Privacy policy

Last updated November 2023

General

We recognise that it is important for you to understand how we use your personal data. Therefore, please read the following information carefully as it contains important information regarding www.livingbridge.com (this/our “Site”) and the way in which we use your personal data. The information contained in this policy is communicated and issued by Livingbridge EP LLP, Livingbridge Enterprise LLP and/or Livingbridge VC LLP (together “the Livingbridge Firms” and “we”, “us”, “our”). Our Site operates as the website for each of the Livingbridge Firms.

Our contact details are set out in part 10 of this privacy policy below.

This Site is not intended for children and we do not knowingly collect data relating to children.

This privacy policy (and any other documents referred to in it) describes the way we will process and use any personal data about visitors to our Site, job applicants, the employees and related personnel (including shareholders) of our current, potential and former investee businesses and media contacts. We aim to be transparent about our data practices regarding the personal data that we may collect, use, maintain and otherwise process. Please read this privacy policy carefully to understand our practices regarding your personal data and how we will treat it.

We have a legal duty to protect personal data that we collect under the Data Protection Act 2018 (the “DPA”) and the General Data Protection Regulation (EU) 2016/679 as adopted into law in the UK, (the “GDPR”).

Which Livingbridge Firm uses my data?

Our contact details are set out in part 10 of this privacy policy below.

This Site is not intended for children and we do not knowingly collect data relating to children.

About this Policy

By accessing any part of this Site, you acknowledge that we may process your personal data as described in this policy. If we ask for your consent to a particular use of your information on this Site and you give that consent, that use will also be covered by this policy.

This policy covers:

Information we may collect from you
How do we collect personal data about you?
Our use of your personal data and our justifications for doing so
Disclosure of your information
Security of your personal data
Retention of your personal data
Where we transfer and store your personal data
Your rights in your personal data
Changes to our policy
Contact and complaints
Disclaimer

Information we may collect from you

The personal data that we collect from or about you includes the following:

Name
Email address
Telephone number
Postal address
Gender
Age
Work address
Job role and the organisation you are involved with
Job history (and your CV if you submit it to us)
If you are an employee or related personnel (including shareholders) of our current, potential and former investee businesses, we may process all information that the investee company holds about you
Technical information, such as your IP address, information about the device on which you accessed our Site and information about your visit, such as the pages that you viewed and how you interacted with our Site
Your social media handle/user name details if you engage with us on social media
Information we collect as part of the due diligence on prospective investee companies or when deciding to invest in third parties (if we interview you as part of our due diligence, you will be given more information about this at the time)
Any other information that you decide to give us when you use our Site or contact us

How do we collect personal data about you?

We may collect personal data about you in a variety of ways, including:

When you access our Site
When you contact us, via our Site or otherwise
When you apply for a role with us, where a recruitment company provides us with information about you, or if you send us your CV
When we are involved in the general management of one of our investee businesses
When you engage with us on social media (for example by mentioning or tagging us or by contacting us directly)
When one of our employees gives it to us

Our use of your personal data and our justifications for doing so

How and why we use your personal data

What is our legal justification for processing your personal dataTo provide you with the information and services that you request from us (i.e. to complete certain tasks, processes, and to communicate with you regarding those services that you request from us and respond to your questions and comments).If we have a contractual relationship with you, we may rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data.

Alternatively, in some scenarios, we rely on our legitimate interests as a business (for example, it is in our interests to troubleshoot customer issues or deal with your specific queries via our Site or on social media). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
To measure how satisfied our Site visitors are and provide customer service (including troubleshooting in connection with your requests for services or when you ask us questions on social media);We may use your personal data to tell you about relevant services and offers (“marketing”).

We can usually only use your personal data to send you marketing messages if we have consent from you to do so or, in some cases, we can rely on a legitimate interest.

You can ask us to stop sending you marketing messages by contacting us at any time at the contact details set out at part 10 of this privacy policy below.

To help in the general management of one of our investee businesses, for example, we may assist investee companies with their recruitment process and, in doing so, will collect and retain the CVs and references of promising individuals.We have a legitimate interest to make sure that the businesses in which we have invested in receive the support that we believe they need, which may involve processing personal data.
Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

To monitor the use of our Site and ensure that it is presented in the most effective and relevant manner for you and your device.

We may use cookies to do this.

We have a legitimate interest to ensure that our Site works properly and that our services are high quality and efficient.

We rely on consent to place cookies on your device. For information on how we use cookies, please see our cookie statement.

To find out more about the users of our services as a whole (and not to find out more about you as an individual) to ensure that the services that we offer are most likely to interest our service users.
We may use cookies to do this.

We have a legitimate interest to make sure that we are providing you with the information that we think is most relevant to you.

Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.
We rely on consent to place cookies on your device. For information on how we use cookies, please see our cookie statement.

To manage our internal business HR practices to process emergency contact and dependent information.We rely on the performance of our contract with our employee that has provided us with your personal data.We may record calls you make to us or that we arrange with you and will use this data for quality assurance purposes, or for record keeping purposes (for example if we want a record of a company meeting or an interview we have given). Where your call is recorded we will tell you in advance.We use data in this way for a variety of reasons. It may be pursuant to a legal obligation and it is also in our legitimate interests to retain records of certain meetings or interviews.To carry out a recruitment process or to retain promising or speculative CVs (and associated references) that we have received where a role is not currently available.We have a legitimate interest to determine whether to appoint possible candidates and to retain the CVs, references and personal data of applicants that we feel might be suited for a role in the future.

Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights. To ensure that the personal and any financial information that you provide to us is accurateIn some cases we will use your personal data because it’s necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud or ensuring security of the Site) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.To detect, investigate, report, and seek to prevent financial crime or other illegal activityTo manage risk for us and our investors.To fulfil our legal and compliance-related obligationsFor administrative or business purposes, where you contact us for a particular reason other than those set out above, such as to report problems with our Site.We have a legitimate interest to respond to your contact for the purposes of administering our business.

Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

Disclosure of your information

Service provision: In order to provide our services to you we have to share your information with certain third parties such as our group companies who share various operations and business processes (including our investee companies), professional advisors or analysts and search engine providers that assist us in the optimisation of our Site. Whenever we share your personal data, we require all third parties to whom we send your data to treat your data securely and in accordance with this policy, and will take reasonable steps to enforce this.

Third party marketing: Where you have told us that it is ok to do so, we may allow carefully selected third parties, including marketing and advertising companies, or our business partners, to contact you occasionally about services that may be of interest to you. We do not sell your personal data. If you change your mind about being contacted by these companies in the future, please let us know by contacting us using the details set out at part 10 below. You may also opt out of receiving any marketing communications you receive by following the instructions outlined in these communications.

Where our group structure changes: If any of our businesses enter into a joint venture with, purchase or are sold to or merge with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors. We will only do this if they agree to keep your data safe and private. If a change to our group happens, then other parties may use your data in the same way as set out in this notice.

Sharing data to prevent crime and otherwise comply with laws: We may use the information that you provide to us if we are under a duty to disclose or share your information in order to (a) comply with (and/or where we believe we are under a duty to comply with) any legal obligation; (b) enforce or apply our terms of use and any other agreement; or (c) protect the rights, property, or safety of the Livingbridge Firms, our other group companies, clients, employees, investees, contractors or others. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention, or where we have to carry out an internal investigation. It may also include sharing your personal data with law enforcement agencies, regulatory bodies or public authorities in order to prevent or detect crime.

Security of your personal data

We take the security of your personal data very seriously and have put physical, technical, operational and administrative strategies, controls and measures in place to help protect your personal data from unauthorised access, use or disclosure as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate.

Where you have chosen a password which allows you to access certain parts of our Site, you are responsible for keeping this password confidential. Please do not share your password with anyone.

Our Site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any personal data via these websites.

Retention of your personal data

We will keep your personal data for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal data. This means that the retention periods will vary according to the type of personal data.

Where we transfer and store your personal data

We may transfer your personal data outside of the UK and the European Economic Area (EEA) where local laws may not provide legal protection for your information in the same way as is applicable in the UK or the EEA. This is because many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we send (or permit a third party to send) your personal data outside of the UK and the EEA, we will make sure that we take steps necessary to protect your data as required by applicable laws. This means that we will only transfer your personal data to third parties that: (a) are in countries that have been confirmed by the UK government and/or European Commission to provide adequate protection to personal data; or (b) have agreed to provide all protections to your personal data as set out in applicable laws (such as entering into particular contract terms).

Your rights in your personal data

You have certain rights in respect of the personal data that we hold about you. Details of these rights are set out below. To exercise any of these rights, please contact us using the contact details set out at part 10 of this privacy policy below.

You have the right:

to ask us not to use your personal data for direct marketing purposes;
to ask to see what personal data we hold about you and to find out about the way that we process the data (and in some circumstances, you can ask us to provide a copy to a third party);
to ask us to correct or update any personal data which is inaccurate;
to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to use it;
to ask us to temporarily stop using your data if you don’t believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it; and
not to be subject to decisions made solely on the basis of ‘automated processing’ (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.

