This Privacy Notice describes the privacy practices of Activate Capital Partners and its affiliates, (collectively, “Activate Capital”). This Privacy Notice describes how we collect, use, store and disclose (together “process”) personal data in connection with offering, forming and operating private investment funds, and explains the rights and choices available to individuals.

Activate Capital may provide additional privacy notices to individuals at the time we collect their data (e.g. potential investors or employment candidates) that describe our privacy practices in connection with specific activities and will apply to the information you provide at that time, in addition to this notice. 

Please note this Privacy Notice does not apply to Activate Capital’s processing of employee or contractor data.

BY PROVIDING YOUR PERSONAL DATA TO ACTIVATE CAPITAL OR OTHERWISE USING OUR WEBSITES OR APPLICATIONS, YOU UNDERSTAND THE TERMS OF THIS PRIVACY NOTICE AND WISH TO CONTINUE TO PROVIDE YOUR PERSONAL DATA FOR THE PURPOSES DESCRIBED.

Whose Personal Data We Collect?

We collect personal data about the following types of individuals: investors or potential investors, and family members of investors in certain circumstances, and other financial advisors, financial professionals or ultimate beneficial owners. We may also collect personal data about heirs and estate beneficiaries related to investments or accounts you hold with us.

We may also collect personal information of contractors, consultants, job applicants, volunteers, visitors to our offices, and other individuals who interact directly with Activate Capital or its service providers or business partners, including users of websites and mobile applications.

How We Collect Personal Data

We may collect personal data:

• Directly from individuals as part of our recruitment activities
• Automatically through our website(s) and mobile apps, if applicable (including automated online mechanisms such as cookies)
• From investor applications and questionnaires
• From subscription agreements (including, without limitation, any anti-money laundering, identification and verification documentation)
• From public sources such as government agencies, any tax authorities to which you are subject, and other public registries and agencies 
• From third party service providers, data brokers or business partners
• From social media or other public forums (including adverse event information or product quality complaints)
• From recruiters

Types of Personal Data We Collect

The types of personal data we collect, and share depends on the nature of the relationship you have with Activate Capital and the requirements of applicable laws. The types of personal data we may collect include but is not limited to:

• Names and identity information (including passport and drivers’ license) and verification documentation
• Personal or professional contact details (including physical address, email address and telephone number);
• Biographical and demographic information such as date of birth, age, gender, marital status;
• Professional credentials, educational and professional history, institutional and government affiliations;
• Financial data and other information such as tax, income and asset information provided to Activate Capital (whether directly or indirectly), and account or transaction information that may be relevant to managing our relationship with you (e.g. payment for services) or for completing necessary due diligence activities related to the conduct of our business activities;
• Information regarding your use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history);
• Information regarding your citizenship and location of residence;
• Security and access credentials such as username and password 
• Your photograph, social media handle or digital or electronic signature
• If you are a visitor to a Activate Capital office location, we may collect information through closed circuit television (CCTV)
• Other information you provide to us (such as in emails, on phone calls, through our websites or mobile applications, or in other correspondence)

How we use your Personal Data

To the extent permitted by applicable local law, we may use personal data for the following purposes:

• Communicating with you about the products and services we offer, and responding to requests, inquiries, comments, and suggestions
• Analyzing and enhancing our communications and strategies (e.g. effectiveness of emails or our website(s) and mobile applications, if applicable) 
• Operating, securing, and improving the administration and management of our private investment funds (in both physical premises and digital environments)
• The performance of contractual and legal obligations in connection with assessing suitability of potential investors in the Partnership
• Facilitating and improving our recruitment activities (such as processing employment applications, evaluating job candidate suitability and analyzing recruitment trends and statistics)
• Complying with regulatory due diligence and reporting obligations (including applicable anti-money laundering, KYC, employment and other related laws and regulations)

In some situations, we may have a separate agreement or relationship with you with respect to a specific type of processing of your data (e.g. a subscription or partnership agreement). These situations will be governed by specific terms, privacy notices, or consent forms that provide additional information about why we need your personal data and how we will use your information.

Note: Failure to provide the personal data requested to fulfil the purposes described in this Privacy Notice may result in our being unable to provide the services or information you have requested.

Legal basis for processing data

In some cases, Activate Capital has a legitimate interest to process the personal data that we collect to operate our business of offering opportunities to participate in private investment funds; to support our recruitment activities; or to facilitate a sale of assets or merger or acquisition. We may also process your personal data as necessary for the protection against criminal offences, safeguarding of domestic law, the maintenance of a safe workplace for staff, and enforcing the terms and conditions that govern the products or services we provide.

In other cases, Activate Capital processes personal data to fulfill our contracts with our business stakeholders, such as investors, service providers or employees.

Activate Capital’s processing of certain health and other associated information may be necessary to comply with our legal obligations, and for reasons of overriding public interest.

