Privacy Policy

DATA PRIVACY NOTICE
1. Why are you seeing this notice?
You have provided or may need to provide Personal Data to us as part of your agreement with 7 Global Capital GP S.à r.l. ("7GC").

We want you to understand how and why we use, store and otherwise process your Personal Data when you deal with us or our relevant affiliates.

This Data Privacy Notice applies to you to the extent that EU data protection legislation applies to our processing of your Personal Data or to the extent you are a resident of the EEA. If this Data Privacy Notice applies to you, you have certain rights with respect to your Personal Data which are contained in this Data Privacy Notice.

"Personal Data" has the meaning given in the EU data protection legislation and includes any information relating to an identifiable individual (such as name, address, date of birth or economic information).
2. Who is providing this notice?
This privacy statement is made on behalf of 7GC. 7GC is committed to protecting and respecting your privacy.

Where we use the terms "we", "us" and "our" in this Data Privacy Notice, we are referring to 7GC.

When you provide (or have provided) us with your Personal Data, 7GC acts as a "data controller". In simple terms, this means that:

- we "control" the Personal Data that you provide – including making sure that it is kept secure

- we make certain decisions on how to use and protect your Personal Data – but only to the extent that we have informed you about the use or are otherwise permitted by law
3. What Personal Data do we collect about you?
The types of Personal Data we process, hold and share depends on the product or service you have with us and the nature of your investment.  This can include or be related to:

- social security number and income
- assets and investment experience
- risk tolerance and transaction history
- investment activity
- accounts at other institutions
- assets

The Personal Data collected about you will help us provide you with a better service and facilitate our business relationship.  

- we may combine Personal Data that you provide to us with Personal Data that we collect from, or about you, in some circumstances

- this will include Personal Data collected in an online or offline context
4. Where do we obtain your Personal Data?
We collect, and have collected, Personal Data about you from a number of sources, including from you directly:

Personal Data that you give us:

- from the forms and any associated documentation that you complete when subscribing for an interest in 7GC. This can include information about your name, address, date of birth, passport details or other national identifier, driving licence, your national insurance or social security number and income, employment information and details about your investment or retirement portfolio(s)

- when you provide it to us in correspondence and conversations

- when you make transactions with respect to 7GC

- when you purchase securities from us and/or tell us where to send money

Personal Data we obtain from others:

- publicly available and accessible directories and sources
- bankruptcy registers
- tax authorities, including those that are based outside the EEA if you are subject to tax in another jurisdiction
- governmental and competent regulatory authorities to whom we have regulatory obligations
- credit agencies
- fraud prevention and detection agencies and organisations
5. Why do we process your Personal Data?
We process your Personal Data for the following reasons:

1) Contract

It is necessary to perform our contractual obligations with you to:

- administer, manage and set up your investor account(s) to allow you to purchase your holding (of interest) in our Fund
- meet the resulting contractual obligations we have to you
- facilitate the continuation or termination of the contractual relationship between you and 7GC
- facilitate the transfer of funds, and administering and facilitating any other transaction, between you and 7GC

2) Compliance with law

It is necessary for compliance with an applicable legal or regulatory obligation to which we are subject to:

- undertake our client and investor due diligence, and on-boarding checks
- carry out verification, know your client (KYC), terrorist financing and anti-money laundering checks
- verify the identity and addresses of our investors (and, if applicable their beneficial owners)
- comply with requests from regulatory, governmental, tax and law enforcement authorities
- surveillance and investigation
- carry out audit checks
- maintain statutory registers
- prevent and detect fraud
- sanctions

3) Our legitimite interest

For our legitimate interests or those of a third party to:

- manage and administer your holding in any funds in which you are invested, and any related accounts on an ongoing basis
- assess and process any applications or requests made by you
- open, maintain or close accounts in connection with your investment in, or withdrawal from, 7GC
- send updates, information and notices or otherwise correspond with you in connection with your investment in 7GC
- address or investigate any complaints, claims, proceedings or disputes
- provide you with, and inform you about, our investment products and services
- monitor and improve our relationships with investors
- comply with applicable regulatory obligations
- manage our risk and operations
- comply with our accounting and tax reporting requirements;
- comply with our audit requirements
- assist with internal compliance with our policies and process
- ensure appropriate group management and governance
- keep our internal records
- prepare reports on incidents / accidents
- protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes (to the extent that this is not required of us by law)
- analyse and manage commercial risks
- seek professional advice, including legal advice
- enable any actual or proposed assignee or transferee, participant or sub-participant of the partnership's or Fund vehicles' rights or obligations to evaluate proposed transactions
- facilitate business asset transactions involving 7GC partnership or Fund-related vehicles
- monitor communications to/from us using our systems
- protect the security and integrity of our IT systems

We only rely on these interests where we have considered that, on balance, our legitimate interests are not overridden by your interests, fundamental rights or freedoms.

