We are committed to processing personal information with due care and in accordance with applicable data protection law. In this Privacy Statement, ‘We’ are Butterfly Ventures Ltd., our subsidiaries, and the limited partnership funds we manage.

This Privacy Statement explains what purposes we handle personal information for, and who we give that information to. It also explains what rights you have regarding your own personal information and provides contact information for any additional questions.

What personal information we handle and for what purposes

We handle our customers’ information to manage and develop our business and the customer relationship, and to fulfill our contractual and legal obligations. Our customers are the investors and investee companies of the funds we manage, and other investors or potential investors and investee companies.

We handle our business partners’ information to manage and develop our business and the business partnership, and to fulfill our contractual and legal obligations. Our business partners are our service providers and business partners, other parties co-operating with us or in contact with us, and potential service providers and business partners.

We handle employee information to fulfill our employer’s duties.

We handle employee candidate information for potential recruitment decisions.

Who we give personal information to

Our principle is that we do not give personal information to a third party, unless due to legislation or authorities.

We also have agreements with certain service providers that as part of the services provided are allowed to process personal data on our behalf. In such cases, we have agreements in place with the service providers to ensure that personal data is properly handled also in such situations.

Data processing in third countries

We operate as an international manager team e.g. in Finland, Sweden, and the United States, and the members of our manager team are allowed to process personal information. We have ensured the appropriate level of data protection also in these situations. We also use tools to store and manage information, and the service providers of these tools may be located also outside the EU or ETA. Such service providers are e.g. Google, Microsoft, and Dropbox. In such cases, we ensure appropriate level of data protection by applying adequate protective actions.

Data protection

We use both technical and organizational methods and protective means to ensure data security. We also restrict access to information by role based access rights.

Storage period

We keep the information as long as it is necessary for our business operations and as required by legislation and industry guidelines. Retention periods vary significantly depending on to what context the information relates to.

Your rights regarding your personal information

  • Right to Access & Transfer Data – You have the right to request a copy of any personal information that we hold about you or to have it transferred to third party. We may ask you to supply appropriate evidence to verify your identity before responding to your request.
  • Right to Update & AmendIf any of the personal information we hold on you is inaccurate, you have the right to have that information corrected or completed where it is incomplete.
  • Right to ObjectYou can object at any time to our processing of your personal information. We shall then no longer process your personal information unless we demonstrate legitimate grounds for our processing.
  • Right to be ForgottenYou can request to have your personal information erased when it is no longer required for us to fulfill our contractual, legal or other obligations, or we are not legally required to retain the information. Where your personal information is no longer required, any request to have the information erased will be carried out without undue delay.
  • Right to Withdraw ConsentYou can withdraw or restrict your consent to marketing or the processing of your personal information completely or partially, where it is no longer required.
  • Right to ComplainIf you feel at any point that we have mishandled your data or infringed upon your rights set out under data protection laws you can let us know by getting in touch with us or lodge a complaint with the supervisory authority responsible for data protection.

Contact information

If you have any questions or feedback about this Privacy Statement or the way your personal information is processed, or would like to exercise one of your rights set out above, please contact us by one of the following means:

Email: info@nullbutterfly.vc

Post: Butterfly Ventures Oy, Lapinlahdenkatu 16, FI-00180 Helsinki

And you also have the right to lodge a complaint with data protection authority. In Finland this authority is The Office of the Data Protection Ombudsman (https://tietosuoja.fi/en).

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This Privacy Statement was last updated on May 23rd, 2018, and may be updated again at any time by publishing an updated version here. The latest version will apply from that revision date.