What is the purpose of this document?

Kindred Capital LLP is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (the GDPR).

It applies to all investors and potential investors.

Kindred Capital LLP is a ‘data controller’. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to the employees (including directors and, in the case of partnerships, partners) of businesses in which we (may) invest. This notice does not form part of any contract. We may update this notice at any time but, if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. used lawfully, fairly and in a transparent way;

2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

3. relevant to the purposes we have told you about and limited only to those purposes;

4. accurate and kept up to date;

5. kept only as long as necessary for the purposes we have told you about;

6. kept securely.

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health, sexual orientation or criminal convictions.

We may collect, store and use the following categories of personal information about you:

• personal contact details, such as name, gender, title, address(es), telephone number(s) and personal email address(es);

• passport information;

• business bank account details;

• correspondence between us;

• pitch information (including investment decks, references and other information included in a CV or cover/application letter or as part of the pitch process).

How is your personal information collected?

We collect all personal information about you directly from:

• you or your employer; or

• a third party who has introduced you to us

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. where we need to comply with a legal obligation;

2. where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

1. where we need to protect your interests (or someone else’s interests).

2. where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with our investee and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated the purposes for which we are processing or will process your personal information, as well as indicating which data are involved. Where a legitimate interest is involved, we state what the legitimate interest is.

Please note that we have divided the list below to describe how we will process the personal information of: (a) employees of potential investees; and (b) employees of actual investees.

Founders of Potential Investees

Employees of Investees

Some of the above grounds for processing will overlap and, as indicated, there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to enter into (or perform a contract we have entered into) with your employer or we may be prevented from complying with our legal obligations.

Change of purpose

We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent (in compliance with the above rules) where this is required or permitted by law.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

1. where we have notified you of the decision and given you 21 days to request a reconsideration;

2. where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights;

3. in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest and we must also put in place appropriate measures to safeguard your rights.

We do not envisage that any decisions will be taken about you using automated means. However, we will notify you in writing if this position changes.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision making unless we have a lawful basis for doing so and we have notified you.

Data sharing

We may have to share your data with third parties, including third-party service providers.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EEA. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties where: 

• required by law; 

• it is necessary to administer the working relationship with you; or

• we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

‘Third parties’ includes third-party service providers (including contractors and designated agents). The following third-party service providers process personal information about you for the following purposes:

• Google LLC (Google) who we use for cloud storage (‘Google Drive’) and email services (‘Gmail’);

• F Stack Limited (trading as ‘Fundstack’) who we use for customer relationship management software services;

• Typeform SL (trading as ‘Typeform’) who we use for customer relationship management software services;

• Slack Technologies, Inc. (Slack) who provides internal communication tools;

• Marriott Harrison LLP who provide legal services to us (for example, preparing contracts in relation to our investment);

• Vistra Fund Services S.A R.L (Vistra) who provide fund administration services (for example, anti-money laundering and ‘know your client’ checks);

• Rees Pollock who are our auditors.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

What about other third parties?

We may share your personal information with other third parties (for example, in the context of the possible sale or restructuring of the business). In this situation we will (so far as possible) share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulatory or other governmental body or to otherwise comply with the law.

Transferring information outside the EEA

We will transfer the personal information we collect about you to the USA when we transfer your personal information to Google and/or Slack. Google and Slack are Privacy Shield-certified which means that the European Commission has decided that those businesses which are certified provide an adequate level of protection for your personal information.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a need to know for our business. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the CFO.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for (including for the purposes of satisfying any legal, accounting, or reporting requirements). Details of retention periods for different aspects of your personal information are set out in our retention policy (attached to this notice as Schedule 1). 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 unauthorised 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.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you (in which case we may use such information without further notice to you). Once our contract with you ends (or we decide that we will not be entering into a contract), we will retain and securely destroy your personal information in accordance with our data retention policy.

Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law, you have the right to:

• request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;

• request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

• request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);

• object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;

• request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you (for example, if you want us to establish its accuracy or the reason for processing it);

• request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact the CFO in writing.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the CFO. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to (unless we have another legitimate basis for doing so in law).

Changes to this privacy notice

We reserve the right to update this privacy notice at any time and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact us on (security@kindredcapital.vc) to (ir@kindredcapital.vc)

Retention Policy

Founders of Potential Investees

Employees of Potential Investees