Privacy Notice

Introduction

We process your personal data in connection with your involvement with Ture. Your privacy is important to us and we encourage you to read this privacy notice to learn more about our personal data processing.

Ture Invest Partners AB, 559251-2437 (“Ture” or “we”) is the data controller of the processing of your personal data. This means that Ture is responsible for your personal data being processed correctly and in accordance with applicable laws. If you have questions regarding your rights related to personal data, please contact us at GDPR@tureinvest.se or +46 (0) 708 87 08 83.

Legal basis and purposes

All processing of personal data must be based on one of the legal bases stipulated in the EU’s General Data Protection Regulation (the “GDPR”). The legal basis shall be determined and documented before a processing activity is initiated. In practice, we rely on three primary legal bases:

Performance of contract

Processing of personal data is conducted since it is necessary to fulfil a contract with you. This includes to conclude, execute and terminate a contract, or managing client/customer relations.

Legal obligation

Processing of personal data may be conducted if it is necessary to comply with a legal obligation, including but not limited to when we have a legal obligation (i) to file information to tax or police authorities, (ii) to perform know-your-customer (KYC) controls under anti-money laundering (AML) regulations, or (iii) to comply with book-keeping and accounting regulations.

Legitimate interest

In certain cases, we have a legitimate interest of processing your personal data. This may be the case when the processing is not required by law but is of a clear benefit to us or others. For example, we may process personal data to prevent fraud or to provide a service that our customer has asked for. When processing is based on this legal basis, a balance of interest test must be conducted where our legitimate interest and the individual’s right to privacy must be weighed against each other. The more extensive the processing activities, the more compelling the reasons must be to rely on this basis.

Please reach out to us if you want to know more about how we made the balance of interests.

Consent

In some cases, we might obtain your consent to process your personal data. The GDPR stipulates that a consent must meet certain requirements to be valid; for example, it must be documented, specific and freely given. Such requirements must be carefully considered each time consent is obtained. Before giving consent, you will be provided with information on the processing, including its purpose. You can withdraw your consent at any time.

Our data processing activities

Processing of personal data about potential investors and their representatives

We process name and contact details (including phone number, position email, address, company registration numbers) of potential investors and their representatives. As a general rule, we collect the personal data directly from you or the company you represent, but we may also receive personal data from third parties, such as public authorities or publicly available sources.

The purpose of the processing is to manage our “pre-sales” relationship, including tracking follow-ups and keep in touch regarding potential additional investment opportunities. We process personal data for these purposes based on our legitimate interest in establishing a relationship with you or the company you represent. We believe that processing of personal data for these purposes is necessary and that the purpose outweigh any opposing interests and/or fundamental rights and freedoms that you may have.

As the case may be, our investor relations (IR) representative may specifically ask whether you wish to be informed about future investment opportunities. If you agree, your personal data will be retained for a period of two years. If you decline, your personal data will be promptly removed from our systems.

Names of representatives and certain limited financial information may be processed for the purpose of transcribing internal meetings and facilitate administrative work relating to these meetings. The processing is based on our legitimate interest in improving our business and enhance efficiency and accuracy, and only involves a minimal amount of personal data which is only kept for internal purposes. The data is processed for up to one year.

Processing of personal data about investors and their representatives

We process name, contact details (e.g. phone number, position, email, address, registration numbers with the trade and companies’ registers), tax-related information and personal identification documents. If you are an individual investing in our funds, the processing of your personal data is based on our contractual obligations under the investment agreement between us, as well as our legal obligations (e.g. to maintain shareholder registers, as the case may be). For organisations investing in our funds, the processing of personal data of representatives and the organisation, as the case may be, is based on our legitimate interest and legal obligations (e.g. to be able to fulfil the agreement between us and to comply with applicable AML regulations, company law and accounting laws).

To be able to communicate with investors and their representatives, we may rely on the services of virtual data rooms (VDR) where members of our teams will have access to investors and their representatives’ contact names and email addresses. This processing is based on our legitimate interest in providing access to the VDR, coordinating investor relations and conduct our operations in an efficient way. We believe that processing is necessary for these purposes, and that these purposes outweigh any opposing interests, rights or freedoms you may have.

Personal data about you as an investor will be retained as long as the contract remains in effect. Personal data will then be retained for a period of five years after the end of the business relationship. To comply with obligations under the Accounting Act, certain information must be stored until the end of the seventh calendar year after the financial year ends.

