Frog Capital is committed to the following policies that protect your privacy and comply with current international data protection laws and regulations with respect to personal data (i.e. cookies).

Please find below our privacy and cookie policies:

Privacy

Frog Capital respects your privacy. This Data Protection Policy (the Policy) describes how we process personal data, which personal data we collect and why we collect it, with whom we share this personal data, how we protect it, and the choices you can make about how we use your personal data.

This Policy applies to any personal data collected, held or processed by or on behalf of Frog Capital, relating to any individual in his or her dealings with Frog Capital as investee, stakeholder or member of the general public.

The scope of this Policy also includes all the websites, sponsored social media platforms and any other online initiatives that are owned by Frog Capital, where personal data is processed. Unless an express consent is required by the data privacy laws of your country, by using our media platforms, you consent to the collection and use of your personal information by us as described in this Policy. If you chose not to provide us with your personal information, in most cases, we will not be able to provide you with information about Frog Capital.

The requirements of this Policy are in addition to, not in substitution for, any other requirements under the applicable data protection laws and regulations. In case of conflict between the applicable data protection laws and regulations and the provisions of this Policy, the applicable data protection laws and regulations shall prevail.

Contents

  1. Definitions
  2. Key policy principles
  3. Data collection
  4. How we use personal data
  5. Marketing
  6. How long we keep your data
  7. Disclosure of personal data
  8. Disclosures outside the EU/EEA
  9. Social Media Platforms
  10. Where we store personal data
  11. Data Security
  12. Data Compliance Officer (DCO)
  13. Use of cookies or similar devices
  14. Your choices and your rights
  15. Changes to this policy
  16. Contact

1. Definitions

1.1 In this Policy, the following terms shall have the following meanings:

  • Data Controller means the organisation which determines the purposes for which, and the manner in which, any Personal Data is Processed. For the purposes of this Policy, the Data Controller(s) is Frog Capital Limited, a Private limited Company registered in England and Wales with the registered number 06812490 and registered office address at The Mews, 1a Birkenhead Street, London, WC1H 8BA.
  • Data Processor means the individual and/or organisation which Processes Personal Data on behalf of the Data Controller.
  • Data Compliance Officer or DCO means the data compliance officer nominated by Frog Capital to be the contact point for data compliance, but without the obligations of a Data Protection Officer applicable under the GDP Regulation 2016
  • Data Subjects means all individuals about whom Frog Capital holds Personal Data.
  • EEA means the European Economic Area (which is composed of the EU Member States and Iceland, Norway, and Liechtenstein).
  • Personal Data is any data relating to a living individual which allows the individual to be identified, whether from the data alone, or in combination with other information. A description of the Personal Data Processed by Frog Capital is set out below.
  • Processing means any operation or set of operations which is performed upon Personal Data, such as the collection, recording, organization, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction of Personal Data.
  • Sensitive Personal Data means, among others, Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the Processing of data concerning health or sex life. Special provisions apply to the Processing of Sensitive Data.

2. Key policy principles

2.1 We value the Personal Data entrusted to us and we are committed to Processing Personal Data in a fair, transparent and secure way. The key principles of this Policy are as follows:

  • Data collection: we will only collect Personal Data by fair, lawful and transparent means.
  • Data minimization: we will limit the collection of Personal Data to what is directly relevant and necessary for the purposes set out in this Policy.
  • Purpose limitation: we will only Process your Personal Data for specified, explicit and legitimate purposes and not further Process your Personal Data in a way incompatible with those purposes.
  • Accuracy: we will keep your Personal Data accurate.
  • Data security: we will implement appropriate technical and organisational measures to ensure an appropriate level of security in relation to the risks represented by the Processing and the nature of the Personal Data to be protected. Such measures provide for the prevention of any unauthorised disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of Processing.
  • Access and rectification: we will Process your Personal Data in line with your privacy rights.
  • Retention: we will retain your Personal Data in a manner consistent with the applicable data protection laws and regulations. In any event, we will not keep your Personal Data longer than is necessary for the purposes set out in this Policy.
  • International transfers: we will ensure that any Personal Data transferred outside the EU/EEA is adequately protected.
  • Third parties: we will ensure that access to and transfers of Personal Data to third parties are carried out in accordance with the applicable laws and regulations and with suitable contractual safeguards.
  • Direct marketing and cookies: where we send you promotional materials or place cookies on your computer, we will ensure that we do so in accordance with the applicable laws.

3. Data collection

3.1 We collect and process the following personal data relating to you:

  • your name, contact details and other information contained in communications you send to us or that you provide to us when you contact us (by email or telephone or in person), for example to request our news and updates or to submit a query or comment regarding the Website or its content or to apply for a job;
  • data collected by us in our capacity as an investment manager, investment adviser, administrator, company secretary and promoter. This may include data collected in connection with the business of making investments, for example personal due diligence checks (which may include references and credit checks), or in connection with fundraising activities; and
  • data from surveys that we may, from time to time, conduct with our suppliers for research purposes, if you choose to respond to, or participate in, them.

3.2 We also collect personal data automatically when you use the Website and when you navigate through the Website via cookies. Cookies are used to collect technical information about the services that you use, and how you use them.

4. How we use personal data

4.1 Frog Capital may Process the Personal Data for the purposes of our legitimate interests as follows:

  • to respond to your queries;
  • to provide you with information, products or services that you request from us or which we feel may interest you, where you have expressly consented to be contacted for such purposes (please see paragraph entitled “Marketing” for further information);
  • to undertake due diligence and manage investments in our capacity as an investment manager and investment adviser;
  • to contact current or potential limited partners in current or future Frog Capital funds;
  • to ensure that content from the Website is presented in the most effective manner for you and for your computer for device rendering purposes;
  • to prepare anonymised data sets;
  • to notify you about changes to the Website and the materials on the Website;
  • as part of our efforts to keep the Website safe and secure; and
  • for any other purposes that you would reasonably expect.

4.2 Frog Capital shall only Process Personal Data to the extent that it is required for the Purposes and for any other purpose specifically permitted by the applicable data protection laws and regulations.

4.3 To the extent required under the applicable data protection laws and regulations, Frog Capital shall notify the Processing of Personal Data to the relevant authorities.

5. How long we keep your data

5.1 We will keep your personal data for as long as we need it for the purpose it is being processed for.

6. Marketing

6.1 We will only send you marketing material if either you have consented to us or that it is in your interest for us to reasonably expect to be sending you marketing material for your benefit.

6.2 When we send you marketing material, we may monitor whether or not you open and/or click on the material that we send you.

6.3 If you have consented to receive marketing material from us, you have the right at any time to ask us not to process personal data relating to you for marketing purposes.

7. Disclosure of personal data

7.1 We may disclose personal data relating to you to third parties in certain circumstances including (but not limited to) the following:

  • our third party service providers, such as those we engage to host and maintain the Website, our IT systems and to assist us with marketing campaigns;
  • analytics and search engine service providers that assist us in the improvement and optimisation of this Website;
  • to the extent that it is connected with investment activity, with due diligence providers, prospective or actual investee companies and co-investors;
  • law enforcement bodies, Courts of law or as otherwise required or authorised by law; and
  • regulatory, trade association or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies.

7.2 We may also disclose personal data to third parties if we are under a duty to disclose or share personal data relating to you in order to comply with any legal obligation, or in order to enforce or apply our website Terms of Use and other agreements; or to protect the rights, property, or safety of us, our clients, or others.

7.3 Before we disclose personal data to a third party, we take steps to ensure that the third party will protect personal data in accordance with applicable privacy laws and in a manner consistent with this policy. Third parties are required to restrict their use of this personal data to the purpose for which the data was provided.

8. Disclosures outside the EU/EEA

8.1 Your Personal Data may be transferred to any of the recipients identified in this Policy, some of which may be outside the EU/EEA and may be Processed by us and any of these recipients in any country worldwide. The countries to which your Personal Data is transferred may not offer an adequate level of protection. In connection with any transfer of Personal Data to countries that do not offer the same level of protection as in the EU/EEA, Frog Capital shall implement appropriate measures to ensure an adequate level of protection of your Personal Data.

9. Social Media Platforms

9.1 Communication, engagement and actions taken through external social media platforms which Frog Capital attends are subject to the terms and conditions as well as the privacy policies of those social media platforms.

9.2 This Website may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion. You should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these social media platforms.

10. Where we store personal data

10.1 If you live in the EU, the personal data relating to you that we collect may be transferred to, and stored at, locations outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers.

10.2 As described in this Privacy Policy, we may also share personal data relating to you with third parties who are located overseas, for business purposes and operational, support and continuity purposes, for example, when we use IT service providers or data storage services.

10.3 Countries where personal data relating to you may be stored and/or processed, or where recipients of personal data relating to you may be located, may have data protection laws which differ to the data protection laws in your country of residence.  By submitting your personal data, you accept that personal data relating to you may be transferred, stored or processed in this way. We will take all steps reasonably necessary to ensure that the recipients of your data will treat that data securely and in accordance with this policy.

11. Data Security

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

11.2 The security of personal data regarding you is a high priority. We take such steps as are reasonable to securely store personal data regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:

  • storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
  • using industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology;
  • restrictions are placed on the electronic transfer of files; and
  • our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.

