Who is Holocene Impact Capital?

“Holocene Impact Capital” or “HIC” means:
Holocene Impact Capital Sàrl, registered at Rue de la Cité 1, 1204 Genève, Switzerland. Incorporation number CHE -474.514.185.

“Holocene Impact Capital UK” or “HIC UK” means:
Holocene Impact Capital UK Limited, registered at 1 Ropemaker St, London, United Kingdom, EC2Y 9HT. Incorporation number 14189913.

Holocene Impact Capital Sàrl can be reached on [email protected] or +41 78 737 64 24.

Holocene Impact Capital UK Limited can be reached on [email protected] or +41 78 737 64 24. HIC and HIC UK are personal data controllers under General Data Protection Regulation (“GDPR”).

Why do you collect information about me? What information will you collect?

There are a number of reasons why HIC and HIC UK collect information. We need to know how to contact you, we need to be certain of your identity and we need to understand your circumstances so that we can offer you the best possible customer experience.
The type of information that HIC and HIC UK may collect from you includes:

Your identity & contact name, copies of ID (which may include your date of birth), national identity number, details around your assets and liabilities, IP addresses, cookie identifiers, email addresses and contact phone numbers.

Bank account details, credit/debit card details, authorised signatory details, and information relating to power of attorney arrangements.

Information which you have consented to us using, such as allowing us to contact you and send you product related communications on a periodic basis. We also collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers. A cookie is a little piece of text that our server places on your device when you visit any of our websites or apps. A cookie helps us make our website work better for you.

We use (i) technologies to automatically collect information about your internet browser settings, browser user agent, Internet Protocol (IP) address, login information, and location-based data and (ii) Google Analytics to improve our website offerings to you and to enhance your online visit to us. We will also hold information on data access, correction, restriction, deletion, porting and complaints relating to you.

How do you collect information about me? And when do you do so?

We collect information about you in a number of different ways. Some examples include:

When you register with us to receive business related updates.

When you make a request to be added to our marketing database.

When you use our website. When you or others give us information verbally or in writing. This information may be by way of registration forms, viewing attendee sheets, through correspondence with us or if you make a complaint, or from your online activities with third parties where you have given us your consent (e.g., by consenting to our use of certain cookies or other location tracking technologies).

How do you use my information?

We may use your personal data for matters such as confirming your identity, to help us in the processing of an application for one of our services or to improve your customer experience with us.

Your data is used to manage and administer your account. Your data can also used to process transactions. For example, if you have provided us with your credit or debit card information or if you have provided us with your bank account details.

We may use your data to contact you by post, phone, text message, email or social media using our website or other means, but not in a way that is contrary to your instructions to us, legitimate interest or contrary to law. Your data may also be used to recover debts you may owe and also to manage and respond to a complaint or appeal that you have.

We may also use your data to manage our business for our legitimate interests, such as to conduct marketing activities in a form of a direct marketing (provided, that it is allowed or you consented to such online activity) and research, including customer surveys, analytics and related activities.

Your data may be used to carry out strategic planning and business portfolio management. This could include compiling and processing your information for audit, statistical or research purposes (including, in some instances, making your data anonymous) in order to help us understand our customers’ behaviour, background and needs.

We protect your information with security measures under laws that apply. We strive to keep our equipment, files and buildings secure. Personal data could be used to prevent and detect fraud, dishonesty and other crimes (such as preventing someone trying to steal your identity). We need to use your information to manage and administer legal and compliance matters within HIC and HIC UK, including compliance with regulatory, legislative and internal codes of practice. We use your data to comply with your information rights, to establish your identity and to comply with laws and regulations concerning the prevention of money laundering, fraud and terrorist financing. As a result, we may need to disclose information to government and other statutory bodies.

Does HIC use automated processing or analytics? What is the legal basis?

We do not use automated processing in relation to the information we collect from you as part of our business.
HIC and HIC UK uses Google Analytics for statistical purposes.

This enables us to make more informed business decisions, including improving the quality of services we can offer.

Do you share my information with anyone else?

We only share your information with a certain number of other parties and only as necessary. Examples of information sharing here include sharing with:
Your authorised representatives. This would include your Attorney (under a Power of Attorney) and any other party authorised by you to receive your personal data.