Processing of personal data about representatives of borrowers and target companies

We process personal data of representatives of target companies and borrowers differently depending on the business relationship stage. As a general rule, we will collect personal data directly from you or the company or borrower you represent, but we may also receive personal data from third parties, such as public authorities or publicly available sources.

For target companies where Ture decides not to pursue an assessment of the investment case, we will generally not retain any personal data (such as name and contact details) of the company representatives who contacted us. Contact details that are considered relevant to save for future purposes may be retained for a maximum period of one year. The investment professional at Ture who was approached will confirm this by email to the representative.

For target companies where we proceed with an assessment of the investment case or maintain correspondence, we may process name, position, contact details, financial details and employment details (including phone number, email, address, registration numbers with trade and companies’ registers, national identification documents). The purpose of this processing is to establish and maintain our business relationship with the target company, manage ongoing dialogue, keep in touch regarding potential opportunities and to conduct our business operations in compliance with applicable requirements. We consider this processing to be necessary and justified by our legitimate interest. We think the purpose outweighs any opposing interests and/or fundamental rights and freedoms you may have.

For companies with which we enter into loan agreements, the processing of personal data is based on our legitimate interest in connection with carrying out contractual obligations under those agreements, and to comply with applicable AML and accounting laws. We process name, position and contact details (e.g phone number, email, address and registration numbers with trade and companies’ registers), tax-related information and personal identification documents.

As a representative of a company and/or borrower, your personal data will be retained for as long as you represent the company and/or the contract remains in effect. After the end of the business relationship, personal data will be retained for a period of 5 years. To comply with the Accounting Act, certain information must be stored until the end of the seventh calendar year after the financial year ends.

Processing of personal data about representatives of contractors and business contacts

We process name, position and contact details (e.g. phone number, email and address) of representatives of contractors and business contacts. As a general rule, we will collect the personal data from you or the company that you represent, but may also receive personal data from third parties, such as public authorities or publicly available sources.

The purpose of the processing of the personal data is to maintain and communicate with contractors, business contacts or others that contact us. The processing is based on our legitimate interest in connection with retaining a service and/or carrying out our contractual obligations as well as our legal obligations under AML and accounting laws.

The personal data about representatives of contractors and business contacts will be retained as long as you represent the company and/or as long as the contract remains in effect. Personal data will then be retained for a period of five years after the end of the business relationship. This processing of personal data is also necessary for us to fulfil our obligations according to accounting laws. To comply with the Accounting Act, certain information must be stored until the end of the seventh calendar year after the financial year ends.

Processing of personal data about candidates who apply for a position at Ture

We process personal data relevant for our recruitment process. This includes name, current position, contact details (phone number, email and address), national identification documents, picture, information on education, work experiences and other relevant experiences (including information in cover letter and CV), answers to questions during the recruitment process, preferences with regards to job opportunities and financial information (e.g. salary).

As a general rule, we will collect the personal data directly from you but we may also collect personal data from third parties or publicly available sources, such as LinkedIn, Google and sanction lists. You are never required to provide us with your personal data, but the personal data may be necessary for us to carry out the recruitment process. If you do not allow us to process necessary personal data, we may not be able to proceed with the recruitment process.

Our processing is based on our legitimate interest to carry out the recruitment process as well as our legal obligation to retain certain recruitment data under discrimination laws. We consider that the processing of personal data is necessary for this purpose and that our interests in processing candidates’ personal data for this purpose are aligned with the candidates’ own interests in participating in the recruitment process. We believe that the purpose outweigh any opposing interests and/or fundamental rights and freedoms the candidate may have.

Personal data will be processed and stored as long as you participate in the recruitment process. If you are offered a position, you will be informed of the continued processing of the personal data when signing the employment contract. If you are not offered a position, certain personal data will be retained for two years to comply with discrimination laws. If you agree to be contacted regarding future job opportunities, your personal data will be retained for a period of one year. You may withdraw your consent at any time.

Processing of personal data about other representatives and people who contact us

We process your name and contact details (phone number, email and address) when you contact us in a business related matter. As a general rule, we will collect the personal data from you or the company you represent.

We process your personal data to establish and maintain business relationships and conduct our operations, within the ordinary course of business (for example if we require your services in the future). The processing is based on our legitimate interests and we believe that the purpose outweighs any opposing interests and/or fundamental rights and freedoms you may have.