11.3 We take steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law to retain the information.

12. Data Compliance Officer (DCO)

12.1 Frog Capital have nominated a Data Compliance Officer to assist with the lawful processing of personal data.

12.2 If you have a query in relation to this Policy or our Processing of your Personal Data, you can contact the Data Compliance Officer via steven.dunne@frogcapital.com.

13. Use of cookies or similar devices

13.1 We use cookies on our websites.

13.2 For further information about our use of cookies and on how to avoid them, please consult our privacy statement on our website.

14. Your choices and your rights

We want to be as transparent possible with you, so that you can make meaningful choices about how you want us to use your information.

We can contact you by post and by phone, and if you give us your prior consent to do so, by email, SMS and other electronics means.

14.1 Your choices:

In this context, you can make a variety of choices about how you want to be contacted by us, through which channel (e.g. email, mail, Social Media, …), for which purpose and how frequently, by adjusting the privacy setting on the relevant device or updating your user or account profile or by following the unsubscribe instructions included in the communication.

Please note that by default, if you don’t make a choice, you will receive our promotional communications at the following frequency: at date of publication.

14.2 Your personal information

You may always contact us by post or email to find out what personal information we have concerning you and the origin of these.

14.3 Your corrections

If you find any mistake in your personal information or if you find it incomplete or incorrect, you may also require from us that we correct it or complete it.

14.3 Your objections

You may also object to the use of your data for direct marketing purposes (if you prefer, you can also advise us on which channel and how frequently you prefer to be contacted by us).

14.4 Your rights

If you think that any of your rights have been infringed by us, you have the right to lodge a complaint with the relevant data protection regulator.

Finally, you may request for us to erase any data concerning you (except in some cases, for example to provide proof of a transaction or when required by law).

15. Changes to this policy

15.1 We review and amend our Privacy Policy from time to time.  Any changes we make to this 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 this policy.  The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Website.

16. Contact

16.1 For any privacy issues, questions or complaints concerning the application of this Policy or to exercise your rights of access or rectification within the context of this Policy, you may contact Frog Capital at steven.dunne@frogcapital.com.

Cookie Policy

Cookies are small text files stored on your computing device when you visit the Frog Capital website and may be used to enable the website to run effectively or to identify your device whenever you return to the website.

Measuring Google Analytics

We use first-party Google Analytics cookies to track anonymous usage statistics and do not collect any personal information that can be used to identify you. This helps us analyse data about webpage usage and improve our website in order to tailor it to customer needs. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. We do not allow Google to use or share our analytics data.

These are the specific cookies we employ on our website:

_COOKIEPURPOSEEXPIRES
_atuvsThis cookie is associated with the AddThis social sharing widget which is commonly embedded in websites to enable visitors to share content with a range of networking and sharing platforms. This is believed to be a new cookie from AddThis which is not yet documented, but has been categorised on the assumption it serves a similar purpose to other cookies set by the service.2 years from now
_atuvcUsed to show you an updated share count for an article, if you yourself share it and return to the page later, but before the sharing cache was updated. No info from this cookie sent back to AddThis. It is created and used only on the client.2 years from now
_atsscUsed to manage the share count, until the sharing cache is updates2 years from now
_utmaUsed to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.2 years from now
_utmbUsed to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.30 minutes from now
_utmcNot used in ga.js. Set for interoperability with urchin.js. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit.When you quit your browser
_utmtUsed to throttle request rate.10 minutes from now
_utmzStores the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.6 months from now

Google Analytics does not collect any personal information, as identified in their privacy policy. Google also offers a browser plugin that allows users to opt out of their analytics. For further information about Google Analytics, visit: Google’s Privacy Policy – https://policies.google.com/privacy?hl=en Google Analytics Help pages – https://developers.google.com/analytics/devguides/collection/analyticsjs…

Social Media website cookies

Users can ‘like’ or share our content on the likes of LinkedIn and Twitter where we have included sharing buttons on our site. The privacy implications for this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks. More information about cookies All About Cookies – http://www.allaboutcookies.org/

How do I manage cookies or turn them off?

You can manage the cookies stored on your computer, or turn them off completely, through your browser settings. All modern browsers will let you change your cookie settings to give you broad control over whether cookies can be set or not. For more information, visit the help section for the browser you use. Here are a few of the most popular: Cookie settings in Internet Explorer – https://support.microsoft.com/en-gb/help/196955 Cookie settings in Firefox – https://support.mozilla.org/en-US/kb/cookies-information-websites-store-… Cookie settings in Chrome – https://support.google.com/chrome/answer/95647?hl=en Cookie settings in Safari – https://support.apple.com/?path=Safari/3.0/en/9277.html