Privacy Policy

6 Degrees Capital (“we”, “us”, “our”) is committed to protecting and respecting your privacy in accordance with data protection laws that may be applicable to it from time to time. Any reference to the 6 Degrees Group is to us and any funds managed by us.

This policy sets out the basis on which any personal data we collect from you, that you provide to us, or we receive from others will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This website is not intended for children and we do not knowingly collect data relating to children.

We are the controller and responsible for this website. We have appointed a Data Protection Officer (‘DPO’) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise any of your legal rights, please contact the DPO using the details set out below. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Information we collect from you

Whether you are an individual investor or a director/shareholder of a company that we are thinking of investing in through any of the funds managed by us, or someone from within our network who wishes to have a business relationship with us, we may collect and process different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from investments you are involved in and share information.
• Technical Data includes internet protocol (IP)address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website including the full Uniform Resource Locators (URL), clickstream to, through and from our site(including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

Special category personal data

In certain circumstances, we may collect, store and use your sensitive personal data, known under the GDPR as ‘special category’ data. We will do this when you provide us with information about your racial or ethnic origin. Please see below for further details on how we process special category data.

How we collect your personal data

• Personal data you give us. This may include Identity Data, Contact Data and Financial Data about you that you give us by filling informs on our site (our site) or by corresponding with us by phone, e-mail or otherwise. It includes personal data you provide when you register to receive our news and updates.
• Personal data we collect about you. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also collect your Identity Data and Contact Data from publicly available sources, to send you communications which make suggestions and recommendations to you about services or investments that may be of interest to you. You will always be provided with the opportunity to opt-out of receiving these communications (see “Marketing” below).
• Personal data we receive from other sources. This is personal data we receive about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data if we intend to share that data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example: (i) business partners such as accountants and lawyers, located both inside and outside the EU; (ii) portfolio companies, investors and suppliers, located both inside and outside the EU; (iii) analytics providers such as Google based outside the EU; and (iv) publicly available sources such as LinkedIn, Companies House and the Electoral Register based inside the EU).

 

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

We will ask for your permission (Consent) to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.  

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

Uses made of the personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or text message, certain introductions or using non-essential cookies on our website.

Purposes for which we will use your personal data

Business networking and contacts

As a part of our day to day operations we meet large numbers of business contacts at meetings and receive emails about investment opportunities. We are likely to receive and store personal information on those individuals we meet. If you have had contact with us, for example through emailing us or meeting a colleague, it is likely that we will want to make a note of that email or meeting and may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details.

We will collect and store this personal information for the purposes of:

• maintaining a record of contacts;
• providing periodic business updates;
• drawing to your attention working opportunities which may be of mutual benefit to us as described below; and
• organising meetings with you;

The personal information we hold about business contacts may be shared with:

• professional advisers;
• companies who hold or ‘process’ personal information on our behalf, or cloud based products such as Microsoft 365.

The legal basis for collecting and storing such personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.

Details suppliers and professional advisers

As a part of our day to day operations we are likely to receive and store personal information to enable us to buy office and other supplies or engage with professional advisers.

If you are a supplier or professional advisor to us, we will capture and use limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received, and commissioning further services.

The personal information we hold about suppliers and professional advisers may be shared with:

• other professional advisers;
• companies who hold or ‘process’ personal information on our behalf, or cloud based products such as Microsoft 365;

We store and process information in this way because it is necessary to:

• perform a contract to which you are likely to be a party;
• comply with a legal or regulatory obligation; and/or
• protect our legitimate interests in running and promoting our business.

Personal information collected during a transaction

We are likely to receive and store personal information as part of our evaluation of whether to proceed with a particular investment process.

If you are involved in a transaction that our funds enter into, or a potential transaction that we consider, we may store personal information relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.

We collect and store this information for the purposes of:

• evaluating a transaction and your role in it;
• executing transactions;
• managing an investment once made;
• maintaining records of investments;
• meeting regulatory and legal obligations eg KYC checks;
• safeguarding our legal rights and interests;
• seeking and receiving advice from our professional advisers, including accountant’s lawyers and other consultants; and
• providing periodic business updates, as described below

The personal information we hold about the members of a management team teams may be shared with

• professional advisers, such as accountants, lawyers or other consultants;
• financial intermediaries;
• credit and other reference agencies;
• other persons who have an interest or involvement in, or who are considering an interest or involvement in, a 6 Degrees transaction, including co-investors, other providers of finance and investors in our funds;
• companies who hold or ‘process’ personal information on our behalf, or cloud based products such as Microsoft 365.

