Privacy Statement

Privacy Statement Content

  1. Introduction
  2. SOSV Services
  3. What Personal Data Do We Collect and Why
    1. General
    2. Communication And Correspondence
    3. Existing And Potential Limited Partners
    4. Co-Investors Or Potential Co-Investors
    5. Corporate Partner And Mentors
    6. Portfolio Companies
    7. Employees And Applicant Employees Or Interns
  4. How Your Personal Data is Collected
  5. Disclosures Of Your Personal Data
  6. Security Of Your Data
  7. Data Retention
  8. International Transfers
  9. Your Rights
  10. Contact Us
  1. Introduction

    SOSV Limited, a limited liability company incorporated under the laws of Ireland with registered number 433655 and together with its affiliates (“SOSV”, “we”, “us” or “our”), respects your privacy and personal data. This statement describes what personal data we collect and how we use, process and disclose such personal data. Personal data is any information that relates to identified or identifiable persons, in particular by reference to an identification number or to one or more factors specific to their physical, physiological, mental, economic, cultural or social identity.

    We may update this Privacy Statement as required. Each time you use our services you should review this Privacy Statement. If we make any material changes to this Privacy Statement we will post a notice on our website when these changes are implemented. Your use of our services following any such changes indicates your acceptance of our Privacy Statement.

  2. SOSV Services

    SOSV is an early stage investment firm. Your personal data is only collected in accordance with the law. For example, we may require your personal data to provide services as requested by you or to enter into contractual relationships with you. If you do not consent to the provision of such personal data we may not be able to enter into such contractual relationships or provide such services. Our services are intended for adults only. We do not knowingly collect, use and process or disclose personal data relating to children.

  3. What Personal Data Do We Collect And Why
    1. General

      We may collect your personal data from direct and indirect interactions with you to provide our services as agreed by you or to fulfill our contractual obligations with you.

      In this regard we may gather personal data that may include your:
      Name, address, nationality, email address, telephone number, bank account details, job title, name of employer, bank account details, tax ID or your national insurance number, forms of identification.

      We may use this information to:
      Set up meetings with you, maintain a record of your contacts, respond to your enquiries and fulfill your requests, assist you with your transactions or provide you with investor related services.

      The use and processing of your personal data is necessary for our legitimate interests in providing our services, carrying out of administrative duties, the running of our business and in order to make or advise on investment decisions.

    2. Communications And Correspondence

      In the course of communications or correspondence with you we may need to collect your personal data in order to develop our services and offerings and inform our marketing strategy.

      In this regard we may gather the following personal data:
      Name, residential or business address, job title, name of employer, nationality, email address, home or office address.

      The use and processing of your personal data is required for our legitimate interests to develop our services, grow our business and inform our marketing strategy.

    3. Existing And Potential Limited Partners

      Limited Partners (“LPs”) include any individual who invests in any fund managed by SOSV or its affiliates and/or individuals who invest or may potentially invest in our portfolio companies.

      We may collect your personal data for the following purposes:
      Due diligence including identity verification and eligibility checks, to maintain communications by storing a record of contacts, organising meetings with you, responding to your enquiries and requests, investment management i.e capital calls, payments and cash distributions, the completion of fund related documentation.

      In this regard we may gather the following personal data:
      Name, residential address, tax ID, social security number, forms of identification, email addresses, telephone numbers, bank account details.

      We use and process this information for the following purposes and legitimate interests:
      providing our services, administrative purposes, making or advising on investment decisions, performance of contractual relationships, to comply with relevant regulations and laws, tax and compliance obligations including anti money laundering regulations and criminal background checks.

    4. Co-Investors Or Potential Co-Investors

      Co-Investors or potential co-investors include individuals who solely or as part of a corporation invest in the same portfolio companies as SOSV.

      In this regard we may gather the following personal data:
      Name, residential address, telephone number, social security number, forms of identification, email addresses, telephone numbers, job title, employer details.

      We use and process this information for the following purposes and legitimate interests:
      providing our services, administrative purposes, making or advising on investment decisions, performance of contractual relationships, to comply with relevant regulations, laws, tax and compliance obligations.

    5. Corporate Partners And Mentors

      Corporate partners or mentors include any individual who work with SOSV to provide guidance and support to our Portfolio Companies on the basis of their expertise and skill in a given area.

      We may collect personal data from corporate partners and mentors including:
      Name, email address, telephone number, job title, bank account details, area of business and employment history.