Monitoring as described at (3) above

We monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with our regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems.  
6. Who we share your Personal Data with
Your Personal Data will be shared with:

1) Fund Associates

We share your Personal Data with our Associates and related parties. This for:  

- managing our relationship with you
- the purposes set out in this Data Privacy Notice

2) Administrator, Investment Advisor

- delivering the services you require
- managing your investment
- supporting and administering investment-related activities
- complying with applicable investment laws and regulations

3) Tax authorities

- to comply with applicable laws and regulations
- where required by EEA tax authorities (who, in turn, may share your Personal Data with foreign tax authorities)
- where required by foreign tax authorities, including outside of the EEA

4) Service Providers

- delivering and facilitating the services needed to support our business relationship with you
- supporting and administering investment-related activities

5) Our lawyers, auditors and other professional advisors

- providing you with investment-related services
- to comply with applicable legal and regulatory requirements

In exceptional circumstances, we will share your Personal Data with:

- competent regulatory, prosecuting and other governmental agencies or litigation counterparties, in any country or territory
- organisations and agencies – where we are required to do so by law
7. Do you have to provide us with this Personal Data?
Where we collect Personal Data from you, we will indicate if:

- provision of the Personal Data is necessary for our compliance with a legal obligation; or
- it is purely voluntary and there are no implications for you if you do not wish to provide us with it.

Unless otherwise indicated, you should assume that we require the Personal Data for business and/or compliance purposes.

Some of the Personal Data we request, or have requested, is necessary for us to perform our contract with you and if you do not wish to provide us with this Personal Data, it will affect our ability to provide our services to you and manage your investment.
8. Sending your Personal Data internationally
We will transfer your Personal Data to our group members, members of 7 GC’s partnership and related parties, and to third party service providers outside of the EEA, which do not have similarly strict data protection and privacy laws.

Where we transfer Personal Data to other members of our group, or our service providers, we have put in place data transfer agreements and safeguards using European Commission approved terms.

Please contact us if you would like to know more about these agreements or receive a copy of them. Please see below for our contact details.
9. Consent – and your right to withdraw it
We do not generally rely on obtaining your consent to process your Personal Data.

If we do, you have the right to withdraw this consent at any time.

Please contact us or send us an email at inquiries@7globalcapital.com at any time if you wish to
do so.
10. Retention and deletion of your Personal Data
We keep your Personal Data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us.

- we will generally retain Personal Data about you throughout the life cycle of any investment you are involved in
- some Personal Data will be retained after your relationship with us ends

As a general principle, we do not retain your Personal Data for longer than we need it.

We will usually delete your Personal Data (at the latest) after you cease to be an investor in any fund and there is no longer any legal or regulatory requirement or business purpose for retaining your Personal Data.
11. Automated decision-making
We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of Personal Data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the requirements of EU data protection legislation and other applicable laws.
12. Your rights
You have certain data protection rights, including:

- the right to access your Personal Data
- the right to restrict the use of your Personal Data
- the right to have incomplete or inaccurate Personal Data corrected
- the right to ask us to stop processing your Personal Data
- the right to require us to delete your Personal Data in some limited circumstances

From 25 May 2018, you also have the right in some circumstances to request for us to "port" your Personal Data in a portable, re-usable format to other organisations (where this is possible).
13. The use of cookies on our website
7GC uses so-called “cookies” on the website, i.e. Text files which are stored on your access device. Cookies are smaller files with text information which are stored on your hard drive during retrieval of the offer. We use cookies to make the navigation and use of our website as user-friendly as possible. After your successful login to the protected area, we require the cookies to identify and authorise you for the entire duration of your visit. We are not able to draw any references to customers with the cookies. You can deactivate the option to store these cookies at any time in the system preferences of your browser and delete any existing cookies. Every user can also view the offer without cookies. However, if you do not accept any cookies, this may lead to a functional restriction of the website.
14. The use of tracking technologies
The use of Google Analytics:

Our Website uses Google Analytics:

Web analysis services of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter: “Google”). Google Analytics use so-called “Cookies”; text files which are stored on your computer/smartphone and which enable analysis of your use of our Website and Web-App. The information generated by the Cookie about your use of our Website and Web-App is generally transmitted to a Google server in the USA and stored there. However, within member states of the European Union or in other parties to the Agreement on the European Economic Area, your IP address will be previously shortened by Google on our Website and Web-App.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and abbreviated there. Google will use this information on behalf of the operator of this Website/App to evaluate your use of the Website, in order to compile reports about the Website activities and to render further services to the Website operator connected with the Website use and internet use. The IP address transmitted by your browser within the framework of Google Analytics will not be merged with other data from Google.

You can prevent the storage of Cookies by configuring your browser software accordingly; however, we hereby point out that in this case you may not be able to use all functions of our Website fully. Furthermore, you can prevent the collection of the data generated by the Cookie related to your use of our Website (incl. IP address) by Google as well as the processing of these data by Google, by downloading and installing the browser plugin available via the following link: http://tools.google.com/dlpage/gaoptout

You can find more detailed information about this at: http://google.com/intl/de/analytics/privacyoverview.html
15. Concerns or queries
We take your concerns very seriously. We encourage you to bring it to our attention if you have any concerns about our processing your Personal Data.

This Data Privacy Notice was drafted with simplicity and clarity in mind. We are, of course, happy to provide any further information or explanation needed. Our contact details are below.

If you want to make a complaint, you can also contact the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose.  A list of the EU data protection authorities is available by clicking this link: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
16. Contact Us
Please contact us if you have any questions about this Data Privacy Notice or the Personal Data we hold about you.

Contact us by email at inquiries@7globalcapital.com.

Contact us in writing using this address:

121, avenue de la Faïencerie
L-1511 Luxembourg
Grand Duchy of Luxembourg
17. Changes to this Data Privacy Notice
We keep this Data Privacy Notice under regular review.

This Data Privacy Notice was last updated on 24 May, 2018.