The protection of your personal data is very important to us. We process your data in accordance with the EU General Data Protection Regulation (“GDPR”), and the Data Protection Act. In this data privacy notice we inform you of the most important aspects pertaining to the processing of your data, which we collect when you use our website, social media profiles, mobile apps or any other web applications. This data privacy notice also explains some of the measures used to ensure the confidentiality of the data transmitted and to protect your privacy.

This data privacy notice applies to the website published by Lightrock LLP (“Website”). We reserve the right to amend this data privacy notice without prior notice of any changes (e.g. legal circumstances, product or services offering, data processing policy). Any amendments become applicable from the time they are published on the Website. Some pages may contain links to other providers (“Third-party Providers”) within and outside Lightrock LLP, to which this data privacy notice does not apply. The conditions and data privacy notices of the respective Third-party Providers apply for the linked websites and content. We assume no liability in connection with linked third-party websites.

1. Contact with us

If you establish contact with us by e-mail or by using the contact form provided on the Website, your data are used for processing or post-processing of the inquiry, to establish contact and for technical administration purposes.

We collect and use personal data on the Website in order to improve the information, products and services provided, to further align our business processes with the needs of clients and visitors to the Website (“Visitors”) and to ensure efficient access to information.

2. Web server logs

When you use the Website, access data are stored (e.g. log files, IP address, date and time of access, name of the requested file, access status, page from which access is gained, top-level domain, web browser used, operating system used). We use these data for statistical purposes, for technical analysis, to optimize the server infrastructure, to ascertain the frequency of access and to improve user-friendliness and functionality.

3. Use of cookies

The Website uses cookies (small text files that are stored by the browser on your end device) to store access data (e.g. log files, IP address, date and time of access, name of the requested file, access status, page from which access is gained, top-level domain, web browser used, operating system used). 

We use these data to make it easier for you to use and individualize the Website, for technical analysis, to improve the server infrastructure, to ascertain the frequency of access, for statistical purposes, and to draw conclusions about improving the user-friendliness and functionality of the Website.

Some cookies remain stored on your computer until you delete them. They allow us to recognize your browser when you visit the Website again. These include, for example, cookies which are technically necessary for the functioning of the Website or which offer a service or option requested by you, e.g. a cookie that stores your personal settings, such as the language selected by you.

As we are at pains to constantly improve the Website, we use cookies for website and performance analysis, i.e. cookies that give us statistics about the total number of visitors, the pages that were visited, etc. As output we receive statistical analyses which we use to make sure that the Website design meets visitors’ needs. This does not enable our service provider to identify you or to come to any conclusions regarding your identity.

For this purpose, we use the following third-party service provider on the Website:

Google Analytics provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google")

The cookies used for analysis by Google Analytics do not contain any personal data. Your IP address is abbreviated directly on your computer. Your IP address is sent to Google Analytics in this anonymized form. Google Analytics will not link your IP address to other information held by Google Analytics and will only pass on data to third parties where this is provided for by law.

You can refuse permission for Google Analytics cookies to be used in future at any time by clicking on this opt-out link:

• Opt-out Google Analytics: https://support.google.com/analytics/answer/181881?hl=de

Please also read the information on the services and data privacy policy of Google Analytics at:

• https://support.google.com/analytics/answer/6004245?hl=de 

When visiting the Website, providers of targeting services can store temporary cookies on your computer's hard disk or your mobile device, which will be automatically deleted after a specified period. These cookies contain computer-generated alphanumeric identifiers that do not permit any conclusions about your person or the IP address of your computer. You can prevent the use of targeting cookies by changing your browser settings so that no cookies are stored.

The Website can also be used without cookies. However, the functionality of the Website may be limited if you do not allow or disable cookies. If you do not wish any cookies, you can change your browser settings to notify you when a cookie should be set, which will allow you to approve cookies on an ad hoc basis only. You can also set your web browser to automatically disable cookies. Please note that most browsers offer different options for protecting your privacy. As a rule, instructions for managing cookies in your browser are available in the browser's Help function or in the instruction manual for your computer. Instructions for disabling cookies in the most common browsers can be found at the following links:

• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
• Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

4. Incorporation of third-party services and contents and use of plugins

Third-party content and services may be incorporated into the Website (known as externally embedded components or plugins/widgets). These always require that the third-party providers of such content use Visitors’ IP addresses, as no content can be sent to the Visitor's browser without the IP address.

To enable you to share the contents of the Website via social media channels (Facebook, Twitter, etc.), a cookie has to be installed on your end device. Once you have used this function, the responsibility for further data processing lies with the respective third-party provider.

If you click on the relevant symbol, you consent to communication with the relevant platform and the transmission of information to the third-party provider in question. 

This does not apply to the following services, where data are transmitted to the relevant third-party provider without you having to click on the relevant symbol:

Google Maps provided by Google Maps (API) of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) shows our locations and makes it easier to find your way to us.

If you click on pages incorporating maps provided by Google Maps, data (e.g. IP address) are transmitted to and stored on Google's systems in the US. Google uses these data to create and analyze user profiles. If you have a Google account and are logged in to this account, your data are also linked to your Google account. You have the right to object against the creation of user profiles, which you can exercise towards Google.

You can prevent the future transmission of your data when you use Google Maps by disabling the web service of Google Maps in your browser.