Changes to our policy

We reserve the right to modify this privacy policy from time to time – for example, if we need to reflect changes to the way that we use your personal data. Any changes we make in the future will be posted on this Site and, where appropriate, notified to you by e-mail. You should check back frequently to see any updates or changes to our privacy policy.

This policy was last updated on 22 March 2023.

Contact and complaints

All comments, queries and requests relating to our use of your personal data are welcomed (including in relation to our transfer of your data outside the UK and EEA) and should be addressed to compliance@livingbridge.com or to Data Protection, Livingbridge, 100 Wood Street, London, EC2V 7AN. Alternatively, please address the relevant Livingbridge Firm via the details set out below; or call us directly on +44 207 506 5600.

If you have any complaints regarding this privacy policy or the way that we use your personal data you may also contact the UK Information Commissioner at telephone number 0303 123 1113 or https://ico.org.uk/. Although, we would always prefer for you to speak to us about your complaint first so that we could try to put it right.
Information about the Livingbridge Firms:

Livingbridge EP LLP is the Operator, Manager and Alternative Investment Fund Manager (“AIFM”) of Livingbridge 4 LP, Livingbridge 5 LP,Livingbridge 6 LP, Livingbridge Parallel LP, Livingbridge 7 LP and FPPE Fund plc. Livingbridge EP LLP is a limited liability partnership incorporated in England and Wales (registered number OC311889) and is authorised and regulated by the Financial Conduct Authority (Firm reference number 429087).

Livingbridge Enterprise LLP is the Operator, Manager and AIFM of Livingbridge Enterprise 1 LP, Livingbridge Enterprise 2 LP and Livingbridge Enterprise 3 LP . Livingbridge Enterprise LLP is a limited liability partnership incorporated in England and Wales (registered number OC401650) and is authorised and regulated by the Financial Conduct Authority (Firm reference number 717564).

So, for example, if you are an employee of a business that has received investment funds from the Livingbridge Enteprise 2 fund, Livingbridge Enterprise LLP will be your data controller. If you’re ever unsure, please get in touch with us using the contact details at the top of this part 10 and we will put you in touch with the right Livingbridge Firm.

You can contact each of the Livingbridge Firms at the following address 100 Wood Street, London, EC2V 7AN or by email at compliance@livingbridge.com.

