The Data Protection Laws (as defined below) require that data controllers provide certain information to persons whose information (personal data) they hold and use.
We are committed to protecting your personal information and ensuring we respect your privacy. This privacy notice (the “Privacy Notice”) explains how we will look after and use any personal information that we collect about you.
This Privacy Notice was last updated on 22 August 2024.
Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.
Dawn Capital LLP is the controller of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact us using the details set out below.
Full name of legal entity: Dawn Capital LLP
Email address: hello@dawncapital.com
Postal address: Ilona Rose House, Manette Street, London, W1D 4AL, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
We collect information in the course of providing our financial services to you. The information which we collect, use, store and transfer about you are:
Where we need to collect your personal information by law, or under the terms of a contract we have with you or where we have collected personal information with a view to enter into a contract, and you fail to provide that information when requested, we may not be able to provide the goods or services you asked for. In this case we may have to cancel the relevant product or services, but we will tell you if this is the case.
Typically, we will collect information from you when you contact us directly or provide information in order for us to provide our products and services. We collect information from and about you in the following ways primarily through direct interactions when you give us your personal information by filling in forms or during correspondence with us. This includes when you subscribe to our funds or meet with us in person, talk to us face to face, communicate with us electronically or use our website.
We may also receive information about you from third parties, including from portfolio companies or persons in our network, or may obtain information about you from social media platforms such as LinkedIn.
We only obtain, use and keep personal information where we need it for a specific purpose. We set out in the table below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected. Most commonly we will use your information in the following ways:
We set out below all the ways we plan to use your personal information and the legal basis we rely on to do so. We also explain what our legitimate interests are where appropriate:
| Purpose / Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
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| To provide our services and perform our contractual duties and obligations with respect to our investors, founders, management companies and suppliers |
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| To facilitate investments into our funds and co-investment opportunities and comply with our obligations as manager as set out in the constitutional documents of our funds/vehicles |
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| To facilitate investments into companies and otherwise conduct the business of a venture capital fund manager |
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| To provide advice and assistance to help our portfolio companies grow |
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| To facilitate candidate introductions to existing and prospective portfolio companies |
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| To manage our relationships (including communicating with our investors, founders, management companies and suppliers) |
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| To send out promotional communications. If you would like to unsubscribe from these, please click the unsubscribe button in the relevant communications, or contact us at hello@dawncapital.com |
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| Events management, including allergy and accessibility information |
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| Social outreach, including facilitating public communications |
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| Research and analytics |
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| To acquire and exit investments |
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| To purchase services from our suppliers |
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| To comply with our know your client and customer due diligence obligations |
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| To comply with legal, regulatory, tax, reporting, filing, anti-trust, anti-bribery, anti-money laundering, anti-terrorist financing and other obligations |
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| To establish, exercise or defend our legal rights for the purposes of proceedings or dispute resolutions in connection with our management and administration of our investments and/or the conduct of our business |
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| We process the personal data of a wide variety of business contacts for the purposes of conducting key parts of venture capital business, such as fundraising, generating deal flow, and recruiting management teams |
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| To use data analytics to improve our website or any other platforms we may use in our communications |
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We will only use your personal information for the reason for which we collected it. We will only use it for another reason if we believe that new reason is compatible with the original purpose. If we do need to use your personal information for a non-related purpose, we will tell you about it and explain the legal basis which allows us to do so.
The website uses cookies and similar technologies to distinguish you from other users.
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. However, you may not be able to take full advantage of our website if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser. Others are used to remember you when you return to the website and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use. The cookie table below sets out the cookies we use.
The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.
