operations which is performed upon Personal Data, such as the collection, recording, organization, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of Personal Data.
Sensitive Personal Data means, among others, Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the Processing of data concerning health or sex life. Special provisions apply to the Processing of Sensitive Data.

2. Key policy principles

2.1 We value the Personal Data entrusted to us and we are committed to Processing Personal Data in a fair, transparent and secure way. The key principles of this Policy are as follows:

Data collection: we will only collect Personal Data by fair, lawful and transparent means.
Data minimization: we will limit the collection of Personal Data to what is directly relevant and necessary for the purposes set out in this Policy.
Purpose limitation: we will only Process your Personal Data for specified, explicit and legitimate purposes and not further Process your Personal Data in a way incompatible with those purposes.
Accuracy: we will keep your Personal Data accurate.
Data security: we will implement appropriate technical and organisational measures to ensure an appropriate level of security in relation to the risks represented by the Processing and the nature of the Personal Data to be protected. Such measures provide for the prevention of any unauthorised disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of Processing.
Access and rectification: we will Process your Personal Data in line with your privacy rights.
Retention: we will retain your Personal Data in a manner consistent with the applicable data protection laws and regulations. In any event, we will not keep your Personal Data longer than is necessary for the purposes set out in this Policy.
International transfers: we will ensure that any Personal Data transferred outside the EU/EEA is adequately protected.
Third parties: we will ensure that access to and transfers of Personal Data to third parties are carried out in accordance with the applicable laws and regulations and with suitable contractual safeguards.
Direct marketing and cookies: where we send you promotional materials or place cookies on your computer, we will ensure that we do so in accordance with the applicable laws.

3. Data collection

3.1 Personal Data you provide us directly

We collect information directly from you in circumstances for example when you:

contract with us;
choose to participate in our newsletters;
call or email us, or otherwise provide information directly to us;
register your details in the Registration Tablet upon arrival at Balderton Capital’s premises;
interact with us in social media.

The Personal Data you provide to us directly can include:

3.1.1 Personal data that you provide at different points of contact with Balderton Capital may include :

Identification data:

Personal identifying information: name, title, address (private and professional), previous addresses, telephone number (residential, business), e-mail address, nationality.
Personal characteristics: age, gender, date of birth, place of birth, marital status and nationality
Professional information: occupation.

3.1.2 In case of the need to verify your Identity (e.g. subject access requests, know your customer (KYC)) data that will be collected from you can include:

IDs assigned by us, identification data issued by the public services, number of identity card, passport, driving license, or a copy of ID (passport, driver’s licence, comparable identity document)

Such data will only be used for verification of identity relating to the purposes it was requested for.

3.1.3 When interacting with Balderton Capital through online channels (e.g. website) the following information can be captured (in accordance with the cookies policy):

Electronic identification data: IP addresses, cookies, moments of connection.

3.1.4 For travel services the following data can be collected:

Electronic data location: GSM, GPS.

3.1.5 When receiving or applying for investments, the following data can be collected and treated under the local banking legislation (i.e. it will not be shared with any other entities of Balderton Capital):

Financial features (only in relation with financial services offerings): Income/possessions of Data Subject and his/her partner, solvency, assessment of income, financial status, credit rating, details relating to insurance, professional activities of the data subject and their partner, conventions and agreements.
Housing characteristics: Address of housing, housing type, own house or leased, length of stay at this address, rent, charges, classification of housing, valuation details, names of key holders.

3.1.6 For special events (e.g. new initiatives) Balderton Capital might take – with your permission –photos and videos of you:

Image recordings: Films, photographs, video recordings, digital photos.

3.2 Personal Data we receive from third parties

We may obtain the same categories of Personal Data about you from third parties such as our network of authorised third parties, carefully selected business partners who provide services on behalf of us, and any other third party who may lawfully pass to us information about you.

3.3Personal Data we collect automatically

We may collect certain information by automated means (e.g. cookies, log-files or web beacons) when you visit websites and digital applications and services. For further information on these technologies, we refer to section 8 of this Policy.