Third parties we need to share your information with in order to facilitate payments (for example, stripe, SWIFT, credit card issuers and merchant banks) and those you ask us to share your information with.
A potential counterparty in case you are interested in the execution of a transaction with our support. This will be done on a need-to-know basis and after your consent is provided.

Companies that provide support services for the purposes of protecting our legitimate interests. Your personal information remains protected when our service providers use it. We only permit service providers to use your information in accordance with our instructions, and if they have appropriate measures in place to protect your information. Our service providers include marketing and market research companies, IT and telecommunication service providers, software development contractors, data processors, debit/credit card companies, computer maintenance contractors, document storage and destruction companies, business advisers, debt collection agencies, auditors and other consultants, including legal advisers. Statutory and regulatory bodies (including central and local government) and law enforcement authorities.

How long does HIC hold onto my information?

The length of time we hold your data depends on a number of factors, such as regulatory and statutory requirements. Other considerations are the type of data we hold about you, whether the data is required for a legal dispute and whether you or a regulatory authority asks us to keep it for a valid reason.

As a general rule, we keep your information while a contract with you is in force or there is a valid ground for any claims afterwards.

What happens if I do not provide requested information to HIC?

Sharing information with us is in both your interest and ours. We need your information in order to provide our services to you, fulfil any contracts we have with you, manage our business for our legitimate interests and comply with our legal obligations.

You can choose not to share information with us, but must understand that this may limit the services we are able to provide to you. We may not be able to provide you with certain services that you request.

What is the legal basis for HIC using my information?

We will use your data and may share that data where:
Its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so that you can enter into a contract with us or so that we can provide a service to you.

Its use is in accordance with our legitimate interests. When we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms. We may use your personal information to manage our everyday business needs including internal reporting, market research, to progress and respond to legal claims, to ensure appropriate IT security and to prevent fraud. Our legitimate interest here is the effective management of our business. We may use your personal information for marketing reasons (i.e., to update you in regarding to property related matters). Our legitimate interest here is to connect with you and to update you on properties and services we provide which may be of interest to you.

Its use is necessary because of a legal obligation that applies to us, in particular with respect to “know your client”, “anti money laundering” and tax related purposes.

You have consented to the using of your data (including special categories of data) in a specific way.
Where you have made clearly sensitive categories of data about yourself public. Where the processing of special categories of data is necessary for the establishment, exercise or defence of legal claims.

Does HIC process my information outside of Switzerland (“CH”) or the European Economic Area (“EEA”)?

Your information is stored on secure systems within the premises of HIC and HIC UK and with providers of secure information storage. HIC and HIC UK do not transfer information about you outside of CH or the EEA.

We may allow the transfer of information about you outside of CH or the EEA by our service providers, but only if they agree to act solely on our instructions and to protect your information to the same standard that applies inside of CH and the EEA. Where we authorise the processing/transfer of your personal information outside of CH or the EEA, we require your personal information to be protected to standards stemming from GDPR and the Swiss Data Protection Act (DPA).

What rights do I have under the DPA and the GDPR?

You have several rights in relation to how we use your information and we have significant obligations in this regard.

You have the right to:

  • Find out if we use your information, to access your information and to receive copies of the information we have about you. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your data. If you make your request electronically, we will, where possible, provide the relevant information electronically, unless you ask us otherwise.
  • Request that inaccurate information is corrected and incomplete information updated.
  • Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests. However, doing so may have an impact on the services we can / are willing to provide.
  • Object to the use of your personal data for direct marketing purposes.
  • Have your data deleted or its use restricted – you have a right to this under certain circumstances.
  • Obtain a transferable copy of certain data, which can be transferred to another provider, known as “the right to data portability”. This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. This right also permits the transfer of data directly to another provider where technically feasible.
  • Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
  • Have your request processed without undue delay. In most instances, we will respond within one calendar month. If we are unable to fully deal with your request within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar month period. Should this be necessary, we will explain the reasons why.

Complain to the competent data protection authority. If you have a complaint about the use of your personal information, please let HIC or HIC UK know first and we shall seek to resolve your issue as soon as possible. Please be assured that all complaints received by us will be fully investigated. We ask that you supply as much information as possible to help us to resolve your complaint quickly.

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