If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
| Cookie Type: Necessary | ||
|---|---|---|
| Name | Purpose | More Information |
| __cf_bm | Unclassified | Provider: vimeo.com Type: HTTP Expiry: 1 day First found URL: https://dawncapital.com/members/norman-fiore/ Initiator: Script tag Source: Data is sent to: Unknown (not adequate) |
| _cfuvid | This cookie is a part of the services provided by Cloudflare – including load-balancing, deliverance of website¬ content and serving DNS connection for website operators. | Provider: medium.com Type: HTTP Expiry: Session First found in URL:https://dawncapital.com/finances-on-autopilot-how-do-we-get-there/ Initiator: Script tag Source: Data is sent to: Unknown (not adequate) |
| _cfuvid | Unclassified | Provider: vimeo.com Type: HTTP Expiry: Session First found URL: https://dawncapital.com/members/norman-fiore/ Initiator: Script tag Source: Data is sent to: Unknown (not adequate) |
| CookieConsent | Stores the user’s cookie consent state for the current domain. | Provider: dawncapital.com Type: HTTP Expiry: 1 year First found URL: https://dawncapital.com/ Initiator: Script tag Source: Data is sent to: Germany (adequate – adequate country under GDPR (EU)) |
| docs/common/netcheck.gif | Necessary for the general functionality of the website. | Provider: gstatic.com Type: Pixel Expiry: Session First found URL: https://dawncapital.com/dawn-agm-2024-presentation/ Initiator: Script tag – page source line number 261 Source: https://docs.google.com/presentation/d/e/2PACX-1vQLXLLOUCu62Tqo6_lJtU0YvUcr7_5NpPWKOHSQSf9ADiQcQrUnvgmar648UqUYoN-o9J-z2B5dinCr/embed?start=falseloop=falsedelayms=3000 Data is sent to: United States (adequate – adequate country under GDPR (EU)) |
| sc_anonymous_id | Used in context with the 3D-view-function on the website. | Provider: soundcloud.com Type: HTTP Expiry: 10 years First found URL: https://dawncapital.com/finances-on-autopilot-how-do-we-get-there/ Initiator: Script tag – page source line number 277 Source: https://w/soundcloud.com/player/?visual=trueurl=https%3A%2F%2Fapi.soundcloud.com%2Ftracks%2F973898755show_artwork=truemaxheight=1000maxwidth=1920 via https://widget.snd cdn.com/widget-9-464eca95d46d.jsData is sent to: United States (adequate – adequate country under GDPR (EU)) |
| wpEmojiSettingsSupports | This cookie is part of a bundle of cookies which serve the purpose of content delivery and presentation. The cookies keep the correct state of font, colour themes and other website settings. | Provider: dawncapital.com Type: HTML Expiry: Session First found URL: https://dawncapital.com/ Initiator: Page source line number 32 Source: Inline script Data is sent to: Germany (adequate – adequate country under GDPR (EU)) |
| Cookie Type: Analytical/Statistics/Performance | ||
| Name | Purpose | More Information |
| number(#) | Unclassified | Provider: widget.sndcdn.com Type: HTML Expiry: Session First found URL: https://dawncapital.com/finances-on-autopilot-how-do-we-get-there/ Initiator: Script tag – page source line number 277 Source: https://w/soundcloud.com/player/?visual=trueurl=https%3A%2F%2Fapi.soundcloud.com%2Ftracks%2F973898755show_artwork=truemaxheight=1000maxwidth=1920 Data is sent to: United States (adequate – adequate country under GDPR (EU)) Blocked until accepted by user: No |
| vuid | Collects data on the user’s visits to the website, such as which pages have been read. | Provider: vimeo.com Type: HTTP Expiry: 2 years First found URL: https://dawncapital.com/members/norman-fiore/ Initiator: Script tag – page source line number 615 Source: https://player/vimeo/com/video/883234130?h=ff2bfde86cbadge=0autopause=0player_id=0app_id=58479 viahttps://f.vimeocdn.com/js_opt/modules/utils/vuid.min.js Data is sent to: United Kingdom (adequate – adequate country under GDPR (EU)) Blocked until accepted by user: No |
| Cookie Type: Functionality and Marketing | ||
| Name | Purpose | More Information |
| _ga | Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels. | Provider: dawncapital.com Type: HTTP Expiry: 2 years First found URL: https://dawncapital.com Initiator: Script tag – page source line number 85 Source: https://www.googletagmanager.com/gtag/js?id=G-SD2P4HJKE2 Data is sent to: United States (adequate – adequate country under GDPR (EU)) Blocked until accepted by user: No |
| _ga_# | Used to send data to Google Analytics about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels. | Provider: dawncapital.com Type: HTTP Expiry: 2 years First found URL: https://dawncapital.com Initiator: Script tag – page source line number 85 Source: https://www.googletagmanager.com/gtag/js?id=G-SD2P4HJKE2 Data is sent to: United States (adequate – adequate country under GDPR (EU)) Blocked until accepted by user: No |
| GFE_RTT | Used to implement the content through Google Docs. | Provider: docs.google.comType: HTTP Expiry: 1 day First found URL: https://dawncapital.com/dawn-agm-2024-presentation/ Initiator: Script tag – page source line number 261 Source: https://docs.google.com/presentation/d/e/2PACX-1vQLXLLOUCu62Tqo6_lJtU0YvUcr7_5NpPWKOHSQSf9ADiQcQrUnvgmar648UqUYoN-o9J-z2B5dinCr/embed?start=falseloop=falsedelayms=3000 Data is sent to: United States (adequate – adequate country under GDPR (EU)) |
