Privacy Notice

Introduction

Purpose

This notice is provided by EQT Foundation (“the foundation”) on behalf of itself and its various operating and investment entities and affiliates for the benefit of natural persons (excluding those working for the foundation as employees or serving in volunteer roles with the foundation, collectively referred to as “staff” of the foundation) with whom we interact in the course of conducting our business. This intended audience of people with whom we interact and for whom this notice is created includes people who view our website or make contact with us through the website, investors and prospective investors in our various funds or investment vehicles, entrepreneurs and seekers of grant funding from the foundation, and individuals acting on behalf of the foundation or otherwise providing us with personal data in connection with our non-staff business activities.

Terms Used

Certain words are given specific meanings under data protection laws and regulations. Please note that the EQT Foundation is located in Sweden and is subject to the GDPR (as described below). If you are not resident in the EEA, there may be other laws in your country that are different that also apply to your personal data. Other laws may use different or additional terms or define the same terms differently. The terms listed below are intended to have the following meanings in this notice:

“Adequacy decision” means a decision of the European Commission determining that a country outside the EEA ensures an adequate level of protection for personal data.
“Criminal offences data” means personal data about any actual or alleged criminal convictions and offences or related security measures.
“Data controller” means the entity that decides how and why personal data is processed. For purposes of this notice, EQT Foundation is the data controller of the personal data that is within the scope of this notice.
“EEA” means the member states of the European Economic Area.
“EU data protection laws” means all laws and regulations relating to the protection of personal data applicable in the EU, the EEA and, if outside the EU, the UK, including: the Data Protection Act 2018, Privacy and Electronic Communications (EC Directive) Regulations 2003, the Data Protection (Processing of Sensitive Personal Data) Order 2000, Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), and any other applicable legal requirement concerning the protection and processing of personal data.
“Personal data” means information from which it is possible to identify a natural person (an individual), or information from which any individual is identifiable.
“Processing” means anything that is done with personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means the person or entity that processes personal data on behalf of a data controller.
“Sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
“Staff” is used to represent the combined group of EQT Foundation employees and foundation volunteers whose personal data processing and rights are primarily addressed through another EQT Foundation privacy notice.
“Non-staff stakeholders” means all individuals whose personal data the foundation may process in any context other than employment and volunteer service to the foundation. This term includes existing and prospective investors, grantees, entrepreneurs, service providers, and visitors to our website.

Scope

This notice applies to all processing of personal data related to non-staff stakeholders in the foundation’s capacity as the controller of that personal data and, as appropriate, by those operating on behalf of EQT Foundation as data processors.

For More Information

EQT Foundation manages a dynamic philanthropic organization, and this notice is expected to be updated from time to time, such as when there are changes in applicable laws, or to reflect other changes in our policies and procedures with respect to our handling of your personal data. If you have an ongoing business or investment relationship with the foundation, we encourage you to visit our website regularly to review any changes to this notice (https://eqtfoundation.com).

Contacting the EQT Foundation Data Protection Team

If you have any questions about this notice or its currency, or would like further information on any part of this notice or about EQT Foundation’s collection, use, disclosure, transfer, or processing of your personal data, or if you would like to exercise of any of your rights related to your personal data, please address questions, comments, and requests to dataprotection@eqtfoundation.com.

Contacting Data Protection Authorities

You can find out more information about your rights by contacting the appropriate data protection regulator for your country of residence. You may also find out more about your personal data rights and EQT Foundation’s data protection obligations by contacting EQT’s primary data protection regulator, the Swedish Authority for Privacy Protection (IMY) or by searching their website at https://www.imy.se/en/.

Non-Staff Stakeholder Data Processing

Sources of Personal Data We Collect

EQT Foundation collects your personal data from a variety of sources:

From you directly when you provide it to us, for example, during telephone conversations, in voicemails, through written correspondence, or via e-mail
From you when you engage in business with us, for example, by electing to participate in an EQT Foundation-sponsored investment vehicle (including, in the case of an investment relationship, providing applicable information for anti-money laundering identification, verification documentation, and source of funds information), responding to an investor questionnaire, requesting treatment as a professional client, etc.
From you when you visit our website, including any registration information or information captured via “cookies”. For more details, please refer to our Cookie Policy.
When it is available to the public, e.g., on the Internet, in books, journals, magazines, news reports; in public directories, registries, or any other source available to the public; and
When we receive information about you from third parties, such as:
Tax authorities, including those that are based outside the UK and the EEA if the relevant applicant for interests in an EQT Foundation investment vehicle is subject to tax in another jurisdiction
Governmental and competent regulatory authorities to whom we may have regulatory obligations
Credit agencies; and
Fraud prevention and detection services.

