Privacy Policy

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 and individuals identified as part of a general recruitment or talent acquisition exercise by Livingbridge (or one of its third party providers), 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?

As the Livingbridge Firms are three distinct corporate entities, the identity of the data controller for your personal data will vary depending on your relationship with us. If you are a general visitor to our Site, for the purpose of the DPA and GDPR the data controller of your personal data (in other words, the organisation that determines how your personal data is used) will be Livingbridge EP LLP.

If your personal data is processed by us for a fund-specific purpose (for example if you are an employee of an investee business of one of our funds) you can find out more about which Livingbridge Firm will be the data controller for your personal data on this page.

If you contact one of the Livingbridge Firms directly, that Livingbridge Firm will be the data controller for the personal data that you provide during that correspondence and in any action taken by the Livingbridge firm (such as dealing with your request) as a result.

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:

  1. The information we may collect from you
  2. The information that we receive from other people
  3. Our use of your information
  4. How we share your information
  5. Our security and data retention measures, and any transfers we make outside of the EEA
  6. How we use cookies
  7. Your rights in respect of your information
  8. Accessing and updating your information
  9. Changes to our policy
  10. Our contact information
1. 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.
2. 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
3. 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 data
To 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

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 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 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 manage our internal business HR practices to process emergency contact and dependent information. We have a legitimate interest to determine whether to appoint possible candidates and to retain the CVs 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 accurate

In 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 activity
To manage risk for us and our investors.
To fulfil our legal and compliance-related obligations
For 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.

 

4.  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.

5. 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.

6. 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.

7. 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).

8.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.
9.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 10 August 2021.

10. 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 and 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 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 and invests on behalf of its institutional clients. 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).

Livingbridge VC LLP is a limited liability partnership registered in England and Wales (registered number OC320408) and is authorised and regulated by the Financial Conduct Authority (Firm reference number 456135).

So, for example, if you are an employee of a business that has received investment funds from the Livingbridge 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.

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