Pursuant to the requirements of the General Data Protection Regulation (“GDPR“) as implemented in the EU Regulation 2016/679 (in the Netherlands also known as Algemene verordening gegevensbescherming (“AVG”), HPE Growth B.V. (“HPE Growth” or “HPE”) must ensure compliance with GDPR with respect to the collection and processing of personal data.
1. What we collect
2. How we use it
3. Sharing of your personal data
6. Policy Changes
7. Your rights
1. What we collect
We collect, use, share and store personal and financial information about you. Most of the information collected by us is information which you have provided to us directly, whether this is by signing up online to receive information from us or by you providing information to us when becoming an employee, limited partner or portfolio company.
Information we collect from you when you visit and/or request to receive information from this website (www.hpegrowth.com) (“Website“):
- personal contact information (e.g. name, email address); and
When you enter into a contract with us as our limited partner, you may provide us with the following information in order for us to perform our obligations under that contract or to provide you with advice or guidance in relation to our products or services that are offered by us, or to fulfil our legal obligations:
- personal contact information (e.g. name, (email) address, location);
- proof of identification information, which may include a copy of your driver’s license, passport, or other appropriate identification documentation;
- financial information (such as banking information and an account number);
- regulatory requirements, such as FATCA/CRS, TIN-number, KYC-required documents;
- any other relevant information provided by you to us in correspondence; and
- investment details.
When you enter into a contract with us as our portfolio company, you may provide us with the following information in order for us to perform our obligations under that contract or to provide you with advice or guidance in relation to our products or services that are offered by us, or to fulfil our legal obligations:
- personal contact information (e.g. name, address, copy passport location);
- financial information (such as banking information and an account number;
- KYC-required documents; and
- any other relevant information provided by you to us in correspondence.
For our legitimate business interest, we may also process a report of HR due diligence of management of the portfolio company.
As part of our recruitment process, we collect and process personal data relating to job applicants in order for us to (i) meet our contractual obligations when entering into a potential contract with you, (ii) meet our legal obligations or (iii) based on legitimate interest for us to adequately maintain and manage the recruitment process. The following information is collected from you and is stored in certain systems and formats, e.g., in the recruitment file, in the organizations HR management system and in other IT systems, including the organizations email system:
- name, address and contact details, including email address and telephone number;
- gender and date of birth;
- details of qualifications, including skills, experience and employment history, including start and end dates with previous employers;
- details of your marital status;
- nationality and entitlement to work in the Netherlands;
- candidate photographs.
Furthermore, there may be some instances where we collect information about you when we believe our service will interest you. This includes personal contact information (e.g. name, (email) address, location, telephone number) from public databases.
2. How we use it
When we use information, we will ensure that the processing complies with all applicable laws. The purpose for processing personal data includes the following:
- Contract performance – the information needed to perform our service;
- Legal obligation – we are required by law to process your information;
- Legitimate interest – we’re allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights; and
- Consent – in some cases we may obtain your consent to use your information (when we use this reason, you always have the right to withdraw your consent).
If you are our limited partner, or portfolio company, we will use your personal data in the following ways and for the following purposes:
- to perform our obligations under our contract with you;
- to provide you with advice or guidance in relation to our products or services that are offered by us;
- investigating any complaint, dispute and/or any concerns relating to your investments;
- to comply with our legal obligations, such as identification verification, money laundering and other checks; and
- managing and administering our business.
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; and
- to comply with legal and/or regulatory requirements.
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.
3. Sharing of your personal data
We engage third parties to perform services on our behalf with respect to the processing of your personal data, such as third party relationships and service providers (including cloud providers). These service providers will assist us in providing information and/or services to you. HPE Growth 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 light of data security. We do not sell your personal information to third parties for marketing purposes.
HPE Growth may 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 are in place, such as ensuring that third parties residing in such countries adhere to the Privacy Shield.
- 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) entity(ies) involved in the restructuring to be able to continue to provide ongoing service to the affected customers.
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.
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 the user experience.
The Website also makes use of analytics cookies placed by Google Analytics and Squeezely 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.
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 anonymized and they cannot track your browsing activity on other websites.
4. Links to third party functionality
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.
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.
6. Policy Changes
7. 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 email@example.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 firstname.lastname@example.org.
HPE Growth B.V. (“HPE Growth” or “HPE”) makes the following disclosures in accordance with the EU Sustainable Finance Disclosure Regulation (1019/2088) (“SFDR”) when acting as manager under the AIFMD.
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, 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.
If you have any questions or suggestions about our SFDR disclosures, please feel free to contact us by e-mail at email@example.com.
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