Legal

Our Privacy Policy & Terms of Use

Terms of Use

 

About Us: This website is provided by Connect Ventures LLP, a limited liability partnership under the laws of England & Wales with registered number OC367566 (“we”, “our”, “us”). We are authorised and regulated by the Financial Conduct Authority and our registered office is at 4th Floor, 89 Great Eastern Street, London EC2A 3HX.

Acceptance of Terms: By continuing to use this website, you acknowledge that you have read, understood and accepted all of the notices on this page.

Changes to Terms: We may make changes to these notices from time to time. Please check back here every so often to make sure you’re aware of any changes. If at any time you don’t accept any of these terms, please stop using this website.

Website Content: All of the content on this website is provided free of charge, and you do not need to register in order to use it. We may make changes to the website and its content from time to time. We make no guarantee that any of the content will continue to be available, or that the website will operate uninterrupted or be error-free.

Third Party Services: Our website may embed or provide links to third party services. We are not responsible for those third party services, or the content of those third party services. If you choose to access or use those third party services from our website, you should check the terms of use of those third party services before doing so.

No Investment Advice: The content on our website is provided for general information only, and does not constitute investment advice, or any other advice on which you should rely. None of the information on our website constitutes any offer, invitation or solicitation of investment. References to our investments and/or portfolio companies are to companies in which we, or any of our affiliated entities, partners or employees have, either now or in the past, held an interest. We are not promoting or recommending these companies for investment, and make no guarantee that any information regarding these companies, or any other information on our website, is complete, accurate or up-to-date.

Intellectual Property: As between you and us, all intellectual property rights in the content of our website belongs to us. You may access and use this content for the purposes described in these terms, but you may not otherwise reproduce, amend, distribute or make available any of the content of our website for any purpose without our prior approval.

Accessibility: The website is not directed at or intended for use by anyone in any country where such access or use would be contrary to law or regulation, or where the making available of this website or the content of this website would be contrary to law or would subject us to any form of additional regulation.

Limitation of Liability: Except with respect to any liability that cannot be excluded by law, including liability for personal injury or death resulting from our negligence, or our fraud or fraudulent misrepresentation, we will not be liable for any loss or damage that you suffer as the result of your use of our website, or your reliance on any content or information on our website. All warranties that would otherwise be implied by law are excluded to fullest extent permitted by law.

Unsolicited Pitches: Please do not send any proposals or requests for investment via our website. Proposals submitted in this way will not be considered.

Governing Law: These terms are subject to the laws of England & Wales and any disputes will be settled by the English courts.

Privacy Policy

 

LAST UPDATED: January, 2023

 

Connect Ventures is committed to protecting your personal data and we want you to be familiar with how we collect, process, use and disclose it. This notice (the “Privacy Policy”) describes our practices in connection with any personal data we collect from you, or that you provide to us.

By visiting www.connectventures.co or making use of any of the services listed in the “Our Services” section below, you are accepting and consenting to this Privacy Policy.

 

1. IMPORTANT INFORMATION

2. OUR SERVICES

3. HOW WE PROCESS AND USE YOUR DATA

4. HOW IS YOUR PERSONAL DATA COLLECTED?

5. DISCLOSURES OF YOUR PERSONAL DATA

6. DATA SECURITY

7. DATA RETENTION

8. COOKIE POLICY

9. OUR LEGAL RIGHTS

10. CONTACT DETAILS

1. Important information

 

Controller

Connect Ventures LLP is a limited liability partnership incorporated in England and Wales with registered number OC367566 as authorised and regulated by the Financial Conduct Authority (“Connect Ventures”). As the controller of your personal data, Connect Ventures is therefore responsible for any collection, processing, use and disclosure that may be carried out in relation to your personal data.

References to the terms “we”, “us” and “our” in this Privacy Policy are to Connect Ventures.

Purpose of this Privacy Policy

It is important that you read this Privacy Policy together with any other privacy policy update or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you.

Updates to this privacy policy

This Privacy Policy may be updated from time to time. The “Last Updated” section at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes that we make to this Privacy Policy will be effective from the date specified at the top of the revised privacy policy. Your use of our services following any such changes indicates that you have accepted them.

Duty to inform us of changes

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

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. Our services

 

Connect Ventures is a European micro-VC fund manager and we invest in internet and software startups at the seed stage. Please refer to our website for more information. In order to provide our services, we may collect personal data through a number of sources. Please see the ‘How is your personal data collected’ section for more information.

Where we need to collect personal data by law, or under the terms of a contract we have (or are negotiating) with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of the services you have with us, but we will notify you if this is the case at the time.

3. How we process and use your data

 

“Personal data” is information that identifies you as an individual or relates to an identifiable individual.