Personal data will be retained for a maximum period of one year after our last interaction.

Are you required to provide us with your personal data?

Although you are not legally required to provide us with your personal data, we are sometimes required by law to process personal data relating to you for certain purposes, such as investment screening, KYC and screening against export control and sanctions lists. If you do not allow us to process your personal data, we may not be able to provide you with our services or proceed with our relationship.

Who has access to your personal data?

We have implemented technical and organisational measures to appropriately protect your personal data against loss, accidental and unlawful access and unauthorised disclosure. The number of persons with access to your personal data is limited and shared on a need-to-know basis (in accordance with the purposes above).

We may use personal data processors to process personal data on our behalf. This includes fund administrators, banks, IT suppliers, advisors and other subcontractors. We also disclose your personal data when required by law or by decision of the authorities (e.g. police authorities, auditors, tax and supervisory authorities).

As a main rule, recipients of the personal data should be based within the EU/EEA. In the event we would transfer your personal data to recipients outside the EU/EEA, which may have a lower level of protection of personal data, such transfers would be based on our legitimate interest in fulfilling the purposes provided above in the most efficient and convenient way and complying with applicable legal obligations.

We will always ensure that any transfer of personal data is lawful and that we maintain the protection of your personal data through contractual obligations or equivalent measures.

What are your rights?

You have various rights when we process personal data about you, including (under certain circumstances):

right to receive information on the personal data we process on you and obtain register extracts of your personal data (including purpose, categories of personal data, recipients, retention period and any automated decision-making),
right to have inaccurate data rectified,
right to object (when we process personal data based on our legitimate interest, you have the right to object to the processing at any time),
right to require us to restrict our processing of your personal data if, for example, you consider it to be inaccurate,
right to erasure (e.g. if you consider the personal data is no longer necessary for the purposes or if you want to withdraw a consent), and
right to have your personal data transferred to another company (data portability).

You have the right to complain to us and to the supervisory authority, the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, “IMY”), on how we process your personal data. For more information on how to lodge a complaint, please visit: https://www.imy.se/privatperson/utfora-arenden/lamna-ett-klagomal/

Contact

If you wish to exercise any of the rights or if you have any questions regarding our processing of your personal data, please contact us at:

Ture Invest Partners AB
Address: Nybrogatan 7, 114 34 Stockholm
Phone: +46(0)708 870 883
Email: GDPR@tureinvest.se

A request will be handled as quickly as possible and you will receive a response no later than one month from the date of receipt of your request (unless we inform you that we have a right to extend the deadline by a further two months).

Cookies

We use a limited number of cookies on our website, www.tureinvest.se. Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and create a better user experience by enabling websites to remember visitors and their actions and preferences.

We use the following types of cookies:

(i) Necessary cookies (session cookies) or similar technologies to make our website work in a good way for you. Necessary cookies means that information will only be processed during the time you are on the website. They are necessary to be able to display the website in a user-friendly way, for example to let you choose the language.

(ii) Analytical/Performance cookies are used to measure and improve the performance of our website and understand how visitors use our website. Information for this purpose will be stored during a longer period. The information is aggregated for all users and anonymous, i.e. it can never be linked to you. If you do not accept these cookies, some features may stop working.

We may use third-party cookies on our website, such as Google Analytics. These cookies are set by other domains or websites, and we do not have control over them.

The collection of cookies is a data processing activity and you as user may give your consent to the use of cookies. You can choose to accept only the necessary cookies and you can always withdraw your choice of cookies (however, necessary cookies cannot be rejected). All cookies except essential cookies are deleted.

The following cookies are used by TureInvest.se:

Necessary.
Crumb. Deletes after session. Domain is www.tureinvest.se
_cvr. Information about company. Stored for 13 months. Domain is www.tureinvest.se
_cvt. Deletes after 24 hours. Domain is www.tureinvest.se

Others:

_ga Used to distinguish users for Google Analytics. Expires after 2 years.
_gid Used to distinguish users and store random IDs and information about users for Google Analytics. Expires after 1 day.
_gat Used to distinguish users in Google Analytics. Expires after 1 day.
MSO Microsoft. Expires after 24 hours.
MUID Microsoft. Expires after 9 months.
MC1 Microsoft. Expires after 6 months.

For more information, please visit:

Changes

We are constantly working to improve and develop our business and we may therefore make changes to this data privacy notice from time to time. The latest version is always published on our website, www.tureinvest.se.