EU Disclosures
Sustainability related disclosures
On March 10, 2021, the EU Commission’s Sustainable Finance Disclosure Regulation (EU) 2019/2088 (SFDR) entered into force. Systematic Growth falls under the SFDR and Systematic Growth ensures compliance with this regulation. Systematic Growth is required to provide information to investors with regards to the integration of sustainability risks in investment process, the consideration of adverse sustainability impacts, and the promotion of environmental or social characteristics.
Article 8 disclosures
Systematic Growth promotes environmental and social characteristics as defined in Article 8 of (EU) 2019/2088 (SFDR). Website disclosures have been completed using the template for website product disclosure for financial products that promote environmental or social characteristics referred to in Article 24 of Regulation (EU) 2022/1288.
Privacy Policy
This Privacy Policy explains what we do with your personal data. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations. This Privacy Policy applies to the personal data of, website users and other people whose personal data we may process.
For the purpose of applicable data protection legislation, the General Data Protection Regulation (Regulation (EU) 2016/679, (the "GDPR"), the company responsible for the personal data you provide to us is Systematic Management AB, org.nr 559220-0496, Riddargatan 7A, 114 35 Stockholm, Sweden ("Systematic Growth", "we", "us" or "our").
It is important to point out that we may amend this Privacy Policy from time to time.
How do we collect personal data?
We collect personal data in a number of ways, the collection is primarily carried out by us, usually from databases and websites providing information such as name, telephone number, social media profile information etc., often publicly available. We may also receive personal data when you contact us (or any of our other service providers) directly by phone, email or by other means. Personal data may also be provided to us by our service providers (due diligence providers, advisors etc.).
What personal data do we collect?
We describe below the types of personal data we may collect:
We may collect personal data including your name, e-mail address, phone number, job title, shareholdings, ownership information, or any other personal data you may provide to us.
To the extent that you access our website we will also collect certain data from you, as described below in our Cookies Policy.
How do we use personal data?
If you are a current or former shareholder or hold a director position in a company targeted by Systematic Growth for acquisition or investment (the “Target Company”), we, or service providers acting on our behalf, use your personal information in the following ways:
· to comply with legal and/or regulatory requirements;
· to carry out anti-money laundering and "Know Your Customer" checks in accordance with our legal and regulatory obligations;
· storing your details (and updating them when necessary) in our Target Company register;
· contacting you in relation to your shareholding;
· contacting you by e-mail or telephone to promote potential partnerships between Systematic Growth and the Target Company or to send you literature relating to Systematic Growth; and
· keeping records of conversations and correspondence.
If you are a current or former shareholder or hold a director position in a Target Company or someone else we get in contact with such as potential employees, advisors, contractors or collaborators to Systematic Growth (“Prospects”), we, or service providers acting on our behalf, use personal information for informative activities to contact you by email or telephone to describe Systematic Growth or send you literature relating to us (except where you have asked us not to, you have the right to opt out of receiving information materials from us at any time).
If you are a service provider of Systematic Growth or working on behalf of such service provider, we, or service providers acting on our behalf, use personal information in the following ways:
· to store (and update when necessary) details, either ourselves or at another service provider, so that we can contact individuals in relation to our agreements with service providers; and
· to obtain support and services from the service providers
Furthermore, we, or our service providers on our behalf, may provide personal data to our other service providers, provided that the data is used for the purposes described above. We may also share personal data with our group companies for the purposes described above.
How do we store and transfer your data internationally?
In order to carry out the activities described in this Privacy Policy, your data may be transferred between and within entities within our corporate group, to third parties (such as regulatory authorities, advisers or other service providers to Systematic Growth, or their group companies), to a cloud-based storage provider, and to other third parties, as referred to here.
Your data should be stored and transferred in a way that is secure. We will therefore only transfer data outside of the European Economic Area ("EEA") where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
· by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
· in the case of transfer to the US, the transfer is made to an entity certified under the EU – US Privacy Shield or equivalent; or
· transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or
· where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests; or
· where you have consented to the data transfer.
To ensure that your personal information receives an adequate level of protection, we put in place appropriate procedures with any third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
How do we keep personal data secure?
We are committed to taking all reasonable and appropriate steps to protect the personal data that we (or third parties on our behalf) hold from misuse, loss, or unauthorised access. We do this by having in place a range of contractual standards (relating to, amongst other matters, appropriate technical and organisational measures) in agreements with our service providers. These include measures to deal with any suspected data breach. If you suspect any misuse or loss of or unauthorised access to your personal data please let us know immediately. Details of how to contact us can be found below.
How long do we keep personal data?
We, or our service providers on our behalf, will ordinarily process your data throughout the course of our interactions and will then generally retain it for an appropriate period afterwards. The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods. In other instances, there may be legal, regulatory or risk-management reasons for retaining data, including where certain data might be relevant to any potential litigation (bearing in mind relevant limitation periods).
In determining the appropriate retention period for different types of personal data, we always consider the amount, nature and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above).
If you want to know more about handling of personal data, please contact us using the contact information below.
Your legal rights in respect of your personal data
You have the right to ask for a copy of the personal data which we hold about you, subject to certain exceptions. If any of the personal data which we hold about you is incorrect or out of date, please let us know and we will correct it.
You have the right to require an explanation, regarding the processing of your personal data, when such processing is based on us deeming it necessary for our legitimate interests and, if you not accept such explanation, request a review of such explanation. You also have the right to erase any personal data we hold about you and/or request that it be transferred to another data controller, subject to certain exceptions.
Please note that if you exercise any of the rights listed above, we may no longer have the personal data necessary to comply with our obligations to you following such request.
Contacting us
Please contact us at:
Systematic Growth, Riddargatan 7A, 114 35 Stockholm, Sweden,
or email: gdpr@sygrowth.com.
You also have the right to lodge a complaint with a data protection supervisory authority, including in the EU member state of your residence, your place of work or the place of the alleged infringement.
Cookie Policy
Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. Other tracking technologies are also used which are similar to cookies. This can include pixel tags and tracking URLs. All these technologies are together referred to as “Cookies”.
You can always refuse the use of Cookies. Please note that if you delete or disable Cookies from us, you may not be able to access certain areas or features of our website.
How do we use Cookies?
The types of Cookies that we may use on our website, and the purposes for which they are used, are set out below:
Analytical/performance Cookies: These Cookies collect information about how you and other visitors use our website, for instance, which pages you go to most often, and if you get error messages from web pages. We use data from these Cookies to help test designs and to ensure that a consistent look and feel is maintained on your visit to the website. All information these Cookies collect is aggregated and is used only to improve how a website works.
Functionality Cookies: These Cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These Cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video. Additionally, these Cookies can be used to allow an optional service to function. The information these Cookies collect may be anonymised and these Cookies cannot track your browsing activity on other websites.
Pixel tags: These are also known as a clear GIF or web beacon. These are invisible tags placed on certain pages of our website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with Cookies, registering when a particular device visits a particular page. If you turn off Cookies, the pixel tag will simply detect an anonymous website visit.
Tracking URLs: These are used to determine from which referring website our website is accessed.
How to Refuse the Use of Cookies
You may refuse the use of cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality such as personalisation and ‘keep me signed in’ and ‘remember me’ features.