| NID | Unclassified | Provider: google.com Type: HTTP Expiry: 6 months First found URL: https://dawncapital.com/dawn-agm-2024-presentation/ Initiator: Script tag Source: Data is sent to: United States (adequate – adequate country under GDPR (EU)) |
| punchv-e-f | Used to implement the content through Google Docs. | Provider: docs.google.com Type: HTML Expiry: Persistent First found URL: https://dawncapital.com/dawn-agm-2024-presentation/ Initiator: Script tag – page source number 261 Source: https://docs.google.com/presentation/d/e/2PACX-1vQLXLLOUCu62Tqo6_lJtU0YvUcr7_5NpPWKOHSQSf9ADiQcQrUnvgmar648UqUYoN-o9J-z2B5dinCr/embed?start=falseloop=falsedelayms=3000 Data is sent to: United States (adequate – adequate country under GDPR (EU)) |
| punchv-e-n | Used to implement the content through Google Docs. | Provider: docs.google.com Type: HTML Expiry: Persistent First found URL: https://dawncapital.com/dawn-agm-2024-presentation/ Initiator: Script tag – page source number 261 Source: https://docs.google.com/presentation/d/e/2PACX-1vQLXLLOUCu62Tqo6_lJtU0YvUcr7_5NpPWKOHSQSf9ADiQcQrUnvgmar648UqUYoN-o9J-z2B5dinCr/embed?start=falseloop=falsedelayms=3000 Data is sent to: United States (adequate – adequate country under GDPR (EU)) |
| punch-e-v | Used to implement the content through Google Docs. | Provider: docs.google.com Type: HTML Expiry: Persistent First found URL: https://dawncapital.com/dawn-agm-2024-presentation/ Initiator: Script tag – page source number 261 Source: https://docs.google.com/presentation/d/e/2PACX-1vQLXLLOUCu62Tqo6_lJtU0YvUcr7_5NpPWKOHSQSf9ADiQcQrUnvgmar648UqUYoN-o9J-z2B5dinCr/embed?start=falseloop=falsedelayms=3000 Data is sent to: United States (adequate – adequate country under GDPR (EU)) |
| WIDGET::local::assignments | Used by audio-platform SoundCloud to implement, measure and improve their embedded content/service on the website – the collection of data also includes visitors’ interactions with embedded content/service. This can be used for statistics or marketing purposes. | Provider: widget.sndcdn.com Type: HTML Expiry: Persistent First found URL: https://dawncapital.com/finances-on-autopilot-how-do-we-get-there/ Initiator: Script tag – page source line number 277 Source: https://w/soundcloud.com/player/?visual=trueurl=https%3A%2F%2Fapi.soundcloud.com%2Ftracks%2F973898755show_artwork=truemaxheight=1000maxwidth=1920 Data is sent to: United States (adequate – adequate country under GDPR (EU)) Blocked until accepted by user: No |
We may need to provide information to third parties for a variety of reasons, for example, to assist in the detection or prevention of crime or for the purpose of safeguarding national security or where we are otherwise legally obligated or entitled to share your information. Please refer to the table above in the section ‘Purpose and lawful basis for processing of personal data’ which explains how we use your data.
The third parties we share your information with are as follows:
Some of the recipients of your information (as set out under the "Who we share your information with" section above) are outside of the UK and the European Economic Area (EEA). However, we will only transfer your information outside the UK/EEA where the following safeguards have been put in place:
As a financial services provider we will typically have a contract with you and will need to keep your personal information (updated to ensure accuracy) to fulfil our contract. As a minimum, we will retain your personal information for the term of your investment plus any time necessary to exercise any options or defend your rights of claims (which is typically 7 years including in respect of tax claims). We also need to comply with EU and UK law, which often requires us to keep certain records - which will include certain personal information.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained.
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
You are provided with a number of different rights under the Data Protection Laws (as defined below) in relation to your personal information. These apply in certain circumstances and allow you to:
If you wish to exercise any of these rights, please email us at hello@dawncapital.com. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.
This Privacy Notice is in effect as of the date noted at the top of the notice. We may change this Privacy Notice from time to time. If we do, we will post the revised version here and change the date it applies from at the top of the notice and/or contact you directly where we deem appropriate to do so under applicable law. You should check here regularly for the most up-to-date version of the statement.
Data Protection Laws means (i) the Data Protection Act 2018 (as amended from time to time) (the “DPA 2018”), (ii) Regulation (EU) 2016/679 of the European Parliament and of the Council, as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of the DPA 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 and (iii) other laws and regulations relating to the protection of personal data in other jurisdictions to which Dawn Capital LLP is subject, each as amended, consolidated or replaced from time to time.