The information collected in this fashion could relate to you, or your organization, or its officers, directors, partners, employees, shareholders, ultimate beneficial owners or affiliates or to any other data subjects.

EQT Foundation may also create personal data by combining or organizing our records or combining information you have provided with information received from other sources. This will include information collected in an online or offline context.

Personal Data that We Collect

The types of personal data we collect, and share may depend on the nature of your relationship with the foundation. With respect to non-staff activities related to EQT Foundation business activities, we may process the following categories of personal data:

Names, dates of birth, and birthplace
Contact details and professional addresses (including physical address, email address, and telephone number)
Account data, payment instructions, and other information contained in any document you provide to the foundation (whether directly or indirectly, e.g., through a financial adviser)
Risk tolerance, transaction history, investment experience and investment activity, or if the decision to invest is made by individuals within your organization, information about their experience, knowledge and expertise in investing in alternative funds
Information regarding your status under various laws and regulations, including Social Security number, tax status, income and assets
Accounts and transactions with other institutions
Information regarding your interest and holding in EQT Foundation and EQT Group funds or other investment vehicles, including ownership percentage, capital investment, income and losses
Information regarding your citizenship and location of residence
Source of funds used to make any investment in the foundation or its microfunding entities or other investment vehicles
Anti-money laundering, identification (including passport and driver’s license), and verification documentation and, if applicable, additional information for any individual regarded as a politically exposed person; and
Criminal offences data (only where specifically relevant and necessary)

We will only process sensitive personal data and/or criminal offences data, to the extent required by law, and then only with your express consent (in such a case, a consent form will be addressed to you separately, clearly explaining the reasons of the processing). If you decide not to provide sensitive personal data or criminal offences data, we may be unable to process your application or otherwise fulfill your request.

Why We Collect & Process Personal Data

The foundation must have a lawful basis to collect and process any of your personal data. Depending on the nature of the data and your relationship with EQT, there can often be more than one lawful basis for processing. The table below describes the processing activities associated with the foundation’s philanthropic investment activities and the various lawful grounds for processing that data, including where personal data is provided in connection with an investment by an institutional investor in any EQT Foundation investment vehicle:

KYC due diligence, including confirming and verifying your identity (including, if applicable, your credit-worthiness by using credit reference agencies), complying with reporting obligations under FATCA, the CRS or other requirements in relation to tax disclosure, screening against government, and/or law enforcement sanctions lists; other anti-money laundering and countering terrorist financing due diligence and, conducting “well informed investor” or “professional client” checks in assessing suitability of investors.

The processing is necessary for compliance with a legal obligation to which the controller is subject.
The processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that those interests do not override your fundamental rights and freedoms.
For an investor who is the data subject, the processing is necessary for the performance of a contract with you or to take steps prior to entering into a contract with you.
For sensitive personal data (if any), on the basis of your consent.
Or, for criminal offences data (if any) on the basis that such processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that those interests do not override your fundamental rights or freedoms, such processing is authorized by law, and on the basis of your consent.

Administering our relationship with the investor and performance of all tasks necessary to provide the investment services and all related communications, both in preparing for admission to a fund (negotiation, preparation and signature of documentation) and all ongoing communications and reporting (whether communicating directly with the investor or to its representatives, advisors and agents), as well as providing information to actual or prospective lenders or their advisors and making any relevant regulatory, tax or other relevant filings (including with respect to portfolio investments of relevant foundation funds or other investment vehicles in which you participate) and generally operating and managing the activities of relevant foundation funds and/or other investment vehicles.

The processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that those interests do not override your fundamental rights or freedoms.
Or, for an investor who is the data subject, the processing is necessary for the performance of a contract with you or to take steps prior to entering into a contract with the foundation.

Keeping investors informed about the business of EQT Foundation generally, including offering opportunities to make investments in other funds or investment vehicles.

Where the investment contract incorporates an expression of interest in receiving such information) the processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that those interests do not override your fundamental rights and freedoms.
For an investor who is the data subject, the processing is necessary for the performance of a contract with you or to take steps prior to entering into a contract with EQT Foundation.
Or the investor’s express consent.

