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Privacy policy

Imprint & Contact Information (Headquarter)

Tenity Group AG and its subsidiaries

Pfingstweidstrasse 110
8021 Zurich
Switzerland

info@tenity.com

Authorised representative person(s)

Andreas Iten
Maximilian Fabian Jonathan Derpa
Marc Hauser
Luca Casuscelli
Johannes Bungert
Raphael Bianchi
Godefroy Schrago

Commercial register entry

Registered company name: Tenity Group AG
Commercial Register No: CHE-285.606.270

Disclaimer

This disclaimer is to be regarded as part of the internet publication which you were referred from. If sections or individual terms of this statement are not legal or correct, the content or validity of the other parts remain uninfluenced by this fact.

Liability for the contents of this website.

The contents of our pages were created with the greatest care. For the correctness, completeness and topicality of the contents we can take over however no guarantee. As a service provider, we are responsible for our own content on these pages in accordance with general laws. However, we are not obliged to monitor transmitted or stored third-party information or to search for circumstances that indicate illegal activity. Obligations to remove or block the use of information in accordance with general laws remain unaffected by this. However, liability in this respect is only possible from the point in time at which we become aware of a concrete violation of the law. As soon as we become aware of such infringements, we will remove the content immediately.

Privacy Policy

This privacy policy applies to Tenity Group AG and its subsidiaries

The Privacy Policy of Tenity describes the information we collect from you and how we may (and may not) use and disclose that information.

This policy was last updated on September 8, 2023. This Privacy Policy may change from time to time. Our Privacy Policy explains how we handle personal information and the choices available to you regarding the collection, use, access, and how to update and correct your personal information.

This Privacy Policy applies to the processing of information about users and other individuals that we collect when you use our services and platforms, which means any application, event, website, mailing services or services we offer, or when you communicate with us.

1. Scope of the Privacy Policy

This privacy policy on www.tenity.com applies to the website and all other services. Swiss data protection law (DSG) applies. Any additionally applicable law from the European General Data Protection Regulation (DSGVO) is specifically indicated.

2. Processing of Personal Data; Type, Purpose, and Use

When visiting the website:

When accessing our website, information is temporarily stored in so-called log files on our server. These are pieces of information which the browser of your device automatically sends.

Namely:

• IP address of the contacting device

• Date and time

• URL of the accessed page

• Referrer-URL

• Browser and other device information

• Data necessary for transmission security, troubleshooting, and improvements

The mentioned data is processed by us for the following purposes:

• Establishing a connection to the website

• Using our website

• System security and stability

The data processing is carried out upon your request and is necessary according to Art. 6 Para. 1 Sentence 1 lit. b DSGVO for the stated purposes to fulfill the contract and pre-contractual measures. Alternatively, you have given your consent to the described data processing according to Art. 6 Para. 1 Sentence 1 lit. a DSGVO since you have accessed the website.

Examples of data we collect:

When we scout startups we may collect the following personal data: first and last name, email, company, role, phone number, LinkedIn profile URL. We use this data to: Scout and identify relevant startups, analyse and provide application data to our programs and analyse and aggregate data to get industry and internal insight.

We collect this data using the lawful basis: Legitimate Interest.

When you fill out a form on our website requesting information on our programmes, corporate or investor offer. We use this data to: provide you with the information you requested

We collect this data using the lawful basis: Consent

When you sign-up to one of our newsletters we collect the following data: email. We use this data to: send you monthly newsletters updating you on all things Tenity.

We collect this data using the lawful basis: Consent.

When we distribute reports, we use the following data: name, company, email. We use this data to: to give you access to reports or insights created by Tenity.

We collect this data using the lawful basis: Consent

You can edit your communication preferences at any time.

