Privacy policy

Data protection privacy notice

The Data Protection Laws (as defined below) require that data controllers provide certain information to people 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 explains how we will look after and use any personal information that we collect about you.

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

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.
• National insurance number.
• Tax information such as tax district, tax reference (UTR).
• Nationality.
• Bank account details.
• Proof of identity.
• Employment details (job title, company name, address etc.).
• Educational history.
• Employment or work history/background.
• Documentary data (this can include passport or drivers’ licence or other forms of identification).

We do not collect any special categories of personal data. This includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data.

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, 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 or communicate with us electronically.

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 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.
• 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 can provide.
• 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 deals.

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

• To facilitate investment into our funds and co-investment opportunities and comply with our obligations as manager as set out in the constitutional documents of the funds.
• To facilitate investment into portfolio companies and provide advice and assistance to help our portfolio companies grow.
• To acquire and exit investments.
• To purchase services from our suppliers.
• To comply with our KYC and customer due diligence obligations.
• 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.

Lawful basis for processing including our legitimate interests

We are entitled to use your personal data in the ways set out in this notice because:

• It is necessary in order for us to provide our services and perform our contractual duties and obligations with respect to our investors, management companies and suppliers.
• We have to comply with legal, regulatory, tax, reporting, filing, anti-trust, “know your client”, anti-money laundering, anti-terrorist financing and other obligations.
• It is necessary for our legitimate interests in: (a) enabling us to manage, operate and administer our investments in accordance with the investments’ governing documents and applicable laws, regulations and policies and otherwise conduct the business of a venture capital fund manager; (b) collecting information for marketing purposes; and (c) communicating with our investors, management companies and suppliers.
• We may need to establish, exercise or defend our legal rights for the purposes of legal proceedings in connection with our management and administration of our investments.

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.

Who we share your information with

We may need to provide information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security. Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data. The third parties we share your information with are as follows:

• The funds you are invested in.
• Our service providers such as accountants, fund administrators, compliance consultants and lawyers.
• Counter parties to a transaction.

Sending your information outside of the EEA

The regulations which have been put in place to protect your privacy apply throughout the UK and EEA. As explained in the section above we will send your information to other third parties who are based outside of the UK and EEA, however we will only share your information with them because 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 Secretary of State for the Department of Digital, Culture, Media and Sport or the European Commission.
• 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 sets out how your privacy will be protected.
• 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.

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. We also need to comply with EU and UK law, which often requires us to keep certain records - which will include certain personal information – for several years.

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 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 a transfer of your information.
• Complain to the ICO.
• 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.

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.