If applicable, monitoring or recording of telephone communications.

The processing is necessary for compliance with a legal obligation to which the controller is subject.

Maintenance and management of our IT infrastructure and communications systems; operation of IT security; and IT security audits.

The processing is necessary for compliance with a legal obligation to which the controller is subject.
Or, the processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that those interests do not override your fundamental rights and freedoms.

If necessary, for the purposes of detecting, investigating and preventing breaches of policy, criminal offences and fraud.

The processing is necessary for compliance with a legal obligation to which the controller is subject.
Or, the processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that those interests do not override your fundamental rights and freedoms.

If necessary, for establishing, exercising, and defending legal rights.

The processing is necessary for compliance with a legal obligation to which the controller is subject.
Or, the processing is necessary for the purposes of the legitimate interests pursued by the controller, provided that those interests do not override your fundamental rights and freedoms.

From time to time, the foundation may need to process personal data, including possibly sensitive personal data or criminal offences data on other legal bases. Depending on the nature of the data processing, other legal bases may include:

With your consent (provided that, in the case of criminal offences data, consent is authorized by applicable law as a lawful basis for processing such data)
To exercise or defend a legal claim
If it is necessary to protect the vital interests of an investor or other data subjects; or
If it is necessary for a task carried out in the public interest.

A failure to provide the personal data requested to fulfill the purposes described in this notice may result in the foundation being unable to provide the requested services to you or to admit you to participation in any of the foundation’s microfund entities or other investment vehicles.

Recipients of the Personal Data We Control

EQT Foundation may disclose personal data, where permitted by EU data protection laws, to other entities associated with the foundation, including entities of the EQT Group (including their employees, directors, and consultants) and third parties, professional advisers, lenders, data processors and other persons engaged to fulfill the purposes described in this notice, including, without limitation, the administrators to foundation microfund structures and their external data processing centers and dispatch or payment agents. In addition, EQT Foundation may share personal data with regulatory bodies having competent jurisdiction over the foundation, as well as with relevant tax authorities (including, directly or indirectly, with tax authorities outside the EEA), auditors and tax advisers (where necessary or required by law).

International Data Transfers

EQT Foundation’s business is international and EQT Foundation may therefore need to transfer your personal data to third parties located in countries which may not provide appropriate or suitable safeguards. Transferees will include third parties noted in the section above (Recipients of the Personal Data We Control) as well as other members within the EQT Foundation and EQT Group.

Where we transfer your data outside the European Economic Area we will do so on the basis of: (i) an adequacy decision; (ii) model contract clauses; or (iii) another valid transfer mechanisms.

For more information about the safeguards applied by EQT Foundation to international transfers, please contact EQT Foundation at dataprotection@eqtfoundation.com.

Retention, Protection, and Disposal of Personal Data

We employ appropriate technical and organisational measures to protect personal data within our control against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing.

Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations or for any applicable limitation period under applicable law. Personal data will be retained throughout the life cycle of any investment, however no longer than necessary with regard to the purpose of the individual’s relationship with EQT Foundation and its microfund structure. Some personal data will be retained after a non-staff stakeholder ceases to have a relationship with EQT Foundation.

Your Personal Data Rights

You have the right:

to request access to, or copies of, your data;
to request rectification of your personal data;
to object to the processing of personal data (where the processing is based on the legitimate interests of the data controller or a third party);
to request that the processing of your data is restricted;
to request erasure of your personal data;
to exercise your right to data portability;
where we rely on your consent to process data, to withdraw your consent; and
the right not to be subject to automated decision-making.

The foregoing rights may only be exercised within the limits and to the extent permitted by EU data protection laws. Please note that EQT Foundation does not use automated decision-making. The right to object to the processing, as well as the right to erasure and to data portability are not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. If the exercise of any of the foregoing rights prevents the data controller or a third party from processing personal data, including possibly sensitive personal data and/or criminal offences data, for the purposes described in this Notice, this may result in the inability to provide the services to non-staff stakeholders.

Complaints

If you have any concerns about the way in which EQT Foundation uses your personal data please contact us at: dataprotection@eqtfoundation.com.

If you want to complain, you may also contact the data protection authority in your country.

Last Updated: May, 4, 2023