When you get in touch with us or conclude a contract:

When you enter into a contract with us, the following data is collected:
• Name, first name, address, date of birth, mobile number
• Information on orders made
• Details about purchases, services

The data processing is carried out upon your request and is necessary according to Art. 6 Para. 1 Sentence 1 lit. b DSGVO for the stated purposes to fulfill the contract and pre-contractual measures. Alternatively, you have given your consent to the described data processing according to Art. 6 Para. 1 Sentence 1 lit. a DSGVO.

3. Transfer of Data to Third Parties (incl. Joint Controllers and Data Processors)

We use external service providers (data processors) e.g., for web hosting. A separate data processing agreement has been concluded with the respective service providers to ensure the protection of your personal data.

Furthermore, it might be necessary to send the data to the following categories of recipients:
- other customers
- suppliers and business partners
- possibly authorities and courts.

4. For Contract Processing

As far as legally permissible according to Art. 6 Para. 1 Sentence 1 lit. b DSGVO and necessary for the processing of contractual relationships with you, your personal data will be passed on to third parties. This includes, in particular, the transfer to shipping companies for the purpose of delivering the goods you ordered and the transfer of payment data to payment service providers or credit institutions to carry out a payment transaction. The data passed on may only be used by the third party exclusively for the stated purposes.

5. Cookies

We use cookies on our website (session cookies as well as temporary and permanent cookies). These are small files that your browser automatically creates and stores on your device (laptop, tablet, smartphone, etc.) when you visit our site. A cookie does not necessarily mean we can identify you.

The use of cookies serves, on the one hand, to log the frequency of use, the number of users, and behavior on our website, to increase the security of website usage, and to design our information offer in a user-friendly manner. Once you leave the website, these cookies are automatically deleted.

Furthermore, we also use temporary cookies to optimize user-friendliness, which are stored on your device for a specified period. If you visit our site again to use our services, it will automatically recognize that you have been with us before and what inputs and settings you have made, so you don't have to enter them again.

The legal basis for data processing is Art. 6 Para. 1 Sentence 1 lit. f DSGVO. Our legitimate interest arises from operating the website.

You can configure your browser settings so that no cookies are stored on your computer. Fully deactivating cookies may mean that you cannot use all the functions of our website.

By continuing to use our website and/or agreeing to this privacy policy, you consent to us setting cookies and thus collecting, storing, and using personal usage data, even beyond the end of the browser session. You can revoke this consent at any time by activating the browser setting to refuse third-party cookies.

6. Analysis Tools


HubSpot:
We use the services of the software manufacturer HubSpot. HubSpot is a software company from the USA with a branch in Ireland (HubSpot European Headquarters, Ground Floor, Two Dockland Central, Guild Street, Dublin 1, Ireland).

HubSpot is a service platform. The service we use is an integrated software solution with which we can manage customer data and cover various aspects of our online marketing. This includes, among other things, the analysis of landing pages and reporting. So-called "web beacons" are used for this purpose, and cookies are stored on the device you use.

The following personal data, for example, can be collected:
• IP address,
• geographical location,
• type of browser,
• duration of visit,
• pages accessed.

The collected information and the contents of our website are stored on the servers of our software partner, HubSpot Ireland. We use HubSpot to analyze the use of our website. This way, we can continuously optimize our website and make it more user-friendly. Additionally, we use the information to determine which services of our company are interesting for customers and newsletter subscribers and to contact them for advertising purposes. Furthermore, with the evaluation, we optimize our web offer for you.

However, we only use your IP address in a shortened version. This means that HubSpot shortens the IP address of users within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a HubSpot server in the USA and shortened there.

The cookies typically have a lifespan of 13 months. Furthermore, we delete the personal data collected via HubSpot as soon as the purpose for which they were collected is achieved, unless statutory retention periods prevent deletion. The information generated by the cookie about the user's use of the online offer can usually also be transferred to a Google server in the USA and stored there. Further information on the functionality of HubSpot can be found in the privacy policy of HubSpot Inc.

When you fill out a form on our website

The website of the Tenity Group AG contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

We use services from HubSpot to integrate forms in our website, a service provided by HubSpot Inc., 25 First Street, Cambridge, MA 02141, USA. HubSpot is certified under the EU-US Privacy Shield and applies Standard Contractual Clauses (SCCs) to ensure that data is safely processed outside of the EU.

This service uses so-called "web beacons" and stores "cookies" on your computer that enable the analysis of your use of our website. The collected information (for example, IP address, geographic location, browser type, duration of visit and pages viewed)is evaluated by HubSpot on our behalf to generate reports about the visit and the pages visited.

If you subscribe to our newsletter and download studies and other documents, HubSpot allows us to associate visits to our website with additional personal information (such as your name and email address) and provide you with targeted information about the topics you prefer.

If you do not want your data to be collected by HubSpot, you can prevent the storage of cookies at any time with the appropriate browser settings.

For more information about how HubSpot works, please refer to HubSpot's privacy policy: http://legal.hubspot.com/privacy-policy

Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy

7. Social Media Plugin

On our website, we use the following social plugins to promote our company. The underlying advertising purpose is to be regarded as a legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO. The responsibility for ensuring data protection compliance lies with their respective providers. Data processing related to these plugins occurs with your consent when you use these plugins.

If you use the services of these social networks independently or in connection with our website, the social networks will evaluate your use of the plugin. In this case, information about the plugin is forwarded to the social networks.

Embedding YouTube Videos
We use videos from the video portal "YouTube" provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: "Google") on our websites. The implementation is carried out according to Art. 6 Para. 1 lit. f GDPR, where our interest lies in the smooth integration of videos and the attractive design of our website.

We use Google's extended privacy mode option for this. When you visit a page that contains an embedded video, a connection to Google servers is established and the content is displayed on the website by notifying your browser.

According to Google's information, your data—specifically which of our web pages you have visited and device-specific information including your IP address—will only be transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transfer.

If you are logged into Google at the same time, this information will be assigned to your YouTube member account. You can prevent this by logging out of your member account before visiting our website.

Some information may be transmitted to Google Inc. in the USA, other Google companies, and external Google partners, which may be located outside the European Union. Google uses standard contractual clauses approved by the European Commission for this and relies on the adequacy decisions issued by the European Commission regarding certain countries.

For more information on data protection related to YouTube, please refer to Google's privacy policy.

Google Maps
Our website uses Google Maps services (e.g., In-Screen or via interfaces/API). Google LLC, USA, may therefore process information about your actual location. Google uses various technologies such as IP addresses, GPS, and other sensors for location determination, providing information about nearby devices, WiFi access points, or cell towers.

For the purpose and scope of data collection and further processing and use of data by Google, as well as your related rights and privacy settings, please refer to Google's privacy policy at https://policies.google.com/privacy?hl=de&gl=de.

Airtable
We use Airtable, a service provided by Formagrid Inc., for data management and processing, particularly for handling and storing data submissions.

This data processing is carried out based on our legitimate interests according to Art. 6 Para. 1 lit. f GDPR. Your data will be stored on servers by Formagrid Inc. (hereinafter: "Airtable") located in San Francisco, USA. The system uses a secure HTTPS connection and does not collect personal data from its users. Airtable is committed to ensuring that all personal data is stored and processed in accordance with GDPR regulations. For example, data is encrypted both in transit and at rest.

You can find Airtable's current privacy policy here: https://airtable.com/privacy

Fathom Analytics
We use Fathom Analytics for our website, a web analytics software program. The service provider is the Canadian company Conva Ventures Inv., BOX 37058 Millstream PO, Victoria, British Columbia, V9B 0E8, Canada.

Your data may also be processed in Canada, which is outside the scope of the GDPR. The European Commission has decided that there is an adequate level of protection for commercial offers from Canada according to Art. 45 Para. 1, thus data transfer to this country is permissible.

