Privacy Policy

SCOPE AND PURPOSE OF THIS NOTICE

For the purposes of applicable data protection law, Newton Biocapital is a data controller responsible for the collection and processing of the personal data provided by you, in compliance with the applicable data protection laws and for the purposes described in this investor data protection notice (“Privacy Notice”).

This Privacy Notice informs you on how the provided personal data will be processed and stored by Newton Biocapital.

PERSONAL DATA PROCESSED

When you correspond with us (by phone, e-mail or other means), make enquiries or when you complete the contact form on our website or submit information or content through our website, Newton Biocapital may collect and process personal data.

If you provide us with personal data about any data subject other than yourself, you need to ensure that these persons understand how their personal data will be used and that they have given their permission to disclose their personal data to us in order to allow us to collect and process the personal data in the framework of carrying out the purpose for which the personal data are collected.

Newton Biocapital will collect and process the following categories of personal data:

personal data about representatives, management, key staff, agents, officers, employees, service providers, collaboration partners and other individuals, which may include:

  • first name and surname;
  • gender;
  • nationality;
  • place & date of birth;
  • personal or professional contact details (e-mail address(es), phone or fax number(s))
  • address details;
  • marital status;
  • information about dependents or beneficiaries;
  • function/job title, professional activity ;
  • VAT number ;
  • social security number;
  • bank account numbers;
  • any documentation required under the regulations concerning anti-money laundering (e.g. copy of ID card, passport);
  • other personal data provided in the framework of the negotiations or business relationship with Newton Biocapital.

When we ask you to supply us with personal data we will attempt to make it clear whether the failure to supply us with the requested personal data may make you ineligible to become an investor or to conduct business with Newton Biocapital whether the supply of any personal data we ask for is optional.

PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA BY NEWTON BIOCAPITAL

Newton Biocapital processes the provided personal data for the following purposes and on the following legal basis:

purpose

legal basis

  • identity verification
  • legitimate interest & fulfilment of legal requirements or other regulatory obligations
  • the effective administering of the Newton Biocapital fund(s) and its business
  • legitimate interest
  • the performance of commercial, financial and legal due diligence investigations on investors and possible portfolio companies
  • legitimate interest
  • managing its relationships with its investors and its portfolio companies
  • implementation of the agreement & legitimate interest
  • complying with its legal obligations (e.g. compliance with the obligations under anti-money laundering and counter-terrorist financing regulations, disclosure of personal data in connection with legal process or investigation)
  • legal basis, fulfilment of legal requirements or other regulatory obligations

Newton Biocapital will not use personal data for any purposes other than the purpose for which the personal data were initially collected.

You should be aware that processing necessary to comply with the anti-money laundering and counter-terrorist financing regulations could lead to a refusal to invest or accept you as an investor, a termination of negotiations or a contract and/or a reporting to the Belgian Financial Intelligence Processing Unit (‘CIF ‘).

RECIPIENTS OF YOUR PERSONAL DATA

Newton Biocapital will only grant access to your personal data on a need-to-know basis to its representatives (directors, managers), its staff and its trusted external consultants, advisors and other service providers or professional experts (such as attorneys, legal advisers, accountants and finance/tax experts), and such access will be limited to the personal data that is necessary for the performance of their function or the purposes of their service agreement for which such access is granted. Newton Biocapital will make those persons aware of the importance of personal data protection.

In addition, personal data may also be disclosed to a governmental authority, as required by applicable laws, regulations or court orders or pursuant to a valid request.

RETENTION PERIOD OF YOUR PERSONAL DATA

Newton Biocapital will no longer retain the provided personal data than is necessary or desirable for the business purposes for which the personal data were collected or otherwise processed or to comply with applicable law and audit requirements.

Typically, the retention period will be as follows:

purpose

retention period

  • managing the business relationships with Newton Biocapital’s current and former investors
  • until Newton Biocapital’s liquidation
  • managing Newton Biocapital’s business relationships with (possible) portfolio companies
  • up to 1 year upon termination of the negotiations, or up to 5 years after the business relationship ends (e.g. after the exit date)
  • complying with its legal obligations
  • legal duration (e.g. personal data obtained in the context of compliance with the obligations under anti-money laundering and counter-terrorist financing regulations which will be kept for 10 years

STORAGE AND SECURITY

As Newton Biocapital values and respects the privacy of data subjects and the confidentiality and security of personal data, Newton Biocapital endeavors to implement, or to have implemented, reasonable, appropriate technical and organizational measures to prevent the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed by Newton Biocapital.

Although Newton Biocapital does its best to protect the provided personal data, Newton Biocapital cannot guarantee the security of the personal data transmitted through its website or otherwise via e-mail/the internet. Any such transmission is at your own risk.

Once Newton Biocapital has received personal data, Newton Biocapital will use reasonable security features to prevent as much as possible any unauthorized access thereto.

INTERNATIONAL DATA TRANSFERS

International personal data transfers (to countries outside of the EAA) shall only take place to countries considered as providing adequate legal protection for the processing of personal data or after you have given explicit consent for the personal data transfer, after having been informed of the possible risks of such transfers.

YOUR DATA PROTECTION RIGHTS

  • Right to access

You have the right to be informed which of your personal data is obtained and being processed by Newton Biocapital. You also have the right to request a copy of the personal data that Newton Biocapital holds about you.

  • Right to obtain the rectification

If any of the personal data Newton Biocapital holds on you is inaccurate, incomplete or outdated, you have the right to obtain the correction, completion or update of your personal data.

  • Right to obtain the erasure:

You have the right to request that Newton Biocapital restricts the processing of your personal data or deletes your personal data in case (i) it is no longer necessary for Newton Biocapital to have (all) your personal data available for the purposes for which your personal data were collected and processed or (ii) you object to the processing (of certain of your personal data) and there are no overriding legitimate grounds for the processing by Newton Biocapital.

  • Right to object

You have the right to object, at any time and on legitimate grounds relating to your particular situation, to the processing of your personal data.

Provided that such objection is justified, Newton Biocapital will no longer process the personal data concerned unless Newton Biocapital can demonstrate compelling legitimate grounds for the processing which override your interests.

  • Right to portability

You have the right to receive the personal data which you have provided to Newton Biocapital in a structured, commonly used and machine-readable format.

REQUESTS FOR ADDITIONAL INFORMATION AND COMPLAINTS

If you need any additional information in order to fully understand this Privacy Notice or you wish to exercise any of the aforementioned data protection rights, please contact us on the following e-mail address: info@newtonbiocapital.com. You are kindly asked to attach a copy of your identity card or passport, so Newton Biocapital can check that requested changes are properly authorized.

Newton Biocapital makes every effort to treat your personal data with care and in a legitimate matter.

If you are in the opinion that your personal data is processed by Newton Biocapital in a way that does not comply with the applicable data protection regulations or in case you or if you are not satisfied with the way Newton Biocapital has handled any of your concerns, you have the right to submit a complaint to the Belgian Data Protection Authority (Drukpersstraat 35, 1000 Brussels, contact@apd-gba.be) or another competent supervisory authority located in the country where you have your habitual residence or place of work.