This Privacy Policy was last updated on August 30, 2018.

About F-Prime [1]

F Prime Inc. (dba F Prime Capital Partners) (“F-Prime”) is an affiliate of Fidelity Investments and an active investor in private venture capital backed companies.  F-Prime uses personal data in order to source, transact, and manage investment opportunities as well as to comply with legal and governance obligations.

This policy explains how data we collect about you, or that you provide to us, will be processed.

F-Prime is a data controller for all data processing carried out by F-Prime.  In some cases, an affiliate of F-Prime, F-Prime UK Limited, will act as data controller.  F-Prime UK Limited is a company incorporated in England & Wales with registered number 06229843 whose registered office is at Cannon Place, 78 Cannon Street, London, United Kingdom, EC4N 6AF.

If you would like to contact F-Prime about any use of your personal data, please email info@fprimecapital.com or write to the Director of Risk & Compliance, F-Prime Capital Partners, 1 Main St., 13th floor, Cambridge, MA 02142 USA.

Information We Collect:

We do not provide products or services, or promote our business, to consumers.  We occasionally collect information about individuals who invest in or have other relationships with the investments we manage. We therefore occasionally collect information about individuals who are or may become directors, officers, shareholders, or persons with management or control responsibility for:

  • Existing or potential investments;
  • co-investors in our investments (or potential investments).

We also may collect information from:

  • individuals representing businesses that we work with;
  • individuals we engage as consultants;
  • individuals we meet with to research potential investments;
  • users of our Web site (refer to “Web site” below).

What information we may collect dependent on the nature of your relationship with F-Prime:

  • contact information including personal and work e-mail addresses, mailing addresses, and phone numbers;
  • professional information including employment history, educational and professional qualifications and accreditations;
  • certain information about relationships with F-Prime, Fidelity Investments, and our investments or potential investments;
  • financial information about you and your business interests, your creditworthiness and your financial history;
  • information from anti-fraud, due diligence, political exposure and sanctions databases, which may
  • include information about your criminal convictions (if any);
  • from users of our Web site, information about the website that users came from or are going to.  We also collect information on which pages of our website users visit, IP addresses, the type of browser used and the number of times our website is accessed. However, this information is aggregated and is not used to identify individuals. We do not require personal data to be submitted in order to use our website.

We also collect personal data from you when you voluntarily provide such information, such as when you contact us with inquiries.

How we Collect Information

  • through contact with you, your advisers, and with businesses you are associated with;
  • from the evaluation and completion of investment transactions including information provided during the due diligence process;
  • from public domain sources, such as social media and newspapers;
  • from third party sources, which are used to assist us in conducting due diligence.

How We Use Information

We use personal information for a number of purposes relating to our legitimate interests in operating and promoting our business. In doing so, we seek to balance business needs with your right to have your information handled in a way which does not unreasonably prejudice your interests.

These legitimate interests include:

  • to evaluate and execute potential investment opportunities;
  • to operate and manage our investments;
  • to carry out market research, business, and statistical analysis;
  • to comply with best practices and standards in making investment decisions;

We collect certain information to satisfy our legal obligations:

  • to comply with applicable law, regulation and internal compliance relating to record-keeping, the prevention of fraud, tax evasion, bribery and corruption, money laundering and terrorist offences or relating to cyber or data security.

The most common use of personal information is as an input to our opinion on whether to pursue, or complete, an investment transaction or to engage a consultant and if so, on what terms. We may decide not to pursue an investment transaction or engage a consultant (or be unable to do so for legal or regulatory reasons) as a result of due diligence and background check enquiries (and the information revealed by those enquiries). We rely upon the lawful bases of legal obligations and our legitimate interests (explained above) for such processing.

We are required to use certain personal information in order to comply with legal obligations to which we are subject. If we contract with you directly, we will use personal information in order to perform our contractual obligations.

We only collect and process “special categories” of information when we have been provided with it by third party providers of due diligence and background checking data services, from information that has been manifestly made public by the data subject. We collect and process such information for the purpose of completing due diligence and background checks and in order to comply with legal obligations to which we are subject.

Website

When you interact with F-Prime through our website, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may use such information and pool it with other information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, and the domain names of our visitors’ Internet service providers. It is important to note that no personal data is available or used in this process.

In operating this website, we use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our website gives to your browser when you access the website. Our cookies help provide additional functionality to the website and help us analyze website usage more accurately. For example, we use Google Analytics cookies to help us to understand how users arrive at our website, browse or use our website and highlight areas that can be improved such as navigation. The data stored by these cookies never shows personal details from which users’ individual identities can be established. In all cases in which we use cookies, we will not collect personal data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. You can block cookies by activating the setting on your internet browser that allows you to refuse all or some cookies.

Use of web beacons

Some of our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides.

Links to other websites

Our website may contain links to other websites over which we have no control. We are not responsible for privacy policies or practices of other websites to which users choose to link from our website. We encourage users to review the privacy policies of those other websites to understand how they collect, use and share personal information.

Marketing & Communications

We may use your information to send you emails, for example, with newsletters and invitations to events, and if you do not wish to receive these kinds of communications, you can opt out of our mailing list.

Sharing Information

We may share information with other companies affiliated with Fidelity Investments, FIL Limited and its affiliates, and with associated entities and limited partners of the venture funds.

We may share information collected as detailed under “Information We Collect” in order to comply with legal and regulatory obligations and best practice in relation to investment due diligence and decisions.

We may share information with third party suppliers or service providers, for example, legal advisers, but this will generally be limited to the amount of information needed for that third party to carry out the relevant function.

We may also share information with third parties where you have authorized us to do so, such as

providing information for the purposes of completing tax returns.

If you would like more details about our sharing of personal information, please contact us at info@fprimecapital.com or write to the Director of Risk & Compliance, F-Prime Capital Partners, 1 Main St., 13th floor, Cambridge, MA 02142 USA.

Record Retention

We generally aim to retain your personal information for the period during which have a relationship with you.  However, there are many reasons why we may need to retain your data for a longer period.  We may need to retain your data for compliance or regulatory purposes, or legal, tax, and/or accounting requirements, audits, or requests or requirements of a legal or governmental authority making a request. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as any applicable legal requirements.

Security

We may process personal information in, and transfer personal information to, countries that may not guarantee the same level of protection for personal information as the country in which the Data Subjects reside.

In accessing our website, because the internet is an open system, we cannot guarantee that

unauthorized third parties will never be able to defeat those measures or use our website users’

personal information for improper purposes. In particular, e-mail sent to or from this Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail.

Please keep this in mind when disclosing any personal data to us via the Internet.

Your rights

You have a right in certain circumstances to:

– access information we hold about you, and know for what purpose we use that information;

– correct inaccuracies in information we hold about you;

– withdraw any consent you have given to use of your information;

– complain to the relevant supervisory authority in any jurisdiction about our use of your information.

– in some circumstances:

  • request that we erase information we hold about you;
  • receive a copy of any personal information provided by you and require us to provide this information to a third party; restrict the use of information we hold about you;
  • object to the use of information we hold about you, including where that information is used for direct marketing purposes.

You can exercise these rights by contacting us at info@fprimecapital.com or write to the Director of Risk & Compliance, F-Prime Capital Partners, 1 Main St., 13th floor, Cambridge, MA 02142 USA.

Changes to Our Privacy Policy

If our privacy policy changes in any way, we will place an updated version on our website.

[1] Advisory and related services provided as Impresa Management LLC