4. Why does Balderton Capital collect your personal data?

4.1 Balderton Capital may Process the Personal Data for the following purposes (the Purposes):

Information Requests: to answer your questions or to respond to your requests;
Events and Surveys: to organise events, seminars, etc. in which you participate;
Newsletter: to send you newsletters (provided that you have subscribed to the Balderton Capital newsletter);
Investment Opportunities: to facilitate our assessment of an investment opportunity;
Fundraisings: to contact current or potential limited partners in current or future Balderton Capital funds;
Direct Marketing: to send you email and/or postal messages or contact you by phone or via the social media or any contact channel you have supplied to us with information about Balderton Capital and other content we think may be of interest to you;
Advertising, marketing and public relations: including advertising and marketing Balderton Capital’s business and activities, studying of consumer preferences, and promoting public relations in connection with Balderton Capital’s business and activities;
Accounts: including keeping accounts relating to any business and activity carried out by Balderton Capital and keeping records of purchases, sales and transactions;
Safety and security: any method, system or process used by Balderton Capital to protect its physical and intellectual property, to protect its economic and financial interests and to protect the integrity of its directors, employees, investees and stakeholders.
IT support and development;
Compliance and legal claims: including ensuring compliance with legal obligations or establishing, exercising or defending legal claims;
Financial and statistical research: including the collection and processing of personal data for statistical surveys (or necessary to reach statistical results), analysing earlier events, and establishing patterns and rules of conduct;
Reporting: to enable us to report back to the limited partners in the Balderton Capital funds;
To prepare for and carry out a merger, take-over, transfer of an undertaking, transfer of assets or any other type of corporate transaction; and
Any other purpose described and communicated to you prior to using your Personal Data for such other purpose.

4.2 Balderton Capital shall only Process Personal Data to the extent that it is required for the Purposes and for any other purpose specifically permitted by the applicable data protection laws and regulations.

4.3To the extent required under the applicable data protection laws and regulations, Balderton Capital shall notify the Processing of Personal Data to the relevant authorities.

5. Accurate Data

5.1 It is important for us to maintain accurate and up to date records of your Personal Data. Please inform us of any changes to or errors in your Personal Data as soon as possible by contacting [email protected] We will take reasonable steps to make sure that any inaccurate or out-of-date data is deleted, destroyed or amended accordingly.

6. Access and rectification

6.1 You have the right to access the Personal Data we hold about you and, if such Personal Data is inaccurate or incomplete, to request the rectification or erasure of such Personal Data. If you require further information in relation to your privacy rights or would like to exercise any of these rights, please contact [email protected]

7. Timely Processing

7.1 We shall retain your Personal Data in a manner consistent with the applicable data protection laws and regulations. We will only retain your Personal Data for as long as necessary to comply with the applicable laws and regulations or for the Purposes for which we Process your Personal Data. For guidance on how long certain Personal Data is likely to be kept before being destroyed, please contact [email protected]

8. Data Security

8.1 We shall ensure that appropriate technical and organisational security measures are taken against unlawful or unauthorised Processing of Personal Data, and against the misuse, destruction, disclosure, acquisition, accidental loss of, or damage to Personal Data. Personal Data shall only be processed by a third party Data Processor if that Data Processor agrees to comply with those technical and organisational measures.

8.2 Maintaining data security means guaranteeing the confidentiality, integrity and availability of the Personal Data:

Confidentiality: we will protect your Personal Data from disclosure to third parties.
Integrity: we will protect your Personal Data from being modified by unauthorised third parties.
Availability: we will ensure that authorized parties are able to access your Personal Data when needed.

