The information contained in this Privacy Policy is intended to provide you with details of how we may collect and process your personal data from time to time and the circumstances giving rise to the request and receiving of data.
This Policy is issued by New Science Ventures Management Ltd (together “Company”, “NSV”, “us” or “we”) acts as a data controller and data processor.
This Privacy Policy is addressed to any person who is resident in the European Union and the UK who is any of the following: an investor in any fund managed or advised by the Company (a “Company Fund”), or a member, partner, shareholder, beneficial owner, officer, director, employee or other representative of any client of the Company or any investor or prospective investor in any Company Fund (together, “you”) whose personal data the Company collects and controls in the conduct of its business.
The personal data that we may collect about you
Personal data will only be collected on you where we believe we have a legitimate business interest with you or we have a lawful purpose to do so. These reasons may include but may not be limited to circumstances where you: are a limited partner in a fund managed by NSV; are involved with a current, prospective or exited portfolio company; or, have a contractual agreement with us.
In the conduct of our business, we may obtain personal data about you including, without limitation, your name, date of birth, address and other contact details, employment history, social security or national insurance number, tax or other identification number, identity documents and information about your income, assets and other financial information. This information typically comes from subscription documents or other written, electronic or verbal communications. We may also from time to time receive your personal data through intermediaries where you have authorised the sharing of your personal data with us. Intermediaries may include accountants and solicitors who are working on your behalf. Personal data may be provided to us via a secure data room, email, in person or by post. For cookies used when browsing our website please see our Cookie Policy. Where additional information is required we will provide you with a reasonable explanation of why it is required unless we are prevented from doing so by law.
How we use personal data
We collect your personal data to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of the Company and for other purposes for which the Company has a lawful basis under the Privacy Laws, including: (i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or “Know your Client” requirements, as well as to verify the status and / or eligibility of potential investors to invest in a Company Fund and for compliance with tax reporting requirements, (ii) for purposes of reporting to, or communicating with, investors concerning their investment in Company Funds; (iii) in connection with our investment activities, including investment due diligence or investment monitoring activities or in response to “Know your Client” requirements of counter-parties; (iv) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving the Company, Company Funds or Company clients, and (v) for other legitimate business interests.
We may also create personal data about you, such as records of interactions with us and details of your accounts subject to applicable law.
In addition, we may, with your consent, process your personal data in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about Company Funds, portfolio company updates and scheduled investor conferences. You have the right to unsubscribe from receiving these communications by emailing nsvreports@newscienceventures.com. This opt-out will not apply to communication with you in relation to a legitimate business interest or lawful purpose.
Special category data refers to any data that is sensitive and is subject to additional rules and requirements under the General Data Protection Regulations and may include information regarding: criminal convictions and offences, race, ethnicity, religious or philosophical beliefs, political opinions, sexual orientation, trade union membership and information about your health, genetic and biometric data.
We do not seek to collect or otherwise process your special category data except where it is necessary for compliance with a legal obligation, the detection or prevention of crime to the extent permitted by applicable law; you have manifestly made this data public; we have, in accordance with applicable law, obtained your prior explicit consent prior to processing special category data.
The disclosure of your personal data
We may share your personal data with Company entities including with Company Funds for any of the purposes set forth above and we may share your personal data with third parties for any of the purposes set out above, including:
- Service providers e.g. attorneys, auditors, accountants, tax advisers, administrators, banks, custodians, depositaries, distribution managers and brokerage firms, or other agent, adviser or service provider of any Company Fund or Company client;
- Other counter-parties e.g. managers, general partners or investment advisers or administrators or any of their respective agents or representatives;
- Governmental, legal, tax and regulatory, or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
- to any relevant party in connection with AML/KYC requirements; any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation) or the assets or business of our funds.
Where we transfer your Personal Data to other countries, we do so on the basis of:
- European Commission’s adequacy decisions;
- our binding corporate rules;
- suitable standard contractual clauses; or
- other valid transfer mechanisms.
If you want to receive more information about the safeguards applied to international transfers of personal data, please contact nsvreports@newscienceventures.com
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal grounds for this. We may process your personal data without your knowledge or consent only where this is required and permitted by law.
Security
We take seriously the obligation to safeguard your non-public personal data. We maintain physical, electronic, and procedural safeguards to protect against unauthorised access to your information.
Changes to this Policy
We may change this Policy from time to time. The latest version will be posted on our website.
Your rights
You have certain rights relating to the personal data we hold in accordance with and subject to the Privacy Laws to: (i) check whether we hold personal data about you and to access such data (in accordance with our policy); (ii) request the correction of personal data about you that is inaccurate; (iii) have a copy of the personal data we hold about you provided to you or another controller where technically feasible; (iv) request the erasure of your personal data; and (v) request the restriction of processing concerning you. To do so, please send your request to nsvreports@newscienceventures.com.
You will not have to pay a fee to access your personal data, or to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. In order to respond to a subject access request, we will need to confirm your identity as a security measure to safeguard you from your personal data from being disclosed to non-authorised third parties. Please provide us with as much information as possible to enable us to comply with your request within an acceptable time-frame. We are required to respond to subject access requests where practically possible within 30 days and, if this is not possible, we will provide you with a reasonable explanation as to why this cannot be achieved.
Updating your details
We will make all reasonable efforts to ensure the data we hold on you is accurate and up-to-date and to correct any inaccuracies that we become aware of. Please help us to comply with our obligations by letting us know of any changes in relation to the personal data we hold about you. Please email nsvreports@newscienceventures.com with any required updates or amendments. If you provided consent for us to use your personal data, including for marketing purposes, you have the right to withdraw consent and we will process this withdrawal promptly.
Data Retention
We retain your personal data for a period of at least 7 years from the date on which the relevant business relationship, for which purpose such personal data was provided, has ended.
What if I have a question?
Please email nsvreports@newscienceventures.com if you have any questions about our Privacy Policy. You may also make a complaint, in accordance with applicable Privacy Laws, to a supervisory authority in your country of residence. Our UK supervisory authority is the Information Commissioner’s Office.