We will only use your personal data when the law allows us to and we will not sell, trade or otherwise deal with your personal data in any way that contravenes this Privacy Policy (as may be updated from time to time).

We have set out below a description of the ways we plan to use your personal data, and on which legal basis we do so. Where we rely on our legitimate interests as a legal basis for processing, we have identified the nature of those legitimate interests.

General

Purpose / activity

To perform:

– identity verification;

– investor / investment communications;

– ongoing investment management;

– the completion of fund related documentation e.g. limited partnership agreement, subscription agreements, management arrangement agreements, investment agreements, regulatory filings, amongst others; and

– cash distributions and payments.

Providing our services and fulfilling your requests, including the following:

– to respond to your enquiries and fulfill your requests, when you contact us for example, when you send us questions, suggestions, compliments or complaints;

– to provide services to you;

– to complete your transactions, and provide you with related client service;

– to send administrative information to you, such as changes to our terms, investment agreements, conditions and policies;

– maintaining a record of contacts; and

– organising meetings with you.

Type of personal data

– Name

– Residential address

– Date of birth

– Tax ID / national insurance number

– Passport or similar documented identification

– Nationality

– Email address

– Telephone / mobile number(s)

– Bank account details

Basis for use and processing

– Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)

– To allow the performance of our contract with you

– To comply with legal, tax and compliance obligations (e.g. under anti-money laundering regulations)

(b) Existing Investors

 

Please note that for investors in any fund managed by Connect Ventures or its affiliates, this may include personal data obtained from professional advisers, including administrators, investment managers, custodians and legal service providers.

Please note, Connect Ventures may also enlist the assistance of third parties to undertake due diligence on individuals, investors (including any persons connected to such entities).

Purpose / activity

To perform:

– identity verification;

– investor / investment communications;

– ongoing investment management;

– the completion of fund related documentation e.g. limited partnership agreement, subscription agreements, management arrangement agreements, investment agreements, regulatory filings, amongst others; and

– cash distributions and payments.

Providing our services and fulfilling your requests, including the following:

– to respond to your enquiries and fulfill your requests, when you contact us for example, when you send us questions, suggestions, compliments or complaints;

– to provide services to you;

– to complete your transactions, and provide you with related client service;

– to send administrative information to you, such as changes to our terms, investment agreements, conditions and policies;

– maintaining a record of contacts; and

– organising meetings with you.

Type of personal data

– Name

– Residential address

– Date of birth

– Tax ID / national insurance number

– Passport or similar documented identification

– Nationality

– Email address

– Telephone / mobile number(s)

– Bank account details

Basis for use and processing

– Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)

– To allow the performance of our contract with you

– To comply with legal, tax and compliance obligations (e.g. under anti-money laundering regulations)

(c) Potential Investors

 

Please note, Connect Ventures may also enlist the assistance of third parties to undertake due diligence on individuals, investors (including any persons connected to such entities) and co-investors.

Purpose / activity

To perform:

– identity verification;

– to respond to your enquiries and fulfill your requests;

– investor registration;

– maintaining a record of contacts; and

– organising meetings with you.

Type of personal data

– Name

– Residential address

– Email address

– Telephone / mobile number(s)

Basis for use and processing

– Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)

– To perform the contract we are about to enter into or have entered into with you

– To comply with legal, tax and compliance obligations

(d) Existing portfolio companies

Purpose / activity

To perform:

– founder, director and shareholder identity verification;

– due diligence checks;

– ongoing investment management;

– investor / investment communications;

– maintaining a record of contacts; and

– organising meetings with you.

Type of personal data

– Founder, director and shareholder names

– Founder, director and shareholder addresses

– Founder, director and shareholder email addresses

– Founder and director nationalities

– Residential address

– Date of birth

– Job title / positon of responsibility

– Curriculum vitaes (CVs)

– Employment history

– Your financial status

Basis for use and processing

– Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)

– To allow the performance of contractual relations with you

– To comply with legal, tax and compliance obligations

– Party consent

(e) Potential portfolio companies

 

Any personal data received as a result of unsolicited proposals or requests for investment will be treated in accordance with this Privacy Policy (as may be updated from time to time).

Purpose / activity

– Consideration and analysis of company / management presentations or proposals and evaluating your role within it;

– Carrying out due diligence checks for investment decision purposes;

– Preparing investor / investment communications;

– Executing transactions;

– Seeking and receiving advice from our professional advisors, including accountant’s lawyers and other consultants;

– Maintaining a record of contacts; and

– Organising meetings with you.