      We use and process such personal data for our legitimate interests such as providing services, running our business and administrative purposes.

    6. Portfolio Companies

      We gather personal data from individuals involved in our portfolio companies for the following purposes:
      Founder, director, shareholder and relevant third party identity verification, due diligence checks, ongoing investment management, analysis of company proposals, pitches and presentations, organising meetings with you and maintaining a record of contacts.

      Personal data collected for the above purposes include:
      Founder, director and shareholder names, addresses, email addresses, phone numbers, bank account details; founder nationalities and gender.

      We use and process such personal data for the following purposes and legitimate interests - Providing program and general services; administrative purposes; making or advising on investment decisions; performance of contract rights and obligations with you.

    7. Employees And Applicant Employees Or Interns

      Our employee’s personal data is held on various internal systems. An employee’s personal data policy has been made available to all our employee’s setting out their rights as a data subject. Our legal basis for such processing concerns the employer/ employee contractual relationship.

      We collect personal data of applicant employees in order to consider and manage employment applications.

      Personal data collected may include the following:
      Name, address, date of birth, social security number or tax ID, form of identification, nationality, email address, telephone number, job title, employment history and resumé.

      We require the above information in accordance with your consent and for our legitimate interests in providing our services, running our business, administrative purposes, to enable performance of contractual relations, allow us to progress your potential employment or internship.

  4. How Your Personal Data Is Collected

    Your personal data may be collected directly by interacting with us via:

    Your personal data may also be gathered by automated means or indirectly via public sources such as results from search engines, third party databases, company registration offices or cookies on our websites. You can learn more about cookies by visiting our Cookie Policy.

  5. Disclosures Of Your Personal Data

    SOSV may disclose your personal data to third party service providers such as human resources, legal and accounting services, communications and networking services, IT system administrators and professional advisors, regulators and other authorities. Such disclosures will only be made in accordance with this Privacy Statement and any iterations of this Privacy Statement made over time. All third party service providers are only permitted to process your personal data in accordance with stated purposes and in accordance with our instructions. All processing of your personal data by third parties is carried out in accordance with the law and industry standard security measures.

  6. Security Of Your Data

    SOSV uses industry standard security measures to prevent the loss, misuse or alteration of your personal data within our control. In addition we limit access to your personal data to those SOSV authorised personnel who have a legitimate business purpose to access such personal data. All such personnel are subject to strict confidentiality obligations.

    We have implemented measures in the event of any suspected personal data breach. In such instances we will notify you and the applicable data protection regulator as required by law. Unfortunately, no security system is entirely secure and we cannot guarantee the security of your information.

  7. Data Retention

    We only retain your personal data for the period required to achieve the purposes for which it was collected. Note that such purposes include legal, accounting or reporting requirements.

    To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

  8. International Transfers

    SOSV is based in the European Economic Area (“EEA”) and will only transfer your personal data in accordance with this Privacy Statement. In order to provide our services to you and carry out our legitimate interests we may need to transfer personal data to our affiliate entities or other third parties located outside the EEA. Where such parties are not located in a country deemed to provide an adequate level of protection for personal data by the European Commission, we will ensure that standard contractual clauses approved by the European Commission are in place with the transferee. If we transfer personal data to third party service providers or affiliates located in the United States, such transfers will be done in accordance EU-US Privacy Shield which requires such transferees to provide similar protection to personal data as provided within the EEA.

  9. Your Rights

    Your rights with regard to your personal data:

    • Stay informed: The right to know how we use your personal data;
    • Access: The right to request a copy of and access to your personal data;
    • Amend or update: The right to update or correct your personal data;
    • Erase: The right to erase your personal data;
    • Restrict: The right to restrict the processing of your personal data;
    • Data Portability: The right to obtain your personal data from us and re-use such data for your own purposes. We may also transfer your personal data to third parties as appointed by you;
    • Object: The right to object to the processing of your personal data e.g. when you believe our legitimate interest for processing your data negatively impacts your rights;
    • Automated decision making or profiling: The right to object to decisions that are based on automated processing of your personal data.
  10. Contact Us

    To exercise your rights please contact SOSV by post at the following address: SOSV Limited, First Floor, 12 South Mall, Cork City, Cork, Ireland, T12 RD43 or contact us via email: compliance@sosv.com along with a copy of your identification. Depending on your request and the applicable law, we may be entitled to decline your request.

Last updated: 15th June 2018

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