Welcome to Volta’s Privacy Policy

1. Introduction

Volta Ventures (“Volta Ventures”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal data of everyone who interacts with us, whether you visit our website, attend one of our events, work with us as an employee or contractor, found or work at a (potential) portfolio company, or invest (or consider investing) in a fund managed by Volta Ventures.

This Privacy Policy (the “Privacy Policy”) explains which categories of personal data Volta Ventures processes, for which purposes, on which legal ground, for how long, and with whom this personal data may be shared, in each case in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and any other applicable data protection legislation (together, the “Privacy Legislation”).

Volta Ventures acts as the data controller for the processing activities described in this Privacy Policy, unless explicitly stated otherwise.

If you have any questions about this Privacy Policy or about how we process your personal data, please contact us as set out in Section 11 (“Notifications and questions”) below.

2. Scope and categories of data subjects

This Privacy Policy applies to the personal data of the following categories of data subjects, depending on the nature of your relationship with Volta Ventures:

• You visit our website;
• You subscribe to our newsletter;
• You attend (or are invited to) an event hosted by Volta Ventures;
• You are an employee, contractor, or job applicant of Volta Ventures;
• You are a founder, co-founder, member of the key management, or another stakeholder of a (potential) portfolio company;
• You are a Limited Partner (“LP”) in, or a prospective investor of, a fund managed by Volta Ventures.

The processing activity (or activities) relevant to each of these categories, including the purpose, the personal data concerned, the applicable legal basis, and the retention period, is set out in Section 3 below.

3. Processing activities

Volta Ventures processes personal data for the purposes, and on the legal grounds, described below. Where the legal ground for a given processing activity is “legitimate interest”, Volta Ventures has carried out a balancing test to ensure that this interest is not overridden by your own interests or fundamental rights and freedoms (see Section 4 below).

3.1. You visit our website

Website marketing and web inquiries

Purpose: Operating and improving the Volta Ventures website, responding to inquiries submitted through our contact form, managing cookie consent, preventing spam and abuse, and understanding how visitors use our website through web analytics.

Personal data:

• Firstname, Lastname
• Email address
• IP address
• Cookie and consent preferences, and other data collected via cookies and similar tracking technologies

Legal basis:

• Consent: for non-essential (statistics and marketing) cookies and the related tracking of your browsing behaviour;
• Legitimate interest: for the essential operation and security of our website (e.g. spam and abuse prevention) and to respond to inquiries you submit to us, in accordance with the GDPR and balancing test.

Retention period: Personal data collected via cookies is retained in accordance with the retention periods set out in our Cookie Policy. Personal data submitted via the contact form is retained for as long as necessary to handle and follow up on your inquiry, and in any event no longer than is necessary in light of that purpose.

3.2. You subscribe to our newsletter

Newsletter distribution

Purpose: Managing our distribution list, sending and publishing our newsletter, and tracking engagement with our newsletter (e.g. opens and clicks) in order to improve its content and relevance.

Personal data:

• First name
• Last name
• Email address
• Language

Legal ground: Consent.

Retention period: Until you unsubscribe or otherwise withdraw your consent, after which your personal data will be removed from our distribution list (cfr. Section 8 – “Your privacy rights”).

3.3. You attend an event hosted by Volta Ventures

Event management

Purpose: Organising and managing (smaller) events dedicated to our Limited Partners and/or our portfolio companies, including invitations, registrations, and attendee follow-up.

Personal data:

• First name
• Last name
• Email address
• Job title

Legal ground:

• Consent: for invitations and registration; or,
• Legitimate interest: for the organisation, management, and security of the event itself, in accordance with the GDPR and balancing test.

Retention period: Until you have objected to the processing of your personal data for this purpose (cfr. Section 8 – “Your privacy rights”), and in any event no longer than necessary to organise the event and handle any related follow-up.

3.4. You are an employee, contractor, or job applicant of Volta Ventures

HR administration

Purpose: Administering the employment or contractor relationship, including recruitment for open roles, contract administration, payroll, statutory social security reporting, benefits management, performance management, absence and leave tracking, expense reimbursement, and offboarding.