For the purpose and scope of data collection and further processing and use of data by Fathom Analytics, as well as your related rights and privacy settings, please refer to Fathom Analytics' privacy policy. https://usefathom.com/privacy

Newsletter
Upon signing up for the newsletter and confirming the receipt of the newsletter (Double Opt-in), the following personal data is processed: Name, First name, Email address. This data is processed for the purpose of authenticating the subscriber at the time of registration and delivering a newsletter to them, to determine if and when they opened it, and any specific articles within.

The data you enter for the purpose of subscribing to the newsletter is processed by our provider. The processing of this data is based solely on your consent. You can revoke this consent at any time, for example through the "Unsubscribe" link in the newsletter. Any previous data processing remains unaffected by the revocation. When we send newsletters using our provider, we can determine if a newsletter was opened and which links were clicked.

The newsletter of the Tenity Group AG contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Tenity Group AG may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at anytime entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure.

We use services from HubSpot to send our newsletter, a service provided by HubSpot Inc., 25 First Street, Cambridge, MA 02141, USA. HubSpot is certified under the EU-US Privacy Shield and applies Standard Contractual Clauses (SCCs) to ensure that data is safely processed outside of the EU.

This service uses so-called "web beacons" and stores "cookies" on your computer that enable the analysis of your use of our website. The collected information (for example, IP address, geographic location, browser type, duration of visit and pages viewed)is evaluated by HubSpot on our behalf to generate reports about the visit and the pages visited.

If you subscribe to our newsletter and download studies and other documents, HubSpot allows us to associate visits to our website with additional personal information (such as your name and email address) and provide you with targeted information about the topics you prefer.

If you do not want your data to be collected by HubSpot, you can prevent the storage of cookies at any time with the appropriate browser settings.

For more information about how HubSpot works, please refer to HubSpot's privacy policy:http://legal.hubspot.com/privacy-policy

Their Privacy Policy can be viewed at https://legal.hubspot.com/privacy-policy

8. Place of Processing

We primarily store and process your personal data in Switzerland and the EU. However, we may also transfer your personal data to recipients in countries outside Switzerland or the EU.

9. Cross-border Disclosure in Third Countries without Adequate Data Protection Level

We base data transfers to such countries on standard contractual clauses or legal exceptions. Whenever data transfers are made to a recipient outside the EEA, an appropriate level of data protection for the international transfer is ensured through suitable security measures. If you have questions about these data protection contracts based on the EU standard contractual clauses or if you would like more information on additional security mechanisms and security measures for data transfer to third countries, please feel free to contact our data protection officer. Link to standard contractual clauses: https://ec.europa.eu/info/sites/default/files/1_de_annexe_acte_autonome_cp_part1_v3.pdf

Regarding the transfer of data to the USA, we rely on the EU-U.S. Privacy Framework, which has been in effect since July 10, 2023.

10. Your Rights

You have the right to

- Request information about your personal data processed by us. In particular, you can request information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been disclosed or will be disclosed, the planned storage duration, the existence of a right to correction, deletion, restriction of processing or objection, the existence of a right to complain, the origin of your data if it was not collected from us, and the existence of automated decision-making, including profiling, and, if applicable, meaningful information on their details (Art. 15 GDPR). In the event of a disproportionately large effort, we reserve the right to request identification and a pre-payment of actual costs from you.


- Demand the immediate correction or completion of your personal data stored by us (Art. 16 GDPR).


- Request the deletion of your personal data stored with us unless its processing is required to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or to assert, exercise, or defend legal claims (Art. 17 GDPR).


- Request the restriction of processing of your personal data if you dispute the accuracy of the data, the processing is unlawful, but you refuse its deletion, and we no longer need the data, but you require it to assert, exercise, or defend legal claims, or if you have objected to the processing according to Art. 21 GDPR (Art. 18 GDPR).


- Receive your personal data that you have provided to us in a structured, commonly used, and machine-readable format or request its transfer to another controller (Art. 20 GDPR).

