HPE Growth
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Privacy & SFDR



This is the privacy policy of HPE Growth B.V., a private company with limited liability established under the laws of the Netherlands, registered with the Chamber of Commerce under number 34296377. HPE has its registered office at Jozef Israelskade 46B, 1072 SB AMSTERDAM (“HPE“). 

HPE collects your personal data via this website (www.hpegrowth.com) (“Website“). This privacy policy is meant to advise you about the type of information that HPE collects via the Website and the purposes for which this information is being processed (“Privacy Policy“).

What we collect

When you visit or contact us through the Website, you may provide us with information about yourself, such as your e-mail address. We also automatically collect information via the use of cookies, such as your IP address, browser type, the pages you visit and the time and duration of your visit. 

How we use it

If you choose to provide us with your e-mail address or other (indirect) personally identifiable information, we will use such information:

  • to respond to your inquiry;
  • to support and enhance our service offerings to you; 
  • in the preparation and performance of analysis and development

We store your personal data for as long as is necessary for the above mentioned purposes or for secondary purposes in line with those purposes. 

The personal data collected by us through the Website may also be used to comply with legal and/or regulatory requirements.

HPE observes a strict duty of confidentiality with regard to your personal information. Without your consent HPE does not share, sell, rent, lend or disclose any of the personal data you provide to us with any third party (e.g. for direct marketing purposes), except as described in this Privacy Policy, unless:

  • We must do so by law because we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
  • Some of our businesses may be restructured, bought or sold. In this event, your personal data may need to be transferred in order for the new or surviving entity to be able to continue to provide ongoing service to the affected customers.

HPE does engage third parties to perform services on our behalf with respect to the processing of your personal data. These service providers will assist us in providing information and/or services to you. HPE only provides the amount of personal information that is necessary for these third parties to complete the requested service. Your personal data is provided subject to agreements which state that the service providers must keep such information confidential, that the data is not to be used for its own purposes and that all information will be used in accordance with applicable privacy legislation, including strict provisions in the light of data security. We do not sell your personal information to third parties for marketing purposes.

HPE can transfer your personal data to a third country outside the EEA. If  such a country does not provide an adequate level of protection for personal data, HPE will ensure that appropriate and suitable safeguards shall be in place, such as ensuring that third parties residing in such countries adhere to the Privacy Shield. 


HPE uses cookies and similar techniques whenever you interact with this Website. Cookies are small files that are sent along with this Website and placed on your equipment by your browser. On each subsequent visit to this Website, the browser searches for cookies and sends the available information stored therein to the servers of this Website. 

HPE uses the following types of cookies:
1. Technically necessary cookies

These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like remembering the contents of shopping baskets during your visit, cannot be provided.]

2. Analytical/Performance cookies

These cookies collect information about how visitors use the Website, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is aggregated. This information is used to provide aggregated and statistical information on the use of the Website and is used to improve the contents of the Website to enhance your user experience.

The Website also uses analytics cookies placed by Google Analytics to measure the number of visits and the parts of the Website that are the most popular among the Website’s visitors as well as for benchmarking purposes. This information is used to provide aggregated and statistical information on the use of the Website and is used to improve the contents of the Website to enhance your user experience. [HPE has followed the Manual of the Dutch Data Protection Authority in order to ensure that Google Analytics is used in a privacy friendly manner. This means that HPE has instructed Google to remove the last three digits of your IP-address (“Anonymize IP”) and HPE has disabled the standard setting to share data with Google.] [Furthermore, HPE has concluded a data processing agreement with Google Inc. and HPE does not use other Google services in combination with the Google Analytics-cookies.]

3. Functionality cookies

These cookies may store your browser name, the type of computer and technical information about your means of connection to the Website, such as the operating system and the Internet Service Providers utilized and other similar information. This information is used to technically facilitate the navigation and use of the Website. In addition, functional cookies may be used to store personal settings, such as language, or to remember your information for next visits if so requested. The information these cookies collect will be anonymised and they cannot track your browsing activity on other websites.

4. Links to third party functionality

These cookies are placed by YouTube and Google Maps if you use their functionality on our website to enable these parties to register and store your use of their functionality and your preferences. These cookies will only be placed with your prior permission. Please be referred to the privacy and cookie policy of the relevant medium to be informed on the purposes and use of these cookies.]

Controlling/deleting cookies 

If you do not want to have cookies used by HPE stored on your computer or want to remove cookies used by HPE that have already been stored, you can disable these cookies via your browser settings. [You are also entitled to revoke your consent for the use of cookies referred to above by HPE at any time.] If you wish to revoke your consent for use of these cookies by HPE, you can change your cookie settings by clicking.

If you disable the cookies through browser settings, the Website or certain parts of the Website may not work properly. Furthermore, certain personalized features may not be provided to you and thus you may not be able to take full advantage of all of the Website’s features. 

The browsers on all devices used by you to use or access the Website (e.g. on your smartphone, tablet, laptop etc.) will need to be adjusted to suit your cookie preferences. If you require more information or help to change your cookie preferences in your browser, please click here.