Activate Capital may rely on consent for the processing of your personal data and we will obtain such consent at the time we collect your personal data. For information on how to withdraw such consent, please see the “Personal Data Access Rights” section of this Privacy Notice.

Personal Data We Share

Activate Capital shares personal data for the purposes described in either this Privacy Notice or through a specific “in-time” privacy notice provided at the time we collect the information.

The types of individuals or entities we share personal data with include:

• Activate Capital affiliates and business stakeholders
• Service providers that perform services on our behalf, including but not limited to consultants, professional advisors, lenders and transaction processors.
• Customer service and investor support providers 
• Data storage and analytics and technology providers
• Regulatory bodies having competent jurisdiction over our business activities, including but not limited to the tax authorities, auditors and tax advisors (only where necessary or required by law)

Unless prohibited by applicable law, we may disclose personal data as part of a corporate business transaction, such as a merger, acquisition, reorganization, joint venture or the sale of our assets. We may also disclose personal data to a successor entity in the event of insolvency, bankruptcy or receivership.

International data transfers

In the event we transfer your personal data to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice, the countries to which we transfer personal data may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal data across borders, we consider a variety of requirements that may apply to such transfers, but in any event, we will only transfer your data to a destination and in a manner that ensures your personal data will remain protected at the same or equivalent level as in the country of origin. This may include executing contracts which commit the recipient to process personal data in accordance with applicable law in the country of origin (e.g. Standard Contractual Clauses published by the EU Commission)

Data Retention

Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations. Personal data will be retained throughout the life of our relationship with you (e.g. the investment lifecycle). However, some personal data will be retained after our relationship ends if reasonably needed for monitoring or reporting, or if legally required.

Personal Data Access Rights

Individuals are able to exercise the following rights in relation to the personal data that we may have collected about you. Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our products or services to individuals who exercise these rights, or to otherwise engage with such individuals going forward. 

We reserve the right to verify the identity of the individual in connection with any requests regarding personal data, to help ensure that we provide the information to individuals to whom the information pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

Withdrawal of consent

Where you have provided consent to us to process your personal data, you may withdraw such consent by following the instructions provided at the time of collection or by contacting us using details in the Contact Us section below. In some instances, withdrawing your consent may mean we can no longer provide services to you or otherwise engage with you.

Access to personal data

You may request access to the personal data that we maintain about you. You may request to correct any errors in your personal data. In the event we cannot comply fully or at all, with your request, we will notify you of the reasons for this.

Objection to and deletion of personal data

To the extent provided by applicable law, you may object (opt-out) at any time on legitimate grounds to the processing of your personal data or request that we delete your personal data from our records. In some cases, we may not be able to comply with your request or comply fully. In the event we cannot comply, we will notify you of the reasons for this.

In any event, you have the right to file a complaint with a regulator or data protection supervisory authority in your jurisdiction if you believe your personal data has not been processed in accordance with applicable data protection or privacy law.

Note about “Sales”: Activate Capital does not “sell” personal data as most people would typically understand that term. To request further information about this, you can do so by contacting us using details in the Contact Us section below

When submitting a request to exercise any of these rights, please describe your relationship with us and your request, with sufficient detail to allow us to properly understand, evaluate, and respond to it. We may need to further verify your identity before processing your request, which may require us to request additional personal data from you. 

How we Protect Personal Data

Activate Capital maintains reasonable administrative, technical and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot guarantee that the measures we maintain will ensure the security of the personal data.

Minors

We do not knowingly collect personal data from children under age 13 through our websites or mobile applications. If we learn that we have collected personal data directly from a child under the age of 13 through our website(s) or mobile applications, if applicable, we will delete that information.

Links to Websites and Third-Party Content

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by Activate Capital. The websites and third-party content to which we link may have separate privacy notices or policies. Activate Capital is not responsible for the data processing practices of any entity that it does not own or control.

Cookies and Other Automated Information Collection

We, our service providers, and our business partners, may collect certain information about the use of our websites and mobile applications by automated means, such as cookies, web beacons and other technologies (“Automated Information”). Please see our Cookies Policy for more information about the cookies we collect. We or our service providers and business partners may also collect Automated Information about your online activities over time and across our own and third-party websites when you use our websites and mobile applications, including to deliver customized content. In jurisdictions where Automated Information is considered personal data, or if we associate Automated Information with personal data, we will treat Automated Information as personal data and process such information in accordance with this Privacy Notice.

Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. You can visit Aboutcookies.org for information about cookie and how to disable them.

Updates to our Privacy Notice

Activate Capital reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.

Contact us

You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or to request access to or correction of your information. When raising a request or complaint, please provide sufficient details (including your relationship with us) and any relevant documentation. Contact our Privacy Office at: