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 Notice
Last updated on 27 November 2025
1. GENERAL
1.1 At Systematic Growth (officially registered as “Systematic Management AB”, org. number 559220-0496, with registered address at Birger Jarlsgatan 20, 114 34 Stockholm, Sweden) ("Systematic Growth", "we" or "us") our goal is not only to make multiple acquisitions but also to build strong well-functioning groups that can make a difference for the societies of tomorrow. To support this mission and ensure that our activities run smoothly, we need to process certain categories of personal data about you, which will depend on the specific context of our interactions.
This privacy notice (“Notice”) explains how Systematic Growth and all companies forming part of the Systematic Growth Group of companies (together, the “Group”) collects, uses, stores, and otherwise processes your personal data (collectively referred to as “processing”). It is intended to provide transparency, helping you understand why and how we process your data and to inform you of your data protection rights.
From a legal perspective, we are controllers of the personal data we collect and further process, which means that we decide over why and how we process the personal data but at the same time we remain responsible for such processing. We are committed to processing personal data in accordance with applicable data protection legislation, including the EU General Data Protection Regulation 2016/679 (“GDPR”) and other applicable national laws.
We see this Notice not just as a legal requirement, but as part of our commitment to treating your data with care and respect. Respecting your privacy is fundamental to the trust we aim to build with you, so if you have any questions about the processing of your personal data, please contact us at privacy@sygrowth.com.
This Notice will guide you through how we handle your personal data. We therefore recommend reading this Notice in full, but if you would like to skip ahead, the links below will take you straight to the sections you’re interested in:
2. SCOPE
3. SOURCES OF PERSONAL DATA
4. HOW WE PROCESS YOUR PERSONAL DATA
4.1 Processing of personal data in relation to the Acquisition ProcessWhen you communicate with us
4.2 When you communicate with us
4.3 When we send you insightful communication
4.4 To plan and execute day-to-day business operations
5. COOKIES AND SIMILAR TECHNOLOGIES
6. RECIPIENTS OF PERSONAL DATA
7. TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EEA
8. YOUR RIGHTS
9. INFORMATION ABOUT CHANGES TO THIS NOTICE
2. SCOPE
In the course of our business activities, we process personal data, which includes any information that can identify you directly or indirectly. This Notice applies to the following categories of individuals with whom we interact:
● Persons involved in the acquisition process, such as the (prospective) selling entrepreneur or a person that holds a director position in a company targeted by us for acquisition or investment (the “Target Company”);
● Participants at events, seminars, and other activities organised by us;
● Individuals who otherwise contact us or send us enquiries, for example through our contact forms, by email, or in person at meetings or events.
● Recipients of our insightful communication;
● Individuals who engage with us in a professional capacity, such as contact persons at our suppliers, business partners, or other organisations we work with.
This Notice applies to the following companies within the Group:
● SG Wellma Holding AB, org. number: 5592673379, Birger Jarlsgatan 20, 114 34, Stockholm, https://www.wellma.com
● SG Allvida Holding AB, org. number: 559267-3361, Birger Jarlsgatan 20, 114 34, Stockholm, https://allvida.com
● SG MotionTech Holding AB, org. number: 559447-7894, Nybrogatan 34, 114 39, Stockholm, https://www.motiontech.com
● SG Ryleon Holding AB, org. number: 559325-1951, Birger Jarlsgatan 20, 114 34, Stockholm, https://www.ryleon.com
● SG Elvirian Platform AB, org. number: 559505-8552, Birger Jarlsgatan 20, 114 34, Stockholm, https://www.elvirian.com
● SG Safecto Platform AB, org. number: 559529-9057, Birger Jarlsgatan 20, 114 34, Stockholm, https://safecto.com
● SG Nilario Platform AB, org. number: 559517-0274, Birger Jarlsgatan 20, 114 34, Stockholm, https://nilario.com
● SG Oxevia Platform AB, org. number: 559548-3420, Birger Jarlsgatan 20, 114 34, Stockholm, https://www.oxevia.com
Please note that this Notice does not apply to individuals who apply for job roles, internships, or other career opportunities via our careers page. Such applications are subject to a separate privacy notice specifically addressing recruitment and applicant data.
We also want to clarify that we do not collect any information that falls under the GDPR’s definition of special categories of personal data (such as data revealing racial or ethnic origin, health status, political opinions, religious or philosophical beliefs, or trade union membership).
1. Sources of Personal Data
The personal data we process about you consists of information you provide to us directly, or that we obtain in the course of our business activities. We collect data, for example:
● From you or your representatives when you interact with us in relation to an Acquisition Process (see section 4.1 for more information)
● When you share information with us in other ways, such as through meetings, phone calls, correspondence, events, social media, or online forms in a general business context
We may also collect or receive information about you from other sources, such as:
● From our business contacts, such as suppliers, advisors, and vendors;
● Public records and official registers (e.g. the Swedish Companies Registration Office (Bolagsverket) and other public authorities);
● Company websites and other publicly available online sources;
● Third-party providers who supply us with business contact details, for example regarding prospective portfolio companies or majority shareholders;
● Professional advisors (such as law firms, auditors, consultants, or investment banks) in the context of transactions or due diligence;
● Industry publications, databases, or media reports.
2. HOW WE PROCESS YOUR PERSONAL DATA
Below, you will find details about how we process your personal data, including the purpose of processing, the categories of personal data involved, the legal basis for processing, and the retention period for each specific purpose.
2.1 Processing of personal data in relation to the Acquisition Process
The personal data we process in connection with acquisitions depends on the step of the process and the specific purpose at that stage.
2.1.1 Identifying opportunities and building relationships
Purpose:
To identify promising niches and companies based on recognised mega-trends, and to build trusted relationships with entrepreneurs and key stakeholders. At this stage, we focus primarily on company-level