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

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.

• 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.

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.

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.

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.

What is the purpose of this Talent Acquisition Privacy Notice

Dawn Capital LLP and its group (the "Dawn", "we" or "us") are committed to protecting your privacy rights. If you are applying for work with us or one of our portfolio companies (whether as a C-Suite level executive, employee, worker, contractor or advisor), or engaging with Dawn regarding potential connections to our portfolio companies, this talent acquisition privacy notice (the "Talent Acquisition Privacy Notice") makes you aware of how and why your personal data will be used, namely for the purposes of recruitment or relationship building exercise, and how long it will usually be retained for.

Dawn is a controller for your personal data meaning that it is responsible for deciding how we hold and use personal data about you.

This Talent Acquisition Privacy Notice was last updated on 28 October 2024.

The kind of information we hold about you

In connection with your application for work with us or our portfolio companies, we may collect, store, and use the following categories of personal data about you:

• the information you have provided to us in your CV, covering letter/email, or information that is accessible on your LinkedIn profile (as applicable);
• the information you have provided on our application and/or assessment forms (as applicable), including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications; and
• any information you provide to us during an exploratory conversation and/or interview.

In addition, we may collect the data set out above (as applicable) as part of a relationship building exercise.

We may also collect, store and use "special categories" of more sensitive personal data for the purpose of our equality, diversity and inclusion initiatives, such as:

• information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.

How is your personal data collected

We collect personal data about candidates from the following sources:

• you, the candidate;
• referees, from whom we obtain a reference;
• colleagues, recruiters and other professionals in our network that we engage or work with; and
• publicly accessible sources: results of social media searches such as LinkedIn.

How we will use information about you

We will use the personal data we collect about you to:

• assess your skills, qualifications, and suitability for a role;
• inform of/consider for job opportunities or potential collaboration across our portfolio;
• carry out reference and/or background checks;
• communicate with you about the recruitment process;
• keep records related to our hiring processes; and
• comply with legal or regulatory requirements.

It is in our legitimate interests to i) analyse the applicant pool to ensure that we are appointing, or in the case of a portfolio company recommending, an appropriate connection, advisor or candidate and ii) decide whether to appoint, or in the case of a portfolio company recommend, you to the role, since it would be beneficial to our business or the relevant portfolio company.

We also need to process your personal data to decide whether to enter into a contract of employment or engagement with you.

If you’re interviewing for a specific role with Dawn or with one of our portfolio companies, having received your CV, covering letter/email, your application/profile form, and/or having obtained the data accessible on your LinkedIn profile, we will then process that information to decide whether you meet the basic requirements to be shortlisted for a role. If you do, we will decide whether your profile is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information we collected during the recruitment process and that you provide to us at the interview to decide whether to offer you, and in the case of a portfolio company recommend you for, a role. We may take up references at any point during the interview process.

As part of a general relationship building exercises, we will identify a potentially relevant profile, for example, through a LinkedIn search or through our network. We will then engage you in a conversation with us by way of an introductory call or a LinkedIn message. If we think that your profile would be of interest, we may share it with the Dawn team, certain portfolio companies and/or other companies of interest.

If you fail to provide personal data

If you fail to provide information when requested that is necessary for us to consider your application and/or profile for a particular role (such as evidence of qualifications or work history), we will not be able to process your application successfully.

How we use particularly sensitive personal data

We will use your particularly sensitive personal data in the following ways:

• we will use information about your health and disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made; and
• we may use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. Data that Dawn uses for these purposes will be collected on an anonymised basis. Candidates are entirely free to decide whether or not to provide such information and your application will not be affected either way.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Recipients of your personal data

We may disclose your personal data to key members of our legal and finance teams, as well as to the relevant team managers in respect of the role you are applying for or, where applicable, to the relevant portfolio company.

It may also be necessary from time to time for us to disclose your personal data to:

• entities within our group and affiliates;
• recruiters / search firms to assist with recruitment or relationship building exercise;
• third parties or agents to assist in the administration, processing and management of certain activities pertaining to prospective hires including travel and expense management service providers;
• individuals or companies employed by Dawn to carry out specific services, functions or consultancy work and other financial institutions;
• relatives or legal representatives of prospective hires;
• regulatory bodies to whom we are obliged or required to disclose information including the Workplace Relations Commission, courts and court-appointed persons;
• relevant government departments and agencies; and
• other support service providers necessary to support the organisation in the services listed.

Transfer of personal data outside the UK and/or the EEA

The personal data that we collect from you may be transferred to, and stored at, a destination outside the UK and/ or the European Economic Area ("EEA"), for the purposes described above. Those countries may not provide an adequate level of protection in relation to processing your personal data. Due to the global nature of our business, your personal data may be disclosed to members of our group outside the UK and/ or EEA, including in particular in the USA. It may also be processed by staff operating outside the UK and/ or EEA who work for us or for one of our suppliers who act on our behalf. We will ensure, in so far as possible, appropriate safeguards are in place to protect the privacy and integrity of such personal data.

How long will you use my information for

If your application for employment or engagement is successful, personal data gathered during the recruitment process will be retained in accordance with our retention policy.

If your application for employment or engagement is unsuccessful, subject to a few exceptions as noted below, we will hold your data on file for between six-twelve months after the end of the relevant recruitment process to the extent necessary to enable us to comply with any legal obligations or for the exercise or defence of legal claims (subject to any applicable legal or regulatory obligations to retain such information for a longer period).

We will seek your consent if we wish to retain your data for a further period on the basis that a further opportunity may arise in future and we may wish to consider you for that. You do not have to consent to this, and you can withdraw your consent at any time thereafter. At the end of that period (or if you withdraw your consent prior to this) we will securely destroy your personal data in accordance with applicable laws and regulations.

If you consent to be considered for job opportunities or collaboration opportunities across our portfolio, your data (for example, your CV and any references obtained) may be retained for a period of up to six years.

In the event that any court actions or other legal proceedings are pending or impending, personal data will be deleted after termination of the court action or legal proceeding as appropriate.

Your rights in connection with personal data

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

• request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you;
• request correction of the personal data that we hold about you;
• request erasure or deletion of your personal data where there is no lawful basis for us to continue to process it or where you have exercised your right to object to processing (see below);
• object to processing of your personal data where you believe we do not have a legitimate interest in processing your personal data. You also have the right to object where we are processing your personal data for direct marketing purposes;
• request the restriction or suspension of processing of your personal data;
• request the transfer of your personal data to another party; and
• right to withdraw your consent where we are relying on this as the lawful basis for processing your personal data.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us at hello@dawncapital.com.

Complaints

You have the right to lodge a complaint with a supervisory authority if you are unhappy with how your personal data is being handled. The UK supervisory authority is the Information Commissioner (here).

Further Information

If you require any further clarification regarding this Talent Acquisition Privacy Notice, please contact us at hello@dawncapital.com.