Privacy policy



Data protection privacy notice


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.


What is personal information


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.


Who we are


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.


What types of information do we use


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:


  • full name and title;
  • address and previous address;
  • contact information including: email, telephone number, fax number and date of birth;
  • proof of identity and documentary data (this can include passport or drivers’ licence or other forms of identification);
  • nationality;
  • national insurance number;
  • tax information such as tax district, tax reference (UTR);
  • if you are a company founder or an investor, your bank account details, credit checks and other financial details;
  • employment details (job title, company name, address etc.);
  • employment or work history/background;
  • educational history;
  • references and professional profile;
  • your use of our website including user meta data, cookies and analytics;
  • your image (in photograph or video) if you attend an event;
  • dietary/allergy information; and/or
  • information about you that is already in the public domain or that you disclose to us.

Consequences of not providing some types of information


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.


How do we collect information about you


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.


How we will use your personal information


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 have or are negotiating a contract with you. For example, we manage a fund for which you are an investor in accordance with the constitutional documents of the fund, or you are a founder or senior executive of a company we are looking to invest in (or have invested in);
  • we have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example, this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information, so you understand the risk of the financial services we provide; or
  • we, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to source investments.

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 and lawful basis for processing of personal data


Purpose / ActivityType of dataLawful basis for processing including basis of legitimate interest
To provide our services and perform our contractual duties and obligations with respect to our investors, founders, management companies and suppliers
  • Financial
  • Transaction
  • Contact
  • Identity
  • Contract
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
  • Financial
  • Transaction
  • Contact
  • Identity
  • Contract
  • Necessary for our legitimate interests (ensuring compliance with our obligations as manager)
To facilitate investments into companies and otherwise conduct the business of a venture capital fund manager
  • Financial
  • Transaction
  • Contact
  • Identity
  • Contract
  • Necessary for our legitimate interests (to enable us to successful conduct the business of a venture capital manager)
To provide advice and assistance to help our portfolio companies grow
  • Contact
  • Identity
  • Usage
  • Necessary for our legitimate interests (to enable our portfolio companies to grow)
To facilitate candidate introductions to existing and prospective portfolio companies
  • Contact
  • Identity
  • Consent
To manage our relationships (including communicating with our investors, founders, management companies and suppliers)
  • Identity
  • Contact
  • Profile
  • Marketing and Communications
  • Necessary for our legitimate interests (to manage our relationships)
  • Consent (where required by law)
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
  • Identity
  • Contact
  • Profile
  • Marketing and Communications
  • Necessary for our legitimate interests (to manage our relationships)
  • Consent (where required by law)
Events management, including allergy and accessibility information
  • Identity
  • Contact
  • Health (e.g. dietary and allergy information)
  • Necessary for our legitimate interests (to provide safe and productive events and grow our business)
  • Consent (where required by law)
Social outreach, including facilitating public communications
  • Identity
  • Contact
  • Profile
  • Marketing and Communications
  • Necessary for our legitimate interests (to enable our business to grow)
Research and analytics
  • Technical
  • Usage
  • Profile
  • Necessary for our legitimate interests (in analysing and improving our services)
To acquire and exit investments
  • Identity
  • Contact
  • Financial
  • Transaction
  • Marketing and Communications
  • Necessary for our legitimate interests (to manage our funds effectively for the benefit of our investors)
  • Contract
To purchase services from our suppliers
  • Usage
  • Profile
  • Technical
  • Contract
To comply with our know your client and customer due diligence obligations
  • Financial
  • Technical
  • Legal obligation
  • Contract
To comply with legal, regulatory, tax, reporting, filing, anti-trust, anti-bribery, anti-money laundering, anti-terrorist financing and other obligations
  • Financial
  • Technical
  • Legal obligation
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
  • Legal obligation
  • Legitimate interests
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
  • Financial
  • Transaction
  • Contact
  • Identity
  • Necessary for our legitimate interests (ensuring compliance with our obligations as manager and operating a successful business)
To use data analytics to improve our website or any other platforms we may use in our communications
  • Technical Information
  • Consent where required by law
  • Necessary for our legitimate interests (for example, in understanding your use of our website and using data analytics to improve this)

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.


Cookies and other technologies


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.


We use the following types of cookies:

  • strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. These include, for example, basic functions like page navigation and access to secure areas of our website;
  • analytical/statistics/performance cookies. These cookies are anonymous and allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our website works, for example, by ensuring that users are finding what they are looking for easily; and
  • functionality and marketing cookies. The functionality cookies are used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region). The intention behind marketing cookies is to display ads that are relevant and engaging for you.

Disabling cookies

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 table
Cookie Type: Necessary
NamePurposeMore Information
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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)
_cfuvidThis 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)
_cfuvidUnclassifiedProvider: 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)
CookieConsentStores 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.gifNecessary 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_idUsed 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))
wpEmojiSettingsSupportsThis 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
NamePurposeMore Information
number(#)UnclassifiedProvider: 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
vuidCollects 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:
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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
NamePurposeMore Information
_gaUsed 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_RTTUsed 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))
NIDUnclassifiedProvider: 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-fUsed 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-nUsed 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-vUsed 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::assignmentsUsed 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

How we will use your personal information


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:


  • if you are an investor, the funds you are invested in;
  • our service providers such fund administrators and depositaries, compliance consultants, technology suppliers (hosting and communication distribution), events management providers and partners, analytics providers and professional advisers, including lawyers, accountants and financial advisors;
  • counterparties to a transaction, including but not limited to disclosure in the context of a change in business control, sale or merger; or
  • if you are a founder or investor, credit reference agencies for the purpose of assessing your credit score.

Sending your information outside of the UK/EEA


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:


  • the country we send your information to is deemed to provide an adequate level of protection by the UK government or the European Commission; or
  • the information is being transferred between organisations which are engaged in the same economic enterprise, or within our corporate group, and we have an agreement in place which contains standard contractual clauses; and
  • you can obtain further information on the specific mechanism used by us when transferring your personal information outside of the UK and EEA by contacting us.

Retention of personal data and storing your information


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.


Your rights

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:


  • access your information;
  • request we correct your information;
  • request that we erase your information;
  • object to the processing of your information;
  • request a restriction in the processing of your information;
  • request that your provided personal data be moved to a third party;
  • object to the further processing of your personal data, including the right to object to marketing;
  • complain to the UK data protection regulator, the ICO; and
  • where the processing of your personal information by us is based on consent, you have the right to withdraw your consent.

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.


Changes to our Privacy Notice


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


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.


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