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
  2. SOSV, together with its affiliates (“SOSV”, “we”, “us” or “our”), respects your privacy and Personal Data. SOSV collects and receives information that relates to identified or identifiable individuals. 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. This statement describes what Personal Data we collect and how we use, process and disclose such Personal Data.

    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.

  1. SOSV Services
  2. 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.

  1. What Personal Data Do We Collect And Why
    1. General
    2. 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, which includes primary operations as an accelerator venture capital organization, carrying out of administrative duties, the running of our business and in order to make or advise on investment decisions.

    3. Communications And Correspondence
    4. 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.

    5. Existing And Potential Limited Partners
    6. 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.

    7. Co-Investors Or Potential Co-Investors
    8. 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.

    9. Corporate Partners And Mentors
    10. Corporate partners or mentors includes any individual who works 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.

    11. Portfolio Companies
    12. 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.

    13. Employees And Applicant Employees Or Interns
    14. 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.

  1. How Your Personal Data Is Collected
  2. Your personal data may be collected directly by interacting with us via:

    • Our social media and networking pages including:
      • Linkedin (https://ie.linkedin.com/company/sosvvc);
      • Twitter (https://twitter.com/SOSVvc);
      • Facebook (https://www.facebook.com/SOSVvc/);
      • Medium (https://medium.com/@SOSVvc);
      • Mattermost (https://chat.sosv.com);
      • Angellist (https://angel.co/sosv);
      • YouTube (https://www.youtube.com/channel/UCr3_edKFdOwK6I5L081Zy5Q);
      • Instagram (https://www.instagram.com/sosvvc/); and
      • Our Affiliates social media and networking pages.
    • At our events. SOSV may host, co-host, co-ordinate and/or operate SOSV events, at which we may create visual or audio recordings, take photographs, conduct surveys or similar activities at such events and may as a result collect and process certain Personal Data.
    • Email, telephone, in person, by post or by providing us with Personal Data for the purposes of applying for investment, becoming or applying to become an investor or applying for employment or in the course of employment.

    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.

  1. Use/Disclosures Of Your Personal Data
  2. SOSV may, where necessary and/or appropriate, process Personal Data that you provide or that we receive if you participate on any SOSV program, use any SOSV service or websites or social media and networking pages (“SOSV Services”), in order to:

    • provide the SOSV Services you request;
    • be compliant with the terms and conditions of the SOSV Service;
    • comply with business and operational measures, such as data security monitoring, service analytics, internal research, quality control;
    • protect our rights, privacy, safety and/or property, and/or that of others.
    • protect, investigate and deter against any fraudulent, harmful, unauthorized, unethical or illegal activity.

    SOSV may disclose your Personal Data to SOSV Affiliates, third party service providers such as human resources, legal and accounting services, communications and networking services, IT system administrators and professional advisors, regulators, government or law enforcement officials (where required) and other relevant authorities (where required). 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.

    SOSV will not sell, rent, release, disclose, disseminate, make available transfer or otherwise communicate in any manner your Personal Data to any third party in exchange for monetary or other valuable consideration.

    SOSV may sell, transfer, or otherwise share some or all of our business or assets, which may include your Personal Data, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, asset sale or bankruptcy. In any such circumstances, best efforts will be made to require the recipient to adhere to this Privacy Statement.

  1. Security Of Your Data
  2. SOSV uses industry standard security measures to prevent the loss, misuse or alteration of your Personal Data within our control, including organizational, technical and physical measures. 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.

  1. Data Retention
  2. 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 Data, we consider the amount, nature, and sensitivity of the 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.

    In certain circumstances, we may anonymize your Personal Data. In such circumstances we may use such anonymized data indefinitely without further notice to you.

  1. International Transfers
  2. 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 Affiliates, our affiliated entities or other third parties located outside the EEA. In such cases we will ensure that the transfer is legal and your Personal Data is secure by following the EU’s guidelines.

  1. Your Rights
  2. 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.

    You may opt out of any SOSV newsletter or related emails by following the unsubscribe instructions on such emails, or by contacting us directly at compliance@sosv.com.

  1. Contact Us
  2. 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: 05 June 2019