Fabric Ventures Group Privacy Notice

PRIVACY NOTICE


Date: 8 April 2021

This notice (the “Notice”) is provided by Fabric Ventures Group S.à r.l., a private limited liability company (société à responsabilité limitée) incorporated in Luxembourg with registered number B253323 (“Fabric Ventures”, “us” or “we”). This Notice is addressed to any natural person who is resident in the European Union and the UK who is any of the following: an investor in any fund managed or advised by Fabric Ventures (a “Fabric Ventures Fund”), or a member, partner, shareholder, beneficial owner, officer, director, employee or other representative of any client of Fabric Ventures, any investor or prospective investor in any Fabric Ventures Fund or any person submitting any information to Fabric Ventures through this website (“you”) whose personal data Fabric Ventures collects and controls in the conduct of its business. 


As the controller of your personal data, Fabric Ventures is therefore responsible for any collection, processing, use and disclosure that may be carried out in relation to your personal data. This Notice gives information regarding your personal data (as defined under the Privacy Laws (defined below)) and describes the basis on which we process your personal data, for what purposes, your privacy rights under applicable privacy laws including the General Data Protection Regulation (“GDPR”) and other UK and European data privacy laws (the “Privacy Laws”) and how we protect your personal data. 


The personal data that we collect 

In the conduct of our business, we obtain personal data about you including, without limitation, your name, date of birth address and other contact details, social security number, tax or other identification number, identity documents and information about your income, assets and other financial information. This information may come from sources such as application, subscription or other forms or material completed or supplied by actual or prospective Fabric Ventures clients, other written, electronic or verbal correspondence which relate to transactions by or on behalf of a client of Fabric Ventures. We may also collect personal data provided by you in recorded calls. We may also collect special categories of personal data (as defined in the GDPR and including health, disability and religious or ethnicity information) where provided by you, with your consent, such as disability information or religious data for purposes required by you such as scheduling of meetings or access to  premises of Fabric Ventures.


How and why we use personal data

We collect your personal data to fulfill our contractual obligations, our statutory obligations and/or the legitimate interests of Fabric Ventures and for other purposes for which Fabric Ventures has a lawful basis under the Privacy Laws, including: (i) for compliance with legal and regulatory requirements such as regulations aimed at prevention of money laundering or terrorist financing or “Know your Client” requirements, as well as to verify the status and / or eligibility of Fabric Ventures’ clients for funds or services offered by Fabric Ventures and for compliance with tax reporting requirements, (ii) for purposes of reporting to, or communicating with, Fabric Ventures's clients concerning their investment in Fabric Ventures Funds or appointment or engagement of Fabric Ventures consistent with our obligations to such Fabric Ventures’s clients; (iii) in connection with our  investment activities, including investment due diligence or investment monitoring activities or in response to “Know your Client” requirements of counter-parties; (iv) in connection with litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving Fabric Ventures, Fabric Ventures Funds or Fabric Ventures’s clients, and (v) for other legitimate business interests. Such “other legitimate business interests” mainly consist in (a) the performance of our investment activities, in the event where the application of subscription is not entered into directly by the concerned investors as natural persons; (b) the management, testing, securing and optimizing of our systems and infrastructures; (c) the management of customer communications, relations and complaints; (d) strategic marketing (such as market research or in connection with investments), unless your consent is required.  If you have provided special categories of personal data to us to enable us to respond to certain requests by you such as access requests or scheduling of meetings or similar requirements, we do so with your consent and/or on the grounds of legal necessity. 


Answering questions and requests with respect to your identification and shares held in the Fabric Ventures Funds, FATCA and/or CRS is mandatory. You acknowledge that failure to provide relevant personal data requested by us and/or our service providers in the course of your relationship with the Fabric Ventures Funds may prevent you from maintaining the holding of your shares in the Fabric Ventures Funds and may be reported to the relevant Luxembourg authorities.


You acknowledge that we / our service providers may report any relevant information in relation to your investments in the Fabric Ventures Funds to the Luxembourg tax authorities (Administration des Contributions Directes) which will exchange this information on an automatic basis with the competent authorities in the United States or other permitted jurisdictions as agreed in the FATCA, CRS or similar legislation, at OECD and EU levels or equivalent Luxembourg legislation.