Please also read the information on the services and data privacy policy of Google and Google Maps at:

• http://www.google.de/intl/de/policies/terms/regional.html
• https://www.google.com/intl/de_US/help/terms_maps.html
• http://www.google.de/intl/de/policies/privacy/ 

We have no control over the scope of the data that are collected by the relevant third-party providers with the help of their plugins or your use of websites that incorporate certain services offered by third-party providers. If you use the services of third-party providers, the relevant third-party provider is responsible for the further processing of the data.

5. Newsletter

You can subscribe to our newsletter on the Website. To this end, we require your e-mail address and potentially further information for personalization purposes as well as your confirmation that you agree to the newsletter subscription.

You can cancel your newsletter subscription with effect for the future at any time by clicking on the corresponding link in the newsletter. Your data collected in connection with the mailing of the newsletter will then be deleted, unless you have granted explicit consent to the continued use of your data or we have reserved the legal right to continue to use your data.

The mailing of our newsletters and the processing of the data of the newsletter recipients is carried out by contracted providers or their subcontractors, who are obligated to comply with the GDPR.

6. Data protection

6.1 Data processing and data storage

Due to cookies, the IP data of the owner of the connection is stored when visiting the Website. Under certain circumstances, personal data such as the Visitor's name and address may also be collected via input masks.

Visitors to the Website are informed of the collection of personal data on the respective pages. We use personal data for whose processing you have granted us consent (e.g. when subscribing to newsletters or ordering brochures) or that are necessary for the performance of a contract or the initiation of business contact.

Personal data that we collect via the Website are only used in accordance with the purpose that results from the page in question and will be stored until this purpose has been fulfilled. In the event of the conclusion of a contract, the data from the contractual relationship will be stored until the statutory retention or limitation periods have expired.

The data collected on the Website that have been entered by you are forwarded to the competent unit within Lightrock LLP. The data remain confidential during this process. The data are not disclosed to third parties, unless required (e.g. the mailing of newsletters or brochures by a provider).

The use of state-of-the-art security software and certified encoder and encryption procedures ensure that our IT infrastructure complies with international security standards. We have also implemented additional comprehensive security measures and technical as well as organizational measures to protect your data against loss, unauthorized access and misuse in accordance with state-of-the-art technology for Internet access to accounts and custody accounts.

Irrespective of the measures taken to protect your data, data protection and confidentiality may be limited when data is processed via universally accessible media. When using the Internet to send transmissions from a computer, mobile phone or another end device, it cannot by its nature be excluded that third parties can obtain access to your data and in so doing, can draw inferences concerning possible business relationships, or that personal data are transmitted to third countries without our cooperation or knowledge.

We recommend that particularly sensitive data, especially personal data and data relating to client relationships (account, custody account, transactions, etc.), be transmitted only via secure communication channels. Due to the risks involved, your entry or transmission of personal or business data within the scope of the Website or other digital services is done voluntarily and without any assurances. We do not accept any liability for direct and indirect damages arising in connection with the use of the Website, digital services or their contents.

6.2 Legal basis and purposes of processing

Your data are processed on the basis of a legitimate interest (Art. 6 para. 1 (f) GDPR) for the following purposes:

• As the operator of the Website, we have a legitimate interest in the effective design of the Website, the highest degree of stability and functionality of the Website, the statistical analysis of visitor behavior for optimization and marketing purposes, the targeted advertising or personalized direct advertising and the secure, user-friendly mailing of newsletters.
• Due to the legitimate interest of a Third-party Provider (e.g. Google) to incorporate personalized advertising based on Visitors’ surfing behavior or on market research. The Third-party Providers have undertaken to observe the Privacy Shield Framework between the EU and the US regarding the collection, use and storage of personal data from EU member states.

Where required, your data can also be processed for the purposes of performance of a contract or the initiation of business contact or on the basis of your explicit consent.

6.3 Your rights

You have the following data subject rights with regard to your personal data (Art. 15 to 21 GDPR):

• The right to information: you can request information about whether and to what extent we process your personal data.
• The right to rectification, erasure and restriction of processing: you can have inaccurate or incomplete personal data rectified or you can demand that your data be erased (e.g. if they are no longer necessary, you have withdrawn your consent, or these data are being unlawfully processed) or that the processing thereof be restricted.  
• Right of revocation: you can revoke your consent for the processing of your data at any time. The revocation of consent is only effective for the future and does not have any impact on the lawfulness of the data processed until the time of revocation. Revocation also has no impact on data processing conducted based on a different legal basis.
• Right of data portability: you can have the data which you have provided to us transmitted in a structured, commonly-used and machine-readable format. 
• Right to lodge a complaint: if you feel that your rights have been violated by our data processing, you can lodge a complaint with the Information Commissioner's Office or another supervisory authority of an EU or EEA member state (e.g. in your place of residence or work or in the place where the GDPR was violated).

The contact details of the competent supervisory authority are:

Information Commissioner's Office

Wycliffe House, Water Lane

Wilmslow, Cheshire SK9 5AF

Great Britain

Phone: +44 303 123 1113

www.ico.org.uk

6.4 Right to object

• In individual cases: if the processing of your data is carried out in the public interest or to safeguard legitimate interests by us or a third party, you can object to this processing at any time on grounds relating to your particular situation.
• Direct marketing: you can object informally to the use of your data for direct marketing purposes. In the case of such an objection from you, we shall no longer process your data for such purposes.

6.5 Contact

Please contact us at the following addresses or via the contact form if you have any questions regarding data protection or wish to exercise your rights:

Lightrock LLP

1 Eagle Place

London, SW1Y 6AF

United Kingdom

Lightrock Holding AG

Herrengasse 12

9490 Vaduz

Liechtenstein