Type of personal data

– Names

– Email addresses

– Telephone / mobile numbers

– Job title / position of responsibility

– Nationality

– Employment history

– Your financial status

– Curriculum vitaes (CVs)

Basis for use and processing

– Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)

– To comply with legal, tax and compliance obligations

– Party consent

(f) Other

Purpose / activity

– Contacting suppliers and completing transactions with suppliers

– Investor communications via the Connect Founder Network and monthly newsletter

Type of personal data

– Name

– Email addresses

– Telephone / mobile numbers

– Job title / position of responsibility

– Social media profile(s)

– Bank account details

– Name

– Email addresses

– Name of affiliated company

– Job title / position of responsibility

Basis for use and processing

– Necessary for our legitimate interests (for providing our services, running our business, administrative purposes and making or advising on investment decisions)

– Party consent

– To perform the contract we are about to enter into or have entered into with you

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to us.

4. How is your personal data collected?

 

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

– request for our products or services;

– request marketing to be sent to you;

– give us some feedback;

– use of our website (connectventures.co); or

– use of our social media pages including Twitter (https://twitter.com/connect_v?lang=en) and Crunchbase (https://www.crunchbase.com/organization/connect-ventures).

Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. This information does not reveal your specific identity. We collect this personal data by using server logs and other similar technologies. Connect Ventures does not make use of cookies however, you may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for further information about cookies and how they may be used by third-party websites.

Third parties or publicly available sources. We may receive personal data about you from various third parties.

Identity data from data brokers or aggregators.

Public sources. Identity data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details provided in the “Contact” section.

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

5. Disclosures of your personal data

 

Connect Ventures will only disclose personal data in accordance with this Privacy Policy (as may be updated from time to time).

We may disclose personal data to third party service providers (including service providers, IT system administration services, professional advisers, providers of finance, HM Revenue & Customs, regulators and other authorities) to facilitate services they provide to us. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In such circumstances, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Connect is based in the European Economic Area (“EEA”). If we transfer personal data to our group or affiliate entities or to third parties outside of the EEA, we will ensure your personal data is protected, for example by ensuring one or more of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Standard contractual clauses approved by the European Commission are in place with the transferee.

Where we transfer personal data to service providers or affiliates based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us using the contact details provided in the “Contact Details” section if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

 

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

We have put in place reasonable procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We cannot guarantee the security of any personal data that you disclose online, for example when it is sent by email. You accept the inherent security risks of providing information online over the Internet and will not hold Connect Ventures responsible for any breach of security unless this is due to Connect Venture’s negligence or willful default.

7. Data retention

 

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, contractual, 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 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.

You can request details of retention periods for specific categories of your personal data by contacting us using the details provided in the “details provided in the “Contact” section” section.

8. Cookie Policy

 

By using our website with your browser settings adjusted to accept cookies you consent to our use of cookies and other tools to provide the products and services available on those sites. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to Managing Cookies below.

Cookies and how we use them
Cookies are small text files that may be placed on your web browser when you visit our websites or when you view advertisements we have placed on other websites. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. We do not use cookies to store any personal information that could be read or understood by others. When you quit your browser, some cookies are stored in your computer’s memory, while some expire or disappear.
Cookies are used primarily for administrative purposes, to improve your experience with our websites. Examples of this would include the use of cookies:
In addition to administrative uses, we may also use cookies in one or more of the following ways, depending on the website you are using:
To conduct research and analytics using Google Analytics (_ga) to improve our website and our products and services. This includes compiling statistical information based on visits to our site concerning, among other things, the frequency of your use of our website, the pages visited and the length of each visit.

Managing Cookies
The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer. Some of our sites employ “functionality cookies” that help the site remember your settings and preferences for use when you visit the site in the future. This provides a more tailored and pleasant user experience. These cookies store information in multiple places. On those site using functionality cookies, you will find a “Delete Cookies” feature on every page that will allow you to delete these cookies completely from your device. Please note that, if you decline to use cookies, you may experience reduced functionality and, for sites using authentication-related cookies, declining cookies will prevent you from using the website altogether. To learn more about what cookies are set on your computer as you browse the web and how to manage or delete them, visit www.allaboutcookies.org.

9. Your legal rights

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights include your right to:

– request access to your personal data;

– request correction of your personal data;

– request erasure of your personal data;

– object to processing of your personal data;

– request restriction of processing your personal data;

– request transfer of your personal data; and

– right to withdraw consent;

If you wish to exercise any of the rights set out above, please contact us using the details provided in the “Contact” section.

 

Complaints

If you have a complaint regarding any aspect of your personal data or this privacy policy, please contact us using the details provided in the “Contact Details” section.

You have the right to lodge a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so we would encourage you to contact us in the first instance.

 

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact Details

 

We may be contacted at:

Connect Ventures LLP, 27 Furnival St, London, England, EC4A 1JQ

[email protected]

PLEASE NOTE: Connect Ventures uses [email protected] solely for privacy related matters. All unrelated matters sent to this email address (e.g. unsolicited requests for funding) will not be considered or responded to.