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Privacy Policy

General Information

1    This is the Privacy Notice for Seven Lanes Capital SA, and its affiliates (collectively “Seven Lanes”). For the purpose of this Privacy Notice, “Seven Lanes”, “our”, “we”, or “us” refers to the Seven Lanes Capital SA entity that is the data controller responsible for the processing of your personal data and that depends on your relationship with Seven Lanes. For example, this may be the Seven Lanes entity that operates this website, the entity with whom you have entered into pre-contract discussions or with whom you contract.

 

2    Where we refer to “you”, this refers the following individuals or individuals related to certain counterparties, including but not limited to:

  • Website visitors and users (including Client portal users), and individuals that email or contact Seven Lanes or otherwise connect with our IT infrastructure;

  • Seven Lanes alumni; and

  • Current and potential contractual counterparties such as investors, service providers, portfolio companies.

3    This Privacy Notice describes how we collect and process your personal data and it explains your rights. Personal data is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual. Processing includes all actions that can be performed on personal data such as collecting, organizing, storing, using, disclosing or otherwise making available, restricting or destroying. 

What information do we have about you?

4    The nature of the personal data we collect depends on your relationship with Seven Lanes. For example, when you are visiting our websites, we will process information about the webpages you view. Seven Lanes has issued specific privacy notices for our employees, job applicants, subscribers/investors, and suppliers/service providers/visitors, and this Privacy Notice is to be read in conjunction with such specific privacy notices.

5    We may process the following personal data about you:

If you are a Website visitor or user:

  • Basic personal data such as name, job title, and business name.

  • Contact information such as email address, postal address, and telephone number.

  • Authentication information such as login credentials, password or other authentication data.

  • Online electronic information such as cookies information, IP address, engagement statistics, usage analytics, IT traffic and action traffic (including content accessed, shared, or downloaded), user login details, if you use our websites. Please see our Cookies Notice.

  • Information you provide when you fill in forms, or register to receive information from Seven Lanes, subject to your consent or any other requirements under applicable laws.

  • Information related to electronic interactions with us or our service providers (including by email, phone or other forms of electronic communication) to the extent permitted or required by applicable law.

If you are a former Seven Lanes employee:

  • Basic personal data such as name, job title, and business name.

  • Contact information such as email address, postal address, and telephone number.

  • Information related to electronic interactions with us or our service providers (including by email, phone or other forms of electronic communication) to the extent permitted or required by applicable law.

If you are a potential contractual counterparty, or a contractual counterparty that has not yet received a more specific Seven Lanes privacy notice, information related to your employees, officers, or other related persons:

  • Basic personal data such as name, job title, and business name.

  • Contact information such as email address, postal address, and telephone number.

  • Biographical information.

  • Information to confirm your identity and for security and safety reasons when you visit Seven Lanes premises (such as checking your ID, and CCTV video images in compliance with applicable laws).

  • Information related to electronic interactions with us or our service providers (including by email, phone or other forms of electronic communication) to the extent permitted or required by applicable law.

  • Other personal data disclosed in the context of the contract, or where required under contract, applicable law or regulations.

6    Generally, special categories of personal data are not purposely processed by Seven Lanes, however in limited cases some special personal data may be implied or obtained, for example, from information you provide in relation to meal/dietary preferences, or in support of disability of our visitors/guests. Any special category personal data we receive is processed in accordance with applicable law.

7    We primarily obtain your personal information directly from you, including data about your usage of the website services and actions.  Some information may be inferred from the information you provide or arise in the context of managing our relationships with you. Additionally, Seven Lanes may receive personal information about you from third parties such as third-party data providers, and from publicly available sources.

How do we process your personal information and why is this justified?