Personal data:

• First name and last name
• Address
• Age and date of birth
• National identity number
• Bank account number
• Education and professional skills
• Employment history
• Email address and phone number
• Employee ID
• Job title
• Language
• Income bracket and salary

Legal ground:

• Contract: to perform the employment agreement, contractor agreement, or in order to take steps prior to entering into such an agreement (e.g. recruitment); or,
• Legal obligation: to comply with applicable employment, social security, and tax legislation.

Retention period: For the duration of your employment or contractor relationship with Volta Ventures and, thereafter, for as long as required to comply with applicable statutory retention obligations (e.g. social security, tax, and employment law). Personal data of unsuccessful job applicants is retained for a limited period after the recruitment process has ended, in accordance with our internal retention policy, unless you have consented to a longer retention period for future opportunities.

3.5. You are a founder, co-founder, key manager, or other stakeholder of a (potential) portfolio company

This category includes founders and co-founders, members of key management, and other stakeholders of companies that Volta Ventures is sourcing, evaluating, has invested in, or otherwise manages as part of its portfolio.

3.5.1 Sourcing and inbound

Purpose: Identifying investment opportunities, contacting new opportunities, responding to inbound communications, and performing an initial screening.

Personal data:

• Education
• First name
• Last name
• Email address
• Job title
• Company name
• Company address

Legal ground: Contract: to take steps, at your request, prior to entering into a potential investment agreement.

Retention period: For as long as necessary to assess the investment opportunity, and in any event no longer than is required in light of the purpose described above and our internal retention policy.

3.5.2 Due diligence

Purpose: Performing commercial and legal due diligence, and carrying out KYC/AML (know-your-customer / anti-money laundering) verification, prior to making an investment.

Personal data:

• First name
• Last name
• Job title
• Email address
• Phone number
• Criminal records (where legally required and permitted, e.g. as part of KYC/AML or integrity screening)

Legal ground: Contract: to take steps, at your request, prior to entering into an investment agreement.

Retention period: For the duration of the due diligence process and, where an investment is made, for the duration of Volta Ventures’ investment, and in any event in accordance with applicable anti-money laundering legislation, which generally requires retention of identification data for a minimum of five (5) years – and up to ten (10) years in certain jurisdictions – after the end of the relevant relationship.

3.5.3 Portfolio management

Purpose: Monitoring and managing the portfolio company, including board seat monitoring and assistance during value creation, and informing shareholders of, and facilitating, their shareholder rights.

Personal data:

• First name
• Last name
• Email address

Legal ground: Contract: to perform the shareholders’ agreement, investment agreement, or other contractual arrangement with the portfolio company.

Retention period: For the duration of Volta Ventures’ investment in the portfolio company and during a period thereafter in accordance with our internal retention policy and any applicable statutory retention obligations.

3.5.4 Business contact management (CRM)

Purpose: Maintaining a database of business contacts, covering founders (of current and prospective portfolio companies), co-investors, advisors, service providers, corporate partners, and other ecosystem contacts. Contacts may be sourced from inbound enquiries, referrals, events, LinkedIn, and other public sources, and profile data may be enriched using publicly available information.

Personal data:

• First name
• Last name
• Email address
• Phone number
• Job title
• Employee ID (where applicable)
• Company name
• Company address

Legal ground: Contract: to manage and maintain our business relationship with you and/or your organisation, or to take steps, at your request, prior to entering into such a relationship.

Retention period: For as long as you (or the company you represent) remain a relevant business contact for Volta Ventures, and for a limited period thereafter in accordance with our internal retention policy.

3.6. You are a Limited Partner or a prospective investor

This category includes Limited Partners (“LPs”) of, and prospective investors in, a fund managed by Volta Ventures.

3.6.1 Onboarding and fund structuring

Purpose: Identifying and verifying prospective Limited Partners prior to their admission into a fund, including fund structuring, drafting of articles of association and the limited partnership agreement (LPA), KYC/AML checks, entry into the LP register, and processing of any transfer of units or interests between LPs.

Personal data:

• First name
• Last name
• National identity number
• Copy of identity card
• Address
• Email address
• Phone number
• Bank account number

Legal ground:

• Legal obligation: to comply with applicable KYC/AML legislation; and,
• Contract: to perform the limited partnership agreement, or to take steps, at your request, prior to entering into it.

