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Interogo Long-Term Equity Advisors Privacy Notice

General

This Privacy Notice outlines the processing of Personal Data (i.e. information relating to a living individual and from which that individual can be identified) on this Website (as defined below) and applies to Website visitors,  business partners, services providers, suppliers,  or media.

The nature of the Personal Data we collect depends on your relationship with us.

This Privacy Notice sets out our policies and practices with respect to the processing of Personal Data such as but no limited to collection, use, storage and transfer thereof and other matters relating to it.

Unless otherwise defined herein, all capitalized terms in this Privacy Notice shall have the meaning ascribed to them in the Terms of Use.

Personal Data will be processed in compliance with European data protection legislation (including the EU General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”) and any other EU or national legislation which implements or supplements the foregoing as well as other Data Protection Laws (together the "Applicable Data Protection Laws"). “Personal data”, “Controller” and “Processor” have the meanings given in the Applicable Data Protection Laws.

Interogo  Long-Term Equity Advisors AB collects and processes data for the purposes of the legitimate business interest of the firm. The purposes or grounds for processing your personal data could be the following: to discuss business opportunities relating to specific investment strategies, for the performance of a contract to which the data subject is a party, for media-related communications, for processing job applications, for compliance with any legal obligations and for other reasons with your permission.

Amendments to this Privacy Notice will be posted to the Website and will be effective when posted. Your continued use of the Website following the posting of any amendment to the Privacy Notice shall constitute your acceptance of such amendments. If you do not agree with any changes that we make, you should not use or access the Website.

1. Who is the Controller for the processing of your Personal Data

The website accessible at https://interogo-lte.com (the “Website”) is operated by Interogo Long-Term Equity Advisors AB, a company incorporated under Swedish law under registration number 559091-9295 having its registered address is at Jakobsbergsgatan 24, 111 44 Stockholm, (“Interogo  Long-Term Equity”, “Long-Term Equity” “we”, “us”, “our”).

2. Which categories of Personal Data do we process?

2.1. Information you provide to us: We collect Personal Data, when you contact us directly. Such collected Personal Data may include:

  • Your first name and surname
  • Email address
  • Telephone number
  • Information about your business,
  • Any additional Personal Data you provide to us when corresponding with us.

We do not collect any special categories of Personal Data about you (meaning details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2. Information collected from our Website

Our Website uses Plausible (https://plausible.io/), a privacy focused tool. Plausible does not use persistent identifiers, browser cache nor local storage (nothing is stored, retrieved, or extracted from visitor’s devices) and does not collect any cookies other than HTTP Cookies.

We only use strictly necessary/essential cookies (the “Cookies”) on our Website to ensure the Website can work efficiently and enable core Website functionality such as security, network management, and accessibility. No tracking, analytics or third-party cookies are stored on your device. Your browsing remains private and anonymous.

The table below explains the Cookie we use and why:

Cookie Source  Purpose  Expiry Type
cookieAgree Interogo-lte.com  This cookie is used to remember a website visitor’s choice about cookies on our website.  90 days HTTP Cookie

IP addresses are stored for thirty (30) days and are never stored together with other Personal Data. We do not track between websites or devices and no personal data is collected.

All data from Plausible is processed on servers within the EU.

3. Under which lawful basis do we process your Personal Data?

To the extent you provide us with any Personal Data through or in connection with this Website, we use such information for the following purposes and rely on the following legal basis:

  • (i) for compliance with our legal obligations under article 6(1)(c) GDPR and/or equivalent provisions in other Applicable Data Protection Laws;
  • (ii) pursuant with our legal obligations when required under applicable local laws within and outside of Sweden, such as specific regulations, relevant industry and internal policies, guidance enacted in any jurisdiction, court orders or governmental regulations;
  • (iii) for the purposes of the legitimate business interest of Interogo Long-Term Equity.

4. When and how we share your information with others

We may share your information with third parties (such as personnel employed by or working on behalf of our affiliates (i.e. entities of Interogo Holding Group for the purposes of shared intragroup services, corporate governance or applicable laws/regulations), suppliers and services providers such as professional advisors and external lawyers engaged or external auditors where lawfully required) for the purposes described above.  

In that respect, we will only disclose your Personal Data to those with a legitimate business need and after we have taken steps to ensure that your Personal Data is processed in a manner consistent with this Privacy Notice. 

These include:

1) Our affiliates (i.e. entities of the Interogo Holding Group): We may disclose Personal Data that you provide us with to our affiliates (i.e. other entities within the Interogo Holding Group).