8    We process your personal data for a specific purpose and only process the personal data, which is relevant to achieve that purpose. In particular, we process your personal data to:

  • Manage our relationship with you (including verifying your identity);

  • Communicate with you (including sending promotional or informational communications);

  • Provide our services, including our website such as the Client portal and/or video portal;

  • Assess, develop, administer, support, and improve our services;

  • Take steps to protect the security, accuracy, and confidentiality of data and information held by us, and secure our IT systems, architecture, and networks including to detect and prevent cyber-security and similar threats;

  • Manage our operations and business, including managing the operations, functions, resources, of Seven Lanes entities, and the overall corporate governance of Seven Lanes;

  • Enhance our knowledge of markets in general and analyze market data;

  • Enter into pre-contractual discussions with you, and assess the services and suitability of potential vendors and service providers;

  • Organize and hold online meetings, calls, and video conferences;

  • Record audio or video of our interactions where required by applicable law and regulations (including financial regulations), or where permitted during our online events, meetings, presentations, or training sessions;

  • Secure our premises and property and ensure the safety of visitors and staff;

  • Preserve our economic interests including by protecting ourselves against, detecting, and preventing fraud, misconduct, money laundering, bribery and corruption, theft of proprietary information, breach of confidence, other financial or business crimes, and other unlawful activity;

  • Ensure our compliance with applicable legal and regulatory obligations and industry standards (e.g., complying with our policies and legal requirements);

  • Preserve our legal interests (e.g., managing mergers and acquisitions involving our company, enforcing or defending our legal rights); and

  • Any other purposes imposed by applicable law and governmental authorities,

 

9    We will process your personal data when we have a proper legal basis, such as:

  • To take pre-contractual steps;

  • To perform our obligations in our contract;

  • To comply with our legal or regulatory obligations. For example, this might include in relation to:

    • website visitors or users: adhering and monitoring adherence, as applicable, to international marketing laws, and financial services and financial supervisory regulations and rules;

    • contractual counterparties (current or potential) generally: conducting due diligence; adhering and monitoring adherence, as applicable, to international marketing laws, anti-money laundering and anti-bribery and corruption laws, financial services and financial supervisory regulations and rules, tax legislation;  monitoring sanctions lists and other country specific sources; or exercising our audit rights;

    • individuals that attend our premises/events: monitoring adherence to applicable health and safety laws; and

    • all individuals the subject of this Privacy Notice: adhering and monitoring adherence to laws and regulations governing electronic communications, and complying with judicial or administrative orders as may be applicable to you/the entity related to you;

  • When it is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms.  Please note that, when processing your personal data on this basis, we always seek to maintain a balance between our legitimate interests and your privacy. Examples of ‘legitimate interests’ are data processing activities performed:

    • to design, implement, and continuously improve efficient organizational processes (e.g., we may opt to use certain platforms or tools offered by suppliers to process data and enhance operational efficiencies, we may test our existing technology and security platforms to identify areas for improvement);

    • to benefit from cost-effective services (e.g., we may opt to use certain platforms offered by suppliers or service providers to process data);

    • to market and offer our company, products, and services to our clients and other key stakeholders of Seven Lanes;

    • to manage our relationship with you (e.g., to keep our records updated and to understand how users use the services);

    • to investigate allegations of or prevent fraud or criminal activity, compliance breaches, and misuses of our products, services, or our IT systems, architecture, and networks;

    • to sell any part of our business or its assets or to enable the acquisition of all or part of our business or assets by a third party; and

    • to meet our corporate and social responsibility objectives.

  • we have obtained your prior consent; or

  • we are otherwise permitted or required by law to do so.

10   You are under no obligation to provide Seven Lanes with personal data. However, if you fail to provide personal data when requested and where such personal data is necessary for us, for example, to provide you with services, you may be prevented from using the services. We will notify you if this is the case at the time. 

Who has access to your personal data and to whom are they transferred?