8.3 Security procedures include:

8.3.1 Security Policy

Acceptable Use Policy
Risk analysis and assessment

8.3.2 Organisation and human aspect of security

Information security training and awareness for personnel
Disciplinary measures in case of non-compliance
Confidentiality agreements in contracts
Third Party Security Programme

8.3.3 Physical and environmental safety

Prevention, detection and processing of the physical dangers (fire, water damages, etc.)
Backup System

8.3.4 Network Security

Access Control Policy
Authentication system

8.3.5 Access logging, tracking and analysis

8.3.6 Monitoring, review and maintenance

8.3.7 Management of security incidents and continuity

Incident Management Policy
Disaster recovery procedures
Business continuity plan

8.3.8 Complete and updated documentation.

9. Data Compliance Officer (DCO)

9.1 Balderton Capital have nominated a Data Compliance Officer to assist with the lawful processing of personal data.

9.2 If you have a query in relation to this Policy or our Processing of your Personal Data, you can contact the Data Compliance Officer via [email protected]

10. Use of personal data for direct marketing purposes

10.1 We will only use your Personal Data for the purpose of sending marketing material via electronic means (e.g. email,) if we have obtained your prior consent. You can withdraw your consent at any point in time, by following the unsubscribe instructions included in the marketing material or by contacting [email protected]

11. Use of cookies or similar devices

11.1 We use cookies on our websites.

11.2 For further information about our use of cookies and on how to avoid them, please consult our privacy statement on our website.

12. Disclosure of personal data

12.1 For the above mentioned Purposes, we may disclose your Personal Data to the following categories of recipients:

12.1.1 Authorised staff members of Balderton Capital.

12.1.2 Corporate affiliates and subsidiary companies of the Balderton Capital;

12.1.3 Our advertising, marketing and promotional agencies: to help us deliver and analyse the effectiveness of our advertising campaigns and promotions;

12.1.4 Business partners: trusted companies that may use your Personal Data to provide you with the services and/or the information you requested and/or that may provide you with marketing materials (provided that you have consented to receiving such marketing materials). We ask such companies to always act in compliance with applicable laws and this privacy policy and to pay high attention to the confidentiality of your personal information.

12.1.5 Other parties when required by law or as necessary to protect Balderton Capital: Balderton Capital may share your Personal Data with other third parties:

to comply with the law, regulatory requests, court orders, subpoena, or legal process;
to verify or enforce compliance with Balderton Capital’s policies and agreements; and
to protect the rights, property or safety of Balderton Capital and/or its customers;

12.1.6 Other parties with your consent or upon your instruction: Balderton Capital may share your Personal Data with third parties when you consent to or request such sharing; and
12.1.7 Any other third party communicated to you by Balderton Capital prior to sharing tour Personal Data with that third party.

13. Disclosures outside the EU/EEA

13.1 Your Personal Data may be transferred to any of the recipients identified in this Policy, some of which may be outside the EU/EEA and may be Processed by us and any of these recipients in any country worldwide. The countries to which your Personal Data is transferred may not offer an adequate level of protection. In connection with any transfer of Personal Data to countries that do not offer the same level of protection as in the EU/EEA, Balderton Capital shall implement appropriate measures to ensure an adequate level of protection of your Personal Data.

14. Your choices and your rights

We want to be as transparent possible with you, so that you can make meaningful choices about how you want us to use your information.

We can contact you by post and by phone, and if you give us your prior consent to do so, by email, SMS and other electronics means.

14.1 Your choices:

In this context, you can make a variety of choices about how you want to be contacted by us, through which channel (e.g. email, mail, Social Media, …), for which purpose and how frequently, by adjusting the privacy setting on the relevant device or updating your user or account profile or by following the unsubscribe instructions included in the communication.

Please note that by default, if you don’t make a choice, you will receive our promotional communications at the following frequency: at date of publication.

14.2 Your personal information

You may always contact us by post or email to find out what personal information we have concerning you and the origin of these.

14.3 Your corrections

If you find any mistake in your personal information or if you find it incomplete or incorrect, you may also require from us that we correct it or complete it.

14.3 Your objections

You may also object to the use of your data for direct marketing purposes (if you prefer, you can also advise us on which channel and how frequently you prefer to be contacted by us) or to the sharing of your personal information with third party for the same purpose.

Finally, you may request for us to erase any data concerning you (except in some cases, for example to provide proof of a transaction or when required by law).

15. Contact

15.1 For any privacy issues, questions or complaints concerning the application of this Policy or to exercise your rights of access or rectification within the context of this Policy, you may contact Balderton Capital at [email protected]