Felix Capital Partners LLP (“Felix or the “Firm”)

Scope of Policy
This Policy applies to personal data we collect about individuals:

• who visit our websites or otherwise interact with us via social media – including, where individuals choose to receive our newsletters;

• who visit our offices;

• who are employed or otherwise engaged by our service providers or professional advisors;

• with whom we have contact for business-related purposes (including, without limitation (i) limited partners in our funds; (ii) portfolio companies; and (iii) founders/companies that we engage with as part of our investment pipeline); and

• who we deal with in connection with transactions, or potential transactions.

This Policy does not apply to personal data:

• we collect about job applicants or our employees; and/or 

• collected by any third party, including through any application or content (including advertising) that may link to or be available from our websites.

If you are an organization (for example, a business associate, service provider, professional advisor or investee), we would ask that you provide this Policy to individuals (e.g., customers, or directors, officers, employees, partners and other staff) who have or have had dealings with us on your behalf.

This Policy should be read together with any additional notice that we may provide to you when we collect or otherwise process your personal data.

What personal data do we process and why

1. Individuals who visit our websites or otherwise interact with us via social media channels

What personal data do we process?

• Name and email address

• Log-in information (e.g. for access to online portals)

• Other personal data you voluntarily disclose to us in your communication
  with us

Why do we process your data?

It is in our legitimate interest to process such data in order to respond to your queries, complaints or other communications.
 
If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

Sources of personal data: We will collect the above personal data directly from you.

Cookies: As is now common with most websites, our websites use cookies and may use other online tracking tools (e.g., web beacons) to automatically collect information about your IP address, your use of the websites, or other websites you may visit after ours. Cookies are small data files generated by a website and saved by your web browser. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites.

• Individuals who visit our offices

What personal data do we process?

• Name, contact details and company information provided to us

• Video images from CCTV

Why do we process your personal data?

It is in our legitimate interest to process such data in order to keep our offices secure.
The processing may be necessary to comply with our legal obligations including, those in relation to health & safety.

Sources of personal data: We will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer).

• Individuals who are employed or engaged by our service providers or professional advisors or with whom we have contact for other business related purposes

What personal data do we process?

• Name, contact details (including email address), job title and company information

• Identity and nationality information (e.g., contained in passports)

• Other personal data you voluntarily disclose to us in your communication with us

Why do we process your personal data?

It is in our legitimate interest to process such data in order to: (i) arrange calls / meetings with you or others at your company; (ii) conduct our business; and (iii) manage our relationships with service providers and professional advisors (e.g., record-keeping).
 
The processing may be necessary to perform, or to enter into, contracts with such providers and advisors.

Sources of personal data: We will collect the above personal data directly from you or from the company with which you are affiliated (e.g., your employer).

With whom do we share your personal data

We may disclose and/or make available your personal data to:

• Corporate affiliates and subsidiary companies;

• Third-party service providers such as, our fund administrators, compliance/AML providers, and providers of IT and security services and IT platform service providers;

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

• Business associates (for example, investors, lenders or financial intermediaries) who are involved in, or considering being involved in, transactions where we are involved;

• Professional advisors (e.g., accountants, lawyers or other consultants);

• Independent public accountants and auditors;

• Third parties that are considering acquiring or that acquire all or part of our assets or stock, or that succeed us in carrying on all or part of our business or services provided to or by us; and

• Regulators and other governmental agencies

Timely processing

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.  To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider the applicable legal requirements and the extent to which it is necessary to process the personal data. 

Your data protection rights

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.

Your  rights with regard to personal data which we process about you, which may be subject to limitations and/or restrictions, include the following:

• You have the right to request access to the personal data we process about you.

• You have the right to request us to rectify any personal data that might be incorrect, as well as the right to request us to restrict the processing of your personal data.

• You may request to receive a copy of your personal data that you provided to us, in a structured, commonly used and machine-readable format.

• You have the right to request that we erase your personal data.

• You have the right to withdraw consent to the processing of your personal data at any time.

We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. Please direct any queries to info@felixcap.com