- Revoke your given consent at any time. As a result, we are not allowed to continue the data processing that was based on this consent in the future (Art. 7 (3) GDPR).


- Complain to a supervisory authority (see below) (Art. 77 GDPR).

11. Right to Object

If your personal data is processed on the basis of legitimate interests according to Art. 6 (1) sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided there are reasons arising from your particular situation or the objection is against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation.

12. Data Security

Your data is protected using SSL encryption and organizational measures (TOM) within the company.

13. Retention Period

Your data is processed confidentially and responsibly as described in this privacy policy and in accordance with applicable data protection law. We only store data as long and to the extent required for the described purposes or for legal reasons.

14. Contact Details

This privacy policy applies to data processing by:
Tenity Group AG
Pfingstweidstrasse 110
8005 Zurich
Switzerland
info@tenity.com

Data Protection Officer

Andreas Anton Iten
Tenity Group AG
Pfingstweidstrasse 110
8005 Zurich
andreas.iten@tenity.com
www.tenity.com


Supervisory Authority (in Switzerland): Federal Data Protection and Information Commissioner, FDPIC
Feldeggweg 1
3003 Bern, Switzerland
www.edoeb.admin.ch/edoeb/en/home.html

15. Validity and Amendment of this Privacy Policy

We can change or adjust this privacy policy at any time. The current privacy policy can be accessed at www.tenity.com

SFDR Disclosures – Tenity Incubation GP II S.à r.l. and Tenity Incubation Fund II SCSp

December 27, 2022

Tenity Incubation GP II S.à r.l. (the AIFM), a Luxembourg-based registered alternative investment fund manager within the meaning of article 3(2)(b) of Directive 2011/61/EU of 8 June 2011 on alternative investment fund managers (AIFMD), makes the following disclosures for the purposes of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR) and Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (the Taxonomy Regulation).

The AIFM acts as registered alternative investment fund manager of Tenity Incubation Fund II SCSp (the Fund).

I. AIFM-related disclosures

Transparency of sustainability risk policies – article 3(1)

General overview

Sustainability risks are defined in SFDR as environmental, social or governance ("ESG") events which if they occur could cause an actual or a potential negative impact on the value of the Fund's investments (sustainability risks are referred to herein as "ESG risks").

Sustainability due diligences may be conducted on an ad hoc basis for the Fund before making an investment to assess potential ESG risks, the status of regulatory compliance, determine the potential for positive contribution to social and/or environmental issues and set up the management structures to measure, report and verify performance. There can be no assurance, however, that such due diligence will reveal all ESG risks or sustainability liabilities relating to an investment that could emerge from adverse impact or from the failure to perform and positively contribute to environmental or social issues.

Relevance of sustainability risks

Based on the Fund’s investment objective and investment strategy, the AIFM considers that ESG risks will have a limited impact on the returns of the Fund.

No consideration of adverse impacts of investment decisions on sustainability factors – article 4(1)(b)

Principal adverse impacts are defined in the SFDR as those impacts of investment decisions that result in negative effects on sustainability factors. For the purpose of the SFDR, sustainability factors comprise environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

Article 4(1) of the SFDR requires fund managers such as the AIFM to provide a clear statement as to whether or not they consider such principal adverse impacts.

Although ESG and sustainability risks are important to the AIFM, the latter does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by article 4(1) of the SFDR, in particular due to the fact that (i) no reliable and sufficiently available or accessible data are available to perform such impact measurement and provide the mandatory reporting imposed by the regulatory technical standards in a consistent manner; (ii) the investment strategy and objectives of the Fund and thus its overall portfolio are neither ESG-focused nor, in the opinion of the AIFM, likely to have an impact on sustainability factors and (iii) the underlying investments are not generally required to, and may not currently, report on such factors.

Fund-related disclosures

Transparency of other financial products in pre-contractual disclosures and in periodic reports – article 7 of the Taxonomy Regulation

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.