11    We will never sell your personal data.

12    In the course of our activities and for the same purposes as those listed in this Privacy Notice, your personal data may be accessed by or transferred to the following categories of recipients to achieve such purposes:

  • our personnel (e.g., personnel with management, compliance, communications, human resources, IT, client services, internal audit, finance and other functions, including individuals employed by Seven Lanes entities providing intragroup services);

  • suppliers and service providers (e.g. outsourced service providers, and providers of due diligence and similar checks);

  • technology systems providers, including cloud and database providers, and related consultants;

  • any third parties to whom we assign our rights and obligations;

  • our professional advisors and external lawyers;

  • our banks, lenders, and external auditors where lawfully required; and

  • other Seven Lanes entities where required for the purposes of shared intragroup services, corporate governance or applicable laws/regulations.

 

Such recipients are obligated to protect the confidentiality and security of your personal data.

13    In limited circumstances, your personal data may be accessed by or transferred to law enforcement, regulatory bodies, or judicial authorities. This will occur only when legally required.

14   Your personal data may be processed by Seven Lanes in a different country than where you are based. For example, your personal data may be processed by Seven Lanes in one of its many international offices or processed by a service provider in another country. The data protection legislation in such other country may not give you as much protection as the data protection legislation in the country where you are located

15    We ensure that any transfer is made in accordance with applicable data privacy law. For example, for transfers to a country deemed by a privacy authority to not offer the same level of protection, we ensure that the transfers are governed by appropriate safeguards, such as the European Commission Standard Contractual Clauses.

16    You may request additional information in relation to such cross-border transfers and obtain a copy of the adequate safeguard put in place by Seven Lanes as described in the section titled Who can I contact if I have any questions or concerns?.

How do we protect your personal data?

17    We implement technical and organizational measures to provide an appropriate level of security and confidentiality to your personal data. These measures consider the state of the art of the technology; the costs of its implementation; the nature of the data; and the risk of processing.

18    The purpose of these measures is to protect your personal data against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access, and against other unlawful forms of processing.

19    While we take reasonable care to implement such measures, remember that the internet is inherently unsafe, and we cannot guarantee the security of your personal data when transmitted over the internet or email.

 

How long do we store your personal data?

20    We will retain your personal data for as long as necessary to fulfil the purpose for which it was collected, to comply with legal or regulatory requirements, or for the establishment or defence of legal claims.

21   Where it is not possible to remove your personal data from our systems (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.

What are your rights and how can you exercise them?

22    We recognize that you may have rights with regard to our processing of your personal data. While the nature and extent of these rights will differ from location to location, we have processes in place to respond in a timely manner to any valid request. Your rights may include:

  • the right to access the personal data about you that we process;

  • the right to request the correction of personal data that you believe is incorrect, obsolete, or incomplete;

  • the right to request the erasure of your personal data;

  • the right to restrict the use of your personal data to specific categories of processing;

  • if your personal data is processed based on your consent, you have the right to withdraw your consent at any time (please note that if you withdraw your consent, processing based on your consent that took place before your withdrawal will remain lawful);

  • the right to object, in whole or in part, to the processing of your personal data; and

  • the right to request that the personal data you provided us be returned to you or transferred to the person or entity of your choice in a structured, commonly used and machine-readable format without hindrance from us.

23    You may exercise your rights at any time by using the details in the section Who can I contact if I have any questions or concerns? To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.

24   We may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal data requested, or to exercise any of your other rights. This is to ensure that personal data is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the personal data processed in relation to you, including, for example, the nature and location of your relationship with us.

Who can I contact if I have any questions or concerns?

25    If you have any questions about how your personal data is processed (including if you are unsure of which Seven Lanes entity is the controller), or if you want to exercise the above rights, you may contact our Data Privacy Officer by email at Seven Lanes hello@sevenlanescapital.com

26   You also have the right to complain to the competent data protection authority in relation to the processing of your personal data.

How will you be informed of the changes to our Privacy Notice?

27    We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments.  This Privacy Notice has an effective date as shown at the end of the document.

Version 06 November 2023

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