We store and process information in this way because it is necessary to:

• perform a contract to which you are likely to be a party;
• comply with a legal or regulatory obligation; and/or
• protect our legitimate interests in running and promoting our business.

Personal data collected during visits to our website

When you interact with our digital platforms, we may also automatically collect the following information about your visit. This is primarily to help us better understand how people use our digital platforms to enable us create better content and more relevant communications:

• how you have reached our digital platform and the internet protocol (IP) address you have used
• your browser type, versions and plug-ins, and your operating system
• your journey through our digital platform, including which links you click on and any
• searches you made, how long you stayed on a page, and other page interaction information
• what content you like or share
• information collected in any forms you complete

How we will use your special category personal data

We may collect information about your race or ethnic origin to ensure meaningful equal opportunity monitoring and reporting. We will only do this where you have provided us with your explicit consent, to allow us to collect and process this type of information.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which materials may be relevant for you (we call this marketing). If you are an individual, you will receive marketing communications from us because you have requested to receive them or previously entered into a contract with us and, in each case, you have not opted out of receiving marketing.

If we are contacting you as a business then we are entitled to contact you on the basis of our legitimate interests to find potential investment opportunities for our funds to invest with marketing information provided that you have not previously opted out of receiving such communications. In some circumstances you may receive marketing communications from us if we have collected your Identity Data and Contact Data from a publicly available source, however you will always be provided with the opportunity to opt-out of receiving these communications.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting the DPO at dpenquiries@6degrees.vc at any time.

Disclosure of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above:

• any funds managed by us, any of our affiliates and any of our service providers (such as, without limitation, 6 Degrees Capital LLP, providing fund management services to us)

Selected third parties including:

• Business partners, including portfolio companies and investors, acting as processors or joint controllers based inside and outside the EU.
• Suppliers and sub-contractors acting as processors based inside and outside the EU who provide IT and systems and administration services.
• Professional advisers acting as processors or independent controllers including lawyers, bankers, auditors and insurers based in the UK, the US and other jurisdictions outside the EEA who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities, including HMRC acting as processors or joint controllers based inside and outside the EU who require reporting of processing activities in certain circumstances.
• Analytics and search engine providers based in jurisdictions both inside and outside of the EU that assist us in the improvement and optimisation of our site.

Please contact the DPO at 6 Degrees Capital BV, The Beacon, Sint-Pietersvliet 7, 2000 Antwerp (Belgium) or dpenquiries@6degrees.vc if you want further information on the 6 Degrees Group or any third party with whom we share your personal data.

We will disclose your personal data to third parties:

• • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
  • If we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of the 6 Degrees Group , our clients and investors in our funds, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

International transfers

Where we transfer personal information to other third parties outside of the EEA, we will ensure that those transfers take place in accordance with the applicable Data Protection Laws, including by entering into data transfer agreements with recipients.

• We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU.

If you would like more information about how your personal information may be transferred, please contact us using the information below : DPO at 6 Degrees Capital BV, The Beacon, Sint-Pietersvliet 7, 2000 Antwerp (Belgium) or dpenquiries@6degrees.vc if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our Data Retention Register which you can request by contacting us.

Your rights

You have the right to make a complaint at any time to the Gegevensbeschermingsautoriteit (GBA), the Belgian supervisory authority for data protection issues (https://www.gegevensbeschermingsautoriteit.be). We would, however, appreciate the chance to deal with your concerns before you approach the GBA so please contact us in the first instance. You have the right to ask us not to process your personal data for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting DPO at 6 Degrees Capital BV, The Beacon, Sint-Pietersvliet 7, 2000 Antwerp (Belgium)  or dpenquiries@6degrees.vc. Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us.

No fee usually required

You will not have to pay a fee to exercise any of your rights as set out above. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity to ensure that you do have a right to exercise any of your rights as set out above. This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

We will not usually rely on your consent as the legal basis for processing your personal data.  In the limited circumstances where we have requested you to consent to the processing of your personal data for a specific purpose, and you have provided such consent, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the DPO at 6 Degrees Capital BV, The Beacon, Sint-Pietersvliet 7, 2000 Antwerp (Belgium) or dpenquiries@6degrees.vc. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Third party sites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  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 policies.  Please check these policies before you submit any personal data to these websites.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the DPO at 6 Degrees Capital BV, The Beacon, Sint-Pietersvliet 7, 2000 Antwerp (Belgium) or dpenquiries@6degrees.vc.

This version was last updated in January 2023