PRIVACY NOTICE FOR CUSTOMERS OF GREEN EIGHT CAPITAL AG AND ITS AFFILIATES
WHAT DOES GREEN EIGHT DO WITH YOUR PERSONAL INFORMATION?
Financial companies choose how they share your personal information. This notice (this “Privacy Notice”) is provided by Green Eight Capital AG (together with each of the private investment funds and accounts it advises, and other affiliates and related entities, “Green Eight,” “we,” “our,” or “us”), and sets forth Green Eight’s policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of your personal data as a current, prospective or former investor, as applicable. This Privacy Notice is being provided in accordance with the requirements of applicable data privacy laws, including the EU General Data Protection Regulation 2016/679 (“EU GDPR”), the UK GDPR (as defined below) the US Gramm-Leach-Bliley Act of 1999, as amended (with any implementing regulations, “GLBA”), the Swiss Data Protection Act of 1st September 2023 (“FADP”), as amended from time to time, and the Data Protection Act (“DPA”) of the Cayman Islands, as amended. References to “you” or an “investor” in this Privacy Notice means any current, prospective or former investor, managed account client, as applicable, who is an individual, or any individual connected with the foregoing who is a legal person. For the purposes of the DPA, the Fund is the data controller. U.S. federal law gives you the right to limit some but not all sharing. U.S. federal law also requires us to tell you how we collect, share, and protect your personal information. The rights discussed in certain sections of this Privacy Notice may be subject to exemptions or other limitations under applicable law. Please read this Privacy Notice carefully to understand what Green Eight does.
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) and subject to the EU GDPR or the EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (the “UK GDPR”, and, together with the EU GDPR, the “GDPR”), or if you are located in Switzerland and subject to the Swiss FADP effective from 1st September 2023, or if you are an investor who is, or is associated with investors in our funds based in the Cayman Islands (the “Cayman Funds”) and subject to the DPA, and any other applicable law relating to privacy or the processing of personal data and any statutory instrument, order, rule or regulation implemented thereunder, each as applicable to Green Eight (collectively “Data Protection Laws”), please review this Privacy Notice and see the below section, “Additional Information for EEA, UK and Swiss Data Subjects and Cayman Investors,” for a description of your rights and other information related to the GDPR, FADP and DPA.
We do not disclose non-public personal information about our clients or former clients to third parties other than as described below.
Personal information we collect. We collect and/or may have visibility to, personal information about you in connection with our providing advisory services to you. This information may include, without limitation, your social security number and may include other information such as your:
Assets;
Investment experience;
Transaction history;
Income; and
Wire transfer instructions.
How we collect this information. We collect this information from you through various means. For example, when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies[1].
How we use this information. All financial companies need to share customers’ personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:
To provide advisory services to you.
To open an account for you.
To process a transaction for your account.
To market products and services to you.
To respond to court orders and legal investigations.
Disclosure to others. We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. Such service providers will process such information for the purposes of carrying out its services and may disclose such information pursuant to the guidelines set forth in Green Eight’s privacy policy. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between non-affiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).
How we protect your personal information. To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include:
- designating employees responsible for the security program;
- identifying and assessing security risks;
- developing policies for the storage, access, and transportation of personal data;
- imposing disciplinary measures for violations of the security program, as appropriate;
- limiting access by terminated employees;
- overseeing the practices of third-party vendors;
- restricting physical access to records;
- monitoring and reviewing the scope and effectiveness of the security program; and
- documenting steps taken in response to data security incidents.
Our computer system security standards include:
- securing user credentials;
- restricting access to personal data on a need-to-know basis;
- monitoring of security systems;
- updating firewalls, security patches, anti-virus, and anti-malware software; and
- training employees on the proper use of the computer security systems.
To protect your personal data, we permit access only by authorised employees who need access to that information in order to perform their jobs. Such staff members primarily include investor relations, legal, compliance, operations, product control, finance and administrative staff.
Who is providing this Privacy Notice. This Privacy Notice relates to the following entities:
Green Eight Capital AG
G8C General Partner S.a.r.l.
Green Eight Capital International Corp.
Green Eight Capital Real Invest GmbH
Innovation Aerospace Fund SCA SICAV-RAIF
Green Eight Capital Private Markets Fund 1
Additional Information for EEA, UK and Swiss Data Subjects and Cayman Investors. Data Protection Laws impose certain obligations on us and grants certain rights to data subjects or individuals covered by those laws. For purposes of the GDPR and FADP, we are a “controller” and for purposes of the DPA we are a “data controller.” “Personal data” and other terms as used in this section have the same meaning provided in the Data Protection Laws.
Legal Basis
As described above, we process personal data for various purposes. Our lawful basis for processing such personal data include: (i) where it is necessary for our legitimate interests in connection with our investment advisory business (or those of a third party) and your interests and fundamental rights do not override those interests; (ii) to comply with certain legal and regulatory requirements; (iii) depending on the circumstances, we may need to process your personal data for the performance of a contract to which you are a party, or related pre-contractual steps; and (iv) with your consent, as required by the GDPR, FADP and DPA (as applicable).
Your Rights Under Data Protection Laws
Data subjects in the EEA, the UK and Switzerland have certain rights under GDPR or FADP (and, as applicable, the DPA) in relation to our processing of their personal data and these are, generally: (i) the right to request access to their personal data; (ii) the right to request rectification of their personal data; (iii) in certain circumstances the right to request erasure of their personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of direct marketing activities); (vi) where relevant, the right to request data portability; (vii) where their consent to processing has been obtained, the right to withdraw their consent at any time; and (viii) the right to lodge a complaint with a supervisory authority (including, if applicable, the Cayman Islands Ombudsman who may be contacted at info@ombudsman.ky or the relevant EU member state or UK or Swiss data protection authorities). Please note that the right to be forgotten that applies in certain circumstances under the GDPR or FADP is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above. You can exercise these rights by contacting us at:
USA, EU, UK, CAYMAN:
By Post:
570 Lexington Ave 34th Floor, New York, New York, USA 10022
By email: Santiago@g8c.com
SWITZERLAND
By post: Avenue Villamont 17, 1005 Lausanne, Switzerland.
By email: g8c.CHdpRep@waystone.com
Further Information. Green Eight reserves the right to change or revoke this Privacy Notice at any time. If Green Eight changes its privacy policies to permit it or its affiliates or associated entities to share additional information Green Eight has about clients or to permit disclosures to parties other than those described herein, customers will be notified in advance, and, if required by law, will be given the opportunity to opt out of such additional disclosure and to direct Green Eight not to share such information with such parties.
If you have any questions about this Privacy Notice, please contact us at +41 41 710 0808 and ask to speak to the Chief Compliance Officer.
[1] Our affiliates are companies related to us by common ownership or control and can include both financial and nonfinancial companies. Non-affiliates are companies not related to us by common ownership or control and can include both financial and nonfinancial companies.