Retention period: For the duration of your investment in the relevant fund and, thereafter, in accordance with applicable anti-money laundering legislation, which generally requires retention of identification data for a minimum of five (5) years – and up to ten (10) years in certain jurisdictions – after the end of the business relationship.

3.6.2 Fund administration and cash flow

Purpose: Administering capital calls, distributions and waterfalls, booking of transactions, and maintaining each LP’s capital account, reflecting commitments, drawdowns, distributions, and carried interest.

Personal data:

• First name
• Last name
• Email address
• Phone number
• Bank account number
• Payment history
• Employment history (where relevant to your investor profile)

Legal ground:

• Contract: to perform the limited partnership agreement; and,
• Legal obligation: to comply with applicable fund administration, accounting, and tax legislation.

Retention period: For the duration of your investment in the relevant fund and during a period thereafter in accordance with our internal retention policy and any applicable statutory (e.g. accounting and tax) retention obligations, unless Volta Ventures has a legal obligation to retain your personal data for a longer period.

3.6.3 LP reporting and communication

Purpose: Preparing and distributing quarterly reports, annual accounts, audit-related communications, materials for the Limited Partner Advisory Committee (LPAC), and other ad hoc communications regarding fund performance and governance matters.

Personal data:

• First name
• Last name
• Email address
• Phone number

Legal ground:

• Contract: to perform the limited partnership agreement; and,
• Legal obligation: to comply with applicable fund reporting and audit legislation.

Retention period: For the duration of your investment in the relevant fund and during a period thereafter in accordance with our internal retention policy and any applicable statutory retention obligations.

4. Legal grounds

You can find more information on the applicable legal ground for each processing activity in Section 3 above. Volta Ventures relies on the following legal grounds, depending on the processing activity concerned:

• Consent: where you have given your free, specific, informed, and unambiguous consent to the processing of your personal data for one or more specific purposes;
• Contract: where the processing is necessary to perform a contract to which you are a party, or to take steps, at your request, prior to entering into such a contract;
• Legal obligation: where the processing is necessary to comply with a legal obligation to which Volta Ventures is subject (e.g. KYC/AML, accounting, tax, or employment legislation);
• Legitimate interest: where the processing is necessary for Volta Ventures’ legitimate interests, provided these are not overridden by your own interests or fundamental rights and freedoms.

Where the legal ground for processing is legitimate interest, Volta Ventures shall always (i) assess whether the processing is proportionate to the purpose for which your personal data was collected and used; and (ii) take your reasonable expectations into account and ensure a balance with your fundamental rights and freedoms. If we cannot guarantee this, we will stop processing your personal data for that purpose, or we will determine a new legal ground.

5. Retention periods

You can find more information on the retention period applicable to each processing activity in Section 3 above. As a general principle, Volta Ventures does not retain personal data for longer than is necessary in light of the purpose(s) for which it was collected, after which it is deleted or anonymised, unless:

• We are subject to a legal obligation to retain your personal data for a longer period (e.g. accounting, tax, employment, or anti-money laundering legislation); or
• Retention is necessary for Volta Ventures to establish, exercise, or defend its legal rights (e.g. in the context of (future) legal proceedings).

6. Disclosure of personal data to third parties

Volta Ventures does not disclose your personal data to third parties, unless this is necessary to achieve the purposes described in this Privacy Policy. In this respect, (some of) your personal data may be disclosed to the following categories of recipients, including the service providers we currently use for the purposes indicated:

• Cloud, productivity, and storage providers (e.g. Google / G Suite, Dropbox);
• Customer relationship management (CRM) providers (e.g. Pipedrive);
• Email marketing and newsletter providers (e.g. MailerLite);
• Electronic signature providers (e.g. DocuSign);
• Website analytics and cookie consent management providers (e.g. Google Analytics, Google Tag Manager, Google reCAPTCHA, Complianz);
• Other software, IT, and professional service providers engaged by Volta Ventures, including freelancers, management companies, auditors, and legal or tax advisors.