Disclaimer

This document is being circulated to a limited number of sophisticated institutional investors on a confidential basis and contains information from Livingbridge EP LLP and Livingbridge Enterprise LLP (together the “Livingbridge Firms”) that may be confidential and/or privileged. This document is proprietary to the Livingbridge Firms and if you are not the intended recipient, you may not read, copy, make available, distribute or use this information and must return this document to the Livingbridge Firms immediately.
Livingbridge EP LLP is the operator and manager of Livingbridge 4 LP, Livingbridge 5 LP, Livingbridge 6 LP, Livingbridge 7 LP, Livingbridge Parallel LP and FPPE Fund plc and invests on behalf of its institutional clients. Livingbridge EP LLP is a limited liability partnership registered in England No OC311889.
Livingbridge Enterprise LLP is the operator and manager of Livingbridge Enterprise 1 LP, Livingbridge Enterprise 2 LP and Livingbridge Enterprise 3 LP and invests on behalf of its institutional clients. Livingbridge Enterprise LLP is a limited liability partnership registered in England No. OC401650.
The Livingbridge Firms are authorised and regulated by the Financial Conduct Authority (FCA). The registered office address for the Livingbridge Firms is: 8th Floor, 100 Wood Street, London EC2V 7AN.
You should not rely on any information or opinions contained in this document in making an investment or other decision but should obtain appropriate and specific professional advice of your own. Nothing contained in this document constitutes or should be construed to constitute investment, legal, tax or other advice. This document contains general information about the investment strategies used and intended to be used by the Livingbridge Firms. The information supplied is not and in no way should be construed to constitute an offer, solicitation, invitation or recommendation with respect to the purchase or sale of any security issued by any fund or other pooled investment vehicle sponsored or managed by any Livingbridge Firm (each, a “Fund”) and under no circumstances is this document to be construed as a prospectus or an advertisement. Any offer or solicitation relating to the securities of a Fund may only be made by delivery of the final confidential private placement memorandum and/or other offering document (the “Memorandum”) and governing documents of such Fund and only where permitted by law. This document is qualified in its entirety by the more detailed information in the Memorandum and the governing documents of such Fund. Any decision to make an investment in a Fund should be based solely on the information in the Memorandum and the governing documents of such Fund.
This document is intended to be communicated only to such persons as the Livingbridge Firms are legally able to send it and who are legally able to receive it in their jurisdiction of residence. If you are not such a person, this document must be returned to the Livingbridge Firms immediately.
This document is made to, or directed at, only the following persons: (i) persons falling within one of the categories of “investment professionals” as defined in Article 14 of the Financial Services and Markets Act 2000 (Promotion Of Collective Investment Schemes) (Exemptions) Order 2001 (as amended) (the “Promotion of CIS Order”) and directors, officers and employees acting for such persons in relation to an investment; (ii) persons falling within any categories of persons described in Article 22 of the Promotion of CIS Order and directors, officers and employees acting for such persons; (iii) persons falling within the definition of “certified high net worth individuals” within Article 21 of the Promotion of CIS Order, (iv) persons falling within the definition of “self-certified sophisticated investor” within Article 23A of the Promotion of CIS Order; and (v) to any other person to whom the Livingbridge Firms may otherwise lawfully provide the document in accordance with the Promotion of CIS Order or who receives this document outside the United Kingdom (persons satisfying the criteria above being referred to as “relevant persons” or a “Relevant Person”). Persons who are not Relevant Persons must not act on or rely on this document or any of its contents. Any investment or investment activity to which this document relates is available only to Relevant Persons and will be engaged in only with Relevant Persons.
Whilst the contents of this document are provided in good faith for information purposes only, no representation or warranty, express or implied is given by the Livingbridge Firms or by any of their partners, members or employees as to its accuracy, reliability or completeness or that it is up to date, and it should not be relied on as such.
To the fullest extent allowed by law and the rules and regulations of the Financial Conduct Authority, the Livingbridge Firms and their partners, members and employees shall not be liable, whether in contract, tort (including negligence) or otherwise howsoever, for any losses, damages, costs or expenses of whatever nature (including (without limitation) any consequential, indirect or unforeseeable loss or loss of bargain, opportunity or profit) incurred or suffered by you or any third party arising out of or in connection with the use of the contents of this document.
No representation or warranty is given as to the achievement or reasonableness of any future projections, forecasts, targeted or illustrative returns. Any past performance information contained in this document is not an indication of future performance. It may not have been audited or verified by an independent party and should not be seen as any indication of returns which might be received by investors in any other funds managed by the Livingbridge Firms. Certain information included in this document was derived from third-party materials or other sources believed to be accurate, but no independent verification has been made of such material or other sources. Where projections, forecasts, targeted or illustrative returns or related statements or expressions of opinion are given (if any), they should not be regarded by any recipient as a guarantee, prediction or definitive statement of fact or probability. While the Livingbridge Firms believe that projected returns for unrealised investments are based on assumptions and valuation methodologies that are reasonable under the circumstances, actual events and circumstances are difficult or impossible to predict and will differ from assumptions. In particular, there can be no assurance that unrealised investments will be realised at the valuations shown. Actual realised returns will depend on, among other factors, future operating results, the value of the assets and market conditions at the time of disposition, any related transaction costs, and the timing and manner of any sale, all of which may differ from the assumptions contained herein. Any performance information provided on a ‘gross’ basis may not reflect some or all management fees, carried interest, taxes and/or allocable expenses borne by investors which in the aggregate may be substantial.
This document identifies a number of benefits inherent in the Livingbridge Firms’ services and operations on behalf of the Funds, although the Funds are also subject to a number of material risks associated with these benefits, as further identified in the relevant Fund’s definitive documents. Although the Livingbridge Firms believe that the Livingbridge Firms and their personnel and affiliates will have competitive advantages in identifying, diligencing, monitoring, consulting, improving and ultimately selling investments on behalf of the Funds, there can be no guarantee that the Livingbridge Funds will be able to maintain such advantages over time, outperform third parties or the financial markets generally, implement their investment strategies or achieve their investment objectives for the Funds or any investment or avoid losses. For additional information regarding risks and potential conflicts of interest regarding an investment in a Fund, please see the risk factors and conflicts of interest disclosures in the relevant Memorandum.
Information in this document has been compiled as at 30 September 2023 (unless otherwise stated herein). Under no circumstances should a recipient assume that information contained herein is correct as of any time subsequent to such date.
The Livingbridge Firms expressly disclaim any obligations to update this document, including any information required to correct any earlier inaccuracy or error. Except where otherwise indicated herein, the information provided in this document is based on matters as they exist as of the date of preparation and not as of any future date, and will not be updated or otherwise revised to reflect information that subsequently becomes available, or circumstances existing or changes occurring after the date hereof.
This document may contain material non-public information. The recipient should be aware that U.S. federal and state and non-U.S. securities laws, including the EU Market Abuse Regime, may restrict any person with material, non-public information about an issuer from purchasing of selling securities of such issuer or from communicating such information to any other person under circumstances in which it is reasonably foreseeable that such person is likely to purchase or sell such securities in reliance on such information.