2) Third parties when necessary pursuant to legal and regulatory obligations: We may disclose your Personal Data to third parties in compliance with this Privacy Notice to:

  • (i) fulfil contractual obligations;
  • (ii) protect our legitimate interests;
  • (iii) comply with legal obligations including court orders, applicable regulatory s obligations;
  • (iv) enforce or apply our Terms of Use and other agreements;
  • (v) when we believe that disclosure is necessary to protect our rights, property, safety and/or comply with judicial proceedings, court order, request from a regulator, for the purposes of public importance or any other legal or investigatory process involving us.

We do not process Personal Data otherwise.

We will never sell your Personal Data.

We may process Personal Data in relation to portfolio companies that we are evaluating in connection with a potential investment in or purchase of such companies. This Personal Data may be then obtained via third parties (i.e. the target company in question).

5. Transfers of Personal Data

Personal Data may be transferred by Interogo  Long-Term Equity to Switzerland, within the EU and the EEA or to any country where an entity of the Interogo Holding Group is located. The data protection law in such other countries may not give you as much protection as the data protection law in the country where you are located.

We ensure that any transfer is made in accordance with Applicable Data Protection Laws. For example, for transfers to a country deemed by a privacy authority to not offer the same level of protection, we ensure that the transfers are governed by appropriate safeguards, such as the European Commission Standard Contractual Clauses (“SCCs”).

6. Data subject rights

Subject to Applicable Data Protection Laws  and depending on your jurisdiction, you may be entitled to some of the below rights with regard to  our  processing of your Personal Data.

You may exercise these rights at any time  by contacting us via [email protected]

After considering such requests and, in accordance with the Applicable Data Protection Laws, we will reply to any valid request  within one month. , we will explain why.

We may request you to provide us with information necessary to confirm your identity before responding to any request you make. 

You have the following rights:

  • The right to access: subject to exceptions, you have the right to request access to the Personal Data we process;
  • The right to rectification of errors: if the Personal Data we hold about you is inaccurate, obsolete or incomplete you are entitled to have it updated or rectified;
  • The right to erasure: subject to exceptions, you can ask us to delete your Personal Data.
  • The right to object, in whole or in part: under certain circumstances, you have the right to request  us to stop processing your Personal Data;
  • The right to withdraw consent: where we rely on your consent to process Personal Data, you have the right to withdraw consent at any time. Such withdrawal will not impact the lawfulness of any data processing activities prior withdrawal. To withdraw consent, please contact [email protected] ;
  • The right to restriction of processing: under certain circumstances you have the right to restrict the processing of your Personal Data (other than storing it) to specific categories of processing and in certain situations;
  • The right to data portability: under certain circumstances you have the right to obtain Personal Data (in a structured, commonly used and machine-readable format) (if certain conditions are satisfied), transmit that Personal Data to a third party, if we have the technical means; and
  • The right to lodge a complaint with your local data protection authority: you also have the right to file a complaint with the data protection authority in your residence country or where the alleged infringement of the Applicable Data Protection Laws occurred. Integritetsskyddsmyndigheten IMY is the competent Swedish data protection authority. You can find more information here

7. How do we protect Personal Data?

We have implemented adequate technical and organizational measures to safeguard the Personal Data we process. We update and test our security technology on an ongoing basis. In addition, we restrict access to your Personal Data to employees, contractors, on a need-to-know basis and train all staff about the importance of confidentiality and maintaining the privacy and security of your information.

While we take reasonable care to implement such measures, remember that the internet is inherently unsafe, and we cannot guarantee the security of your Personal Data when transmitted over the internet or email.

8. How long do we keep and store your Personal Data?

We will not retain your Personal Data longer than necessary in relation to the purposes for which the data are processed. In principle, we will retain your data for ninety (90) days after which it will be archived and subsequently deleted  one after the end of your relationship with us, unless we are required by statutory or legal obligations or have an overriding interest to retain your Personal Data for a longer period of time.

Media-related communications may be retained for so long as necessary to manage queries, comply with legal obligations and in line with our legitimate interests. Data is deleted or anonymized when no longer needed.  

 We may also retain your Personal Data for a longer period necessary for us to establish, exercise and defend any legal claims (e.g. based on periods of limitation in law).

10. Changes to this Privacy Notice

We may change this Privacy Notice from time to time by posting the updated version of the Notice on our Website. If at any point we decide to collect Personal Data or use any collected data in a manner different from that stated at the time it was collected, we will notify applicable users where applicable. The “effective date” at the top of this Privacy Notice indicates when such changes will take effect. We encourage you to visit our Website frequently to stay informed about how we use your Personal Data.

11. Questions, concerns or complaints

To ask questions or to comment about this Privacy Notice and our privacy practices, you may contact [email protected]. You may also at any time write to our Personal Data Representative at: Interogo Long-Term Equity, The Personal Data Representative, Jakobsbergsgatan 24, 111 44 Stockholm, Sweden

12. Questions of journalists

If you are a individual involved in media-related communications or otherwise have a media related question, please contact the Media Team of Interogo Holding by emailing [email protected].