Privacy Policy

Planet First Partners Gérant Sàrl, with offices 9B Boulevard du Prince Henri, register with the Trade and Companies under number B250999 (collectively “Company”, “we”, “us”, “our”) are committed to safeguarding the personal data it processes in connection with its business in accordance with fair information practices and applicable data protection legislation.

Please note that this Privacy Notice must be read in conjunction with our Website User Disclaimer and Cookie Policy.

1. Scope
This notice (“Privacy Notice”) explains how the Company, in its capacity as data controller, treats the personal data of its business contacts as well as services providers, agents, consultants, and website visitors (“you”, “your”), in the framework of its activities.

2. How We Collect Personal Data
We collect your personal data :

• at the occasion of business events, meetings, networking events or similar occurrences, regardless of whether they occur in our offices or at an external location, including, as the case may be, through CCTV or other access systems;
• while conducting public searches on professional or social-media databases;
• which is publicly disclosed;
• when you visit our website (please refer to our Cookie Policy for more information ).
We collect personal data, either directly from you or from third parties, including public databases or social media platforms.

3. Type of Personal Data We Collect
In the normal course of our activities, we collect the following types of personal data:

• Contact information, such as your name, home and professional address, email address, date of birth, gender, phone number and images taken by CCTV or access systems;
• Due diligence information in connection with an actual or prospective corporate transaction or investment, including information about your employer, your own company, your business and your contacts;
• Relationship information that helps us do business with you and contact preferences;
• Compliance and risk management information, such as information for fraud prevention;
• Upon visiting our website: IP address, information about your operating system, internet server provider and software, the pages accessed within our Website, the link that laid to our Website, geolocation information, etc.

4. Use of Your Personal Data
We collect your personal data for the purpose of current or future business relationships with you and more preciselyfor the purposes specified below.
We use your personal data for the following purposes:

• Fulfilling our legal obligations;
• Managing your ongoing relationship with us, including communicating with you;
• Providing and improving our business operations;
• Legal defense and compliance, including compliance with government authority requests for information, liens, garnishments and tax compliance;
• Internal reporting and auditing; and
• Protection of the Company, its workforce and the public against injury, theft, legal liability, fraud, abuse, or threat to the security of our networks, communications, systems, facilities and infrastructureand for other legitimate interests.

We use the following legal bases for the processing of your personal data:

• Compliance with the legal obligations to which we are subject;
• The need to process your personal data for contract performance or to take steps to enter into a contract with you;
• Where the processing is necessary for our legitimate business interests including notification of an investment/divestment opportunity, due diligence activities,professional advice or input in relation to an investment/divestment or with respect to one of our portfolio companies, professional advice in connection with the Company’s business or its employees,operating our business properly, protecting against fraud and other liabilities, ensuring compliance and our ability to assert legal defenses, guarantying the security and proper functioning of our networks and systems, and protecting our assets; and
• Your consent, in some specific circumstances, such as conducting direct marketing.

5. Disclosures and Categories of Recipients
We have taken measures to ensure that your personal data is processed in a manner that is compatible with the purposes indicated above. For the stated purposes, your personal data may be disclosed to, or received from, the following parties:

• Other Company entities, joint ventures, investee companies, subcontractors, vendors or suppliers who perform services on our behalf for the aforementioned purposes;
• A newly formed or acquiring organization if the Company is involved in a merger, sale or a transfer of some or all of its business;
• Certain service providers as necessary or useful to fulfill the aforementioned purposes, such as data hosting providers;
• Any recipient, if we are legally required to do so, such as by court order, applicable laws or regulatory requirements; or
• Any recipient when reasonably necessary such as in the event of a life-threatening emergency.

6. International Transfers
We may transfer your personal data to countries that have not been found by the European Commission to provide adequate protection. Where such transfers occur, we will ensure that adequate protection exists either through appropriate contractual arrangements or as required by law.

7. Information Security
We treat your personal data through automated and/or paper-based data processing systems and, as the case may be, CCTV. We have established routine processing functions.
We take precautions to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have taken appropriate technical and organizational measures to protect the information systems on which your personal data is stored, and we contractually require our suppliers and service providers to protect your personal data.