For your convenience, we have provided links to certain third party websites, including but not limited to some of HPE’s clients. HPE is not responsible or liable for any processing of your personal data via these websites. If you choose to visit a third party’s site, please be aware that the third party’s privacy policy, and not HPE’s, will govern your activities and any information you disclose while visiting the third party’s site. If you share content from the Website via social media, your personal data will be visible to those visiting your personal pages on these social media websites. HPE is not responsible or liable for any processing of your personal data via such media. Please refer to the privacy and cookie policies of the relevant third party websites/social media for information on the processing of personal data by those websites/social media and their use of cookies.


HPE has taken appropriate technical and organizational security measures in order to protect your personal data against loss, misuse, alteration and/or destruction. Although we exercise reasonable care in providing secure transmission of information between your equipment and our systems, we cannot ensure or warrant the security of any information transmitted to us over the internet. For more information about communicating with HPE and the use of this Website, please refer to our disclaimer.

Policy Changes

This Privacy Policy can be changed over time to comply with law or to meet our changing business requirement. The most up-to-date Privacy Policy can be found on our website. This Privacy Policy was last changed on [4 June 2018]. We will inform you appropriately of any relevant changes in this Privacy Policy.

Your rights

We aim to keep information about you as accurate as possible. You have a right to know if your data is being processed and, where that is the case, access to your personal data. Also, under certain circumstances, you will have the right to rectify, erase, or restrict the processing of your personal data, and – where applicable – the right to withdraw your consent or the right to data portability. If you wish to access your personal data processed by HPE or have your personal data updated, corrected or deleted, please send your request via e-mail to info@hpegrowth.com. If you feel that your rights have been infringed, we prefer to discuss this in good faith with you. However, you may always contact the appropriate local data protection authority.


If you have any questions or suggestions about our privacy practices, please feel free to contact us by e-mail at info@hpegrowth.com


HPE Growth B.V. (HPE) makes the following disclosures in accordance with the EU Sustainable Finance Disclosure Regulation (1019/2088) (SFDR) when acting as manager under the AIFMD.

Sustainability risks

This section constitutes HPE’s disclosure in accordance with Article 3 (1) of the SFDR

A sustainability risk means “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”. For HPE, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the portfolio companies in HPE’s funds.

Investing responsibly is important for HPE, with its mission being to scale the positive impact of innovations on environmental social and governance (ESG) matters through its investments, as well as its investors and other stakeholders.  HPE defines responsible investing as the consideration of ESG aspects across the entire investment lifecycle in addition to tracking the impact of its investments on the United Nations Sustainable Development Goals (SDGs).

HPE will, to the best of its ability as a minority investor:

  • Adhere to the highest standards of conduct intended to avoid even the appearance of negligent, unfair or corrupt business practices, which are embedded in HPE’s policies and procedures.
  • Identify ESG risks and opportunities within our due diligence processes pre-investment (if needed by external advisors), which are set-out in our investment proposals.
  • Continue to monitor the development of ESG risk and opportunities throughout the lifetime of its investments.
  • Motivate the management teams of our portfolio companies to undertake corrective actions to resolve ESG risks or to seize ESG opportunities and provide them with appropriate support and assistance in such efforts.


To emphasize the importance of ESG, HPE has committed itself to a membership to the Principles for Responsible Investment (PRI), instituted by the United Nations (www.unpri.org), since 2009. In accordance with the principles and in line with HPE’s beliefs, investments in certain segments, geographical areas and activities are excluded. This entails that HPE will not invest in portfolio companies domiciled in or large operations in corrupt countries[1], child labour sensitive industries or the weapon industry. Due to our investment focus of digital technology companies in North Western-Europe, most of these criteria are easily achieved.

Adverse sustainability impact

This section constitutes HPE’s disclosure in accordance with Article 4 (1) of the SFDR

As a long-term investor, HPE believes that there is a strong link between effective ESG integration and improved well-being of companies. Despite the above commitments, HPE states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the Disclosure Regulation. Given the nature and scope of HPE Growth and its investment activities, HPE Growth does not foresee to have an actual or a potential material negative impact of investment decisions on the sustainability factors set forth in the SFDR. In addition, regulatory technical standards as referred to in article 4 sub 6 and 7 of the SFDR which provide for the content, methodologies and presentation of such disclosures are yet to be published by the European Commission.

HPE Growth closely follows regulatory and market developments and will reconsider whether it will or should make disclosures on the adverse impacts of its investment decisions on sustainability factors in the manner as set forth in the SFDR.

Integration of sustainability risks in remuneration policy

This section constitutes HPE’s disclosure in accordance with Article 5 (1) of the SFDR

HPE built a compensation program that is designed to ensure no improper treatment of investors or other risk-taking behaviour will occur and to remunerate and support staff fairly, appropriately, and objectively. HPE pays part of its staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account compliance with all policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.


[1] As measured by the Corruption Perceptions Index

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