In addition, we may, with your consent, process your personal data in order to communicate with you for marketing purposes. In this event, we may provide additional information that we believe may be of interest, including about funds or services, news updates, research or market commentary, conferences, or events offered by or in conjunction with Fabric Ventures. You have the right to withdraw your consent when you have provided your consent to receive these communications by emailing dpo@fabric.vc or by following the instructions in any such communication, e.g. by clicking on the link to unsubscribe. 


The disclosure of your personal data

We may share your personal data with Fabric Ventures entities including with Fabric Ventures LLP and Fabric Ventures Funds for any of the purposes set forth above. 


We may share your personal data with third parties for any of the purposes set out above, including:


  • Service providers e.g., attorneys, auditors, accountants, tax advisers, administrators, custodians, depositaries, distribution managers and brokerage firms, event organisers or other agent, adviser or service provider of any Fabric Ventures Fund or Fabric Ventures’s client.


  • Other counter-parties e.g., managers, general partners or investment advisers or administrators or any of their respective agents or representatives. 


  • Any court, governmental or regulatory bodies, including tax authorities.


Such Fabric Ventures entities and third parties may act as data processor on behalf of Fabric Ventures, or, in certain circumstances, as data controller for pursuing their own purposes.


Where your personal data is processed by third parties outside the EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including the execution of standard contractual clauses (referred to above) if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission).  


Information to data subjects


Insofar as personal data you provide us includes personal data concerning your representatives (such as employees, managers, board members, signatories, beneficial owners, etc.), you represent that you have authority to provide such personal data to us and any of the recipients mentioned above (Fabric Venture entities and third parties). If you are not a natural person investor, you confirm that you have undertaken to inform any individual concerned about the processing of their Personal Data and their rights as described under this privacy notice, in accordance with the information requirements under the Privacy Laws. We may assume, where applicable, that your representatives and any individuals concerned have, where necessary, been informed of the processing and transfer of their personal data and of their rights as described under this privacy notice.


Security

We take seriously the obligation to safeguard your non-public personal data.  We maintain physical, electronic, and procedural safeguards to protect against unauthorized access to your information. 


Changes to this Notice

We may change this Notice from time to time. The latest version will be posted on our website. 


Updating your details

If any of the information that you have provided to us changes, please let us know by sending an email to dpo@fabric.vc. 


Your rights

You have certain rights relating to the personal data we hold in accordance with and subject to the Privacy Laws to: (i) check whether we hold personal data about you and to access such data (in accordance with our policy); (ii) request the correction or deletion of personal data about you that is inaccurate; (iii) have a copy of the personal data we hold about you provided to you or another controller where technically feasible; (iv) request the erasure of your personal data; (v) request the restriction of processing concerning you; and (vi) object, on request and free of charge ,to the processing of personal data concerning you for any processing carried out on the basis of our legitimate interests. Where applicable, you have a right to obtain a copy of or access to the appropriate or suitable safeguards which have been implemented for transferring your personal data outside of the EEA, in the manner and subject to the limitations prescribed in accordance with the Privacy Laws. To do so, please send your request to dpo@fabric.vc. You are required to ensure the personal data we hold about you is up-to-date and accurate and you must notify us of any changes to the personal data you provided to us in, for example in information supplied in relation to an investment in the applicable Fabric Ventures Fund. If you provided consent for us to use your personal data, including for marketing oses, you have the right to withdraw consent and we will process this withdrawal promptly. 


Data Retention

We retain your personal data until the liquidation of the Fabric Ventures Fund and a subsequent period of ten years thereafter, where necessary to comply with applicable laws and regulations or to establish, exercise or defend actual or potential legal claims, subject to the applicable statutes of limitation, unless a longer period is required by applicable laws and regulations. In any case, personal data will not be held for longer than necessary with regard to the purposes described in this privacy notice, subject always to applicable legal minimum retention periods.  


What if I have a question?  

Please email dpo@fabric.vc if you have any questions about our Notice.  You may also make a complaint, in accordance with applicable Privacy Laws, to a supervisory authority in your country of residence. The Luxembourg supervisory authority is the National Commission for Data Protection.


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