We have concluded the necessary contracts or similar legally binding instruments with the above-mentioned third parties to ensure that they treat your personal data in accordance with the Privacy Legislation (e.g. Article 28 GDPR).

In addition, we might transfer your personal data to competent authorities, for instance because (i) we are obliged to provide your personal data on the basis of the law, regulations, circulars, or guidelines, or in the scope of (future) legal proceedings, or (ii) this is necessary to safeguard our rights.

7. Cross-border processing of personal data

In case any of the above-mentioned third parties or other recipients are located in a country outside the European Economic Area, Volta Ventures will ensure that one or more of the following EU-approved safeguards are in place:

• A European Commission adequacy decision;
• A data transfer agreement (cfr. the Standard Contractual Clauses provided for in European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including, where required, the performance of a transfer impact assessment); or
• An appropriate certification mechanism.

8. Your privacy rights

The Privacy Legislation (e.g. the GDPR) gives you certain rights over your personal data vis-à-vis Volta Ventures. You can exercise these rights by contacting Volta Ventures, as specified in Section 11 below, and, where applicable, by using a Data Subject’s Rights Form (see Annex I).

• Access: you can ask Volta Ventures to confirm whether or not personal data relating to you is being processed. If so, you can ask us to provide you with a copy of your personal data;
• Rectification: you can ask Volta Ventures to correct or complete any information you believe is inaccurate or incomplete;
• Erasure: you can ask Volta Ventures to erase your personal data, under certain conditions and to the extent possible in accordance with applicable law, regulations, circulars, or guidelines;
• Objection: you can object to Volta Ventures’ processing of your personal data, under certain conditions and to the extent possible in accordance with applicable law, regulations, circulars, or guidelines;
• Restriction of processing: you can ask Volta Ventures to restrict the processing of your personal data, unless we have legitimate interests for the processing of your personal data that prevail over your interests;
• Data portability: you can ask Volta Ventures to transfer your personal data to another organisation, or directly to you, in a commonly used, structured, machine-readable format, under certain conditions and to the extent possible in accordance with applicable law, regulations, circulars, or guidelines.

Updates / Newsletters. You can always change your communication preferences. If you no longer wish to receive any communications from Volta Ventures, you can object to these direct marketing communications by using the Data Subject’s Rights Form (as indicated above) or by otherwise contacting us as set out in Section 11. Upon receipt of your objection, we will stop processing your personal data for that purpose.

9. Security

Volta Ventures undertakes to take all reasonable physical, technological, and organisational precautions to avoid (i) unauthorised access to your personal data, and (ii) loss, abuse, or alteration of your personal data.

Notwithstanding the verification and audits carried out by Volta Ventures and its legal (privacy) advisors, and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission over the internet, or method of electronic storage, is 100% secure, Volta Ventures is not in a position to guarantee absolute security. Volta Ventures does perform email and browsing security scanning.

The security of your account (if applicable) will also partly depend on the confidentiality and complexity of your password. Volta Ventures will never ask for your password, meaning that you will never be required to communicate it to Volta Ventures or any third party. If you observe that someone has accessed your account without authorisation, we strongly advise you to change your password immediately and contact us.

10. Updates

We are entitled to update this Privacy Policy from time to time. Where we do so, we will indicate the revision date at the top of this Privacy Policy. We recommend that you regularly consult this Privacy Policy to stay informed of any changes.

11. Notifications and questions

Notifications under this Privacy Policy (such as exercising your rights as a data subject) and/or any questions or concerns regarding this Privacy Policy must be directed to info@voltaventures.eu.

12. Complaints

In case you have any concern about the manner in which we collect, store, or otherwise process or secure your personal data, we are prepared to take the measures necessary to remedy the situation. Please contact us as specified in Section 11 above.

You also have the right to lodge a complaint with the competent supervisory authority, generally the data protection authority of (i) your habitual residence, (ii) your place of work, or (iii) the place where the alleged infringement occurred, should you consider that the processing of your personal data infringes the Privacy Legislation. You can contact the Belgian Data Protection Authority at contact@apd-gba.be (https://www.dataprotectionauthority.be/citizen/actions/contact), or the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at https://www.autoriteitpersoonsgegevens.nl.

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