Effective Date: 12 September 2023

The purpose of this policy

The purpose of this policy is to provide you with information about how the ICP group processes personal data and apply cookies when you use this website and how we process personal data as part of our business.

This website

1.        Introduction of the controller

Industry Capital Partners AS (org. no. 928 892 050), part of the ICP group, is responsible for ensuring that we process your personal data in compliance with Norwegian privacy laws, including the General Data Protection Regulation (often referred to as GDPR) when you use this website. It is this company we refer to when we use terms as “we”, “us”, or “our” in the part of this policy that relates to this website.   

2.            What personal data do we process on our website and for what purpose?

2.1          Hosting

Our website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:

Information about your browser, network, and device

Web pages you visited prior to coming to this website

Web pages you view while on this website

Your IP address

Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalized form.

2.2          Cookies

Cookies are small pieces of data that websites store on a device. This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. Cookies can improve your browsing experience because they help websites remember preferences and understand how people use different features. For information about viewing the cookies dropped on your device, visit the cookies Squarespace uses.

These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.

These analytics and performance cookies are used on this website, as described below, only when you acknowledge our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.

You can manage your cookie preferences in your browser parameters.

2.3          Analytics

This website collects personal data to power our site analytics, including:

Information about your browser, network, and device

Web pages you visited prior to coming to this website

Your IP address

This information may also include details about your use of this website, including:

Clicks

Internal links

Pages visited

Scrolling

Searches

Timestamps

We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.

2.4          Webforms

When you submit information to this website via webform, we collect the data requested in the webform in order to track and respond to your submissions. We share this information with Squarespace, our hosting provider, so that they can provide website services to us. We also share this information with Zapier for data porting.

You can reach any of our teams by using the webform on this website. Each team represents different corporate entities within the ICP group. We will transfer your request to the team you choose when contacting us via the webform. The receiving team will be the controller of the further processing of your request. See below for information on how we process personal data as part of our business activities.

Our business

1.            Introduction of the controller

There are four corporate entities in the ICP group that is licensed or in the process of applying for a license from the Norwegian Financial Supervisory Authority. These corporate entities are:

·         Industry Capital Partners AS (org. no. 928 892 050)

·         ICP Ventures AS (org. no. 928 892 107)

·         ICP Asset Management AS (org. no. 931 550 802)

·         ICP Infrastructure AS (org. no. 929 048 539)

Each of these corporate entities process personal data as part of their business. In this context, each corporate entity is the controller of the personal data they process. Unless other is specified, we refer to each of the controller entities by using the terms “we”, “us”, or “our” in the part of this policy that relates to our business.

2.            Professional investors and their employees or representatives

Our firm provides services to professional investors. In order to provide these services, we engage with employees and other representatives of our clients and potential clients. If you are an employee or other representative of our clients or potential clients, we may process your personal data when providing our services. This is limited to information related to your professional life, such as your name, title, and professional contact information. The legal basis for the processing is our legitimate interest.

We also process personal data about professional experts and contacts that can provide services or advice to our firm. We collect this data from publicly available sources or directly from the professional expert, for example where an expert provides us with a business card. We only process personal data relating to the expert’s professional life, including name, title, professional contact information, and area of expertise. The legal basis for the processing is consent.

We process this data using data centres located within the European Union (EU)/ European Economic Area (EEA). However, these services may be provided by companies registered outside the EU/EEA and/or include support services provided from such countries. This means that your personal data could potentially be transferred out of the EU/EEA, for example when we use support services. We are diligent in our choices of service providers and have implemented measures to ensure that the level of protection of personal data within the EU/EEA travels with your personal data if it is transferred out of the EU/EEA.

We do not retain your personal data longer than necessary and will delete it upon your request or once the purpose for the processing is no longer present in accordance with our internal routines or applicable law.

We may share information about our funds and business through cloud-based solutions (data rooms) that require you to register with a personal account. We are the controller of all personal data we populate into the solutions. However, the provider of the solution is the controller of our account data. Please refer to the relevant solution for more information about how they process your personal data.

3.            Legal obligations

We are under legal obligation to register conflict of interest situations and mitigating measures in this relation, keep insider lists, complete customer control for anti-money laundering purposes, collect information for the Foreign Account Tax Compliance Act (FATCA)/Common Reporting Standard (CRS), and to collect information necessary to classify investors as professional investors. The minimum retention period for this information is five years. We may be obligated to share this information with the Financial Supervisory Authority of Norway or the National Authority for Investigation and Prosecution of Economic and Environmental Crime. We might also need to share the information with our legal advisors.

4.            Voice recordings

Industry Capital Partners AS is obligated by law to record telephone conversations with investors and potential investors when  providing investment services, and to document communication through other communication channels. This data shall be stored for a minimum period of five years and will normally be deleted after this mandatory retention period. The retention period is calculated from the collection date. The records shall be made available to the Norwegian Financial Supervisory Authority and to our clients upon their request. The records will also be made available to you as a data subject. See below for information on how to contact us.

Your rights as a data subject

You have the right to access, rectify, and erase your personal data. You may object to the processing and request us to restrict the processing, as well as the right to data portability. If you are not satisfied with how we process your personal data we hope you contact us, but you may also lodge a complaint with the Norwegian Data Protection Authority. 

To use your rights as a data subject or if you have any questions on how any of the corporate entities in the ICP group process personal data, please reach out to privacy@incp.com.

Updates to this Privacy and Cookie Policy

We may update this Privacy and Cookie Policy from time to time. When we make changes, we will update the “Effective Date” at the top of the Privacy and Cookie Policy and post it on our site. We encourage you to check back periodically to review this Privacy and Cookie Policy for any changes since your last visit.