8. Your Personal Data Rights
In accordance with and subject to fulling the requirements under the applicable data protection legislation, you have the following rights:

• Right of access: access your personal data detailing what personal data is being processed and for what purpose;
• Right to opt out: withdraw your consent at any time where your personal data is processed with your consent;
• Right of correction: update or correct your personal data so that it is accurate;
• Right to be forgotten delete your personal data from our records if it is no longer needed for the purposes indicated in this notice. Once you have informed us of this request, we shall erase your personal data unless permitted by law;
• Right to restrict processing: restrict the processing of your personal data in certain circumstances, such as where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
• Right to object: object to us processing your personal data or to tell us to stop processing your personal data. Once you have informed us of this request, we shall no longer process your personal data unless permitted by law; and
• Right to data portability: obtain your personal data in an electronic format and to request that we transmit this data to another data controller.

You may exercise these rights free of charge. However, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, we may refuse to act or we may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation or infringe applicable law.

9. Personal Data Retention
Your personal data will be retained as long as necessary to achieve the purposes stated in this notice, or in accordance with our legal and regulatory obligations. Our retention policies reflect applicable local statute of limitation periods and legal requirements.

10. Cookies
Please refer to our Cookie Policy for more Cookie Policy

11. How to Exercise Your Rights or File a Complaint
If you wish to exercise any of the rights awarded to you under chapter 8 above or have a question, request or complaint related to how we process your personal data, please contact usvia the communication channel of your choice:
- email: privacy@planetfirst.partners
- post: Planet First Partners Gérant Sàrl, 9B Boulevard du Prince Henri, L-1724 Luxembourg
In addition, you have the right to file a complaint with the Luxembourg data protection authority via https://cnpd.public.luor with any other relevant data protection authority.

12. Updates
We may review this Privacy Notice and update it from time to time to reflect any changes to the way in which we process personal data without obligation to inform you. We will post such changes on our website, so we invite you to regularly check this Privacy Notice for updates.
This Privacy Notice was last updated on September 14, 2020.

Copyrights & Disclaimer

This website (www.planetfirst.partners.com) is operated by Planet First Partners Gérant Sàrl, with offices at 9B Boulevard du Prince Henri, register with the Trade and Companies under number B250999(collectively “Company”, “we”, “us”, “our”).

Access to and use of this website (the “Website”) is subject to the following terms and conditions (“Disclaimer”), which we invite you to read carefully. By visiting this Website or by any other use thereof, you are expressly deemed to accept the Disclaimer. If you disagree with the content hereof, you are kindly requested to discontinue your use of this Website.

1. Purpose and Content of this Website
This Website is intended to provide you with information regarding PlanetFirst Partners and its investee companies.

2. Nature of the Information Offered
The information available on this Website is of a general nature and for information purposes only. Neither this Website nor the information contained herein, constitute an investment, financial or other advice or recommendation or anoffer to subscribe for securities, a placement of securities or a solicitation of an offer to buy any securities nor shall it be considered as a public offering of any securities, including the securities of PlanetFirst Partners (the “Holding”).

3. Risk Allocation and Liability
The use of this Website and the information contained thereon occurs exclusively at your own riskand you shall assume full responsibility for your use of any information herein.

We cannot guarantee that our Website will always be available or be uninterrupted. We may suspend, withdraw, discontinue or change all or part of this Website without notice.

While we take care in seeking to present accurate, transparent and useful information, we cannot guarantee that information is up-to-date, complete and correct. This Website may include information based on hypothetical assumptions, estimates, statements, models or other analysis by the Holding, which may or may not be subject to change without notice and no reliance may be placed thereon. Any performance information included herein shall not constitute an indication or guide for future performances and no guarantees are given in that respect. All information contained in this document has been prepared in good faith at the date hereof, without however providing any representation or warranty as to its accuracy or completeness nor as to its suitability at a later point in time and without incurring any liability in respect thereof. We are under no obligation to provide any updates or revisions of the information provided.

This Website is not intended to form the basis of any investment decision. A potential investor is recommended to seek professional advice, including investment, legal and tax advice and other advice it deems relevant.

The distribution of information and the subscription to investment funds may be prohibited by law in certain jurisdictions or subject to prior authorizations from competent authorities. This Website is intended for visitors in the European Union only and is not addressed at physical or legal persons which are subject to such law as a consequence of their nationality or residence. Such persons are invited to consult the restrictions applicable to them.

We will make reasonable efforts to protect this Website against computer viruses and other malware. Taking into account the nature of these dangers, you however acknowledge that we cannot offer protection and you will take the necessary measures to protect your hardware systems.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this Website. In addition, you will hold us harmless from and against any third-party claims directly or indirectly caused by or resulting from a violation of this Disclaimer by you.

4. Hyperlinks
This Website may contain hyperlinks to other websites deemed potentially interesting to you, but over which we have no technical or content control. Such links are provided for your convenience and information only and do not entail our approval, endorsement or recommendation of the statements made or the products and services referred to thereon. We accept no liability for any direct or indirect damages from clicking these hyperlinks.
Links to this Website are prohibited, unless we have given you our prior written consent.

5. Intellectual Property
The names and logos of PlanetFirst Partners are legally protected trademarks. Any use of these or similar names and signs is prohibited without our prior written consent. Any texts, analysis, images, video files and other information contained on the Website are the property of us or of our licensor. They may not be reproduced or distributed to the public without our prior written consent.

6. Miscellaneous
In case any provision of this Disclaimer is proven unlawful, invalid or for any other reason unenforceable, this Disclaimer will be interpreted as if the unlawful, invalid or unenforceable provision had never been included and we shall be entitled to remove this provision from the Disclaimer without affecting the validity or enforceability of the remaining provisions.

7. Applicable law and applicable court
The use of this Website is governed by Luxembourg law and shall be interpreted accordingly. By using this Website, you expressly agree that disputes regarding the validity, the interpretation or implementation of this Disclaimer shall be settled by the courts of the city of Luxembourg, in the Grand Duchy of Luxembourg.

8. How to Contact us
For further information or in case of questions, please contact usvia email
on contact@planetfirst.partners.

9. Updates
We may review this Disclaimer and update it from time to time. We will post suchchanges on our w-Website, so we invite you to regularly check this Disclaimer for updates.
This Disclaimer was last updated on July 27, 2020.

Cookie Policy

When you visit our website, Planet First Partners Gérant Sàrl, with offices at 9B Boulevard du Prince Henri, register with the Trade and Companies under number B250999(collectively “Company”, “we”, “us”, “our”) may collect your personal data by automated means, using cookies or pixel tags.

Please note that this Cookie Policy must be read in conjunction with our Website User Disclaimer and Privacy Notice.

1. About cookies, pixel tags and social plugins
Cookies are small pieces of text sent by your web browser to our website upon your visit. Such cookie-file is stored within your web browser and allows the website or a third party to recognize you.

Pixel tags are small blocks of codes that help tracking your use of the website.

Our website also uses social plugins of the Facebook social network, implying that your browser connects directly to the Facebook server, allowing Facebook to obtain the information that you access on our website even if you do not have a Facebook account or when you are not logged in to your Facebook account.

For more information, including how to manage cookies, you can visit www.allaboutcookies.org and www.youronlinechoices.eu .

2. Reason for their use
We use cookies, pixel tags and social plugins to improve the use and functionalities of our website, to analyse your use of our website and for compiling statistics. Cookies can be placed by us or by third parties.

3. Type of information collected
For the type of information that we collect when you visit our website, please refer to our Privacy Policy

4. Details of cookies used

Hereafter you can find the main cookies that we use on our website:
- Goolge analytics cookies :
    https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
- Wordpress cookies:
    wordpress_[hash]
    wordpress_logged_in_[hash]
    wordpress_test_cookie
    wp-settings-{time}-[UID]

5. Updates
We may review this Cookie Policy and update it from time to time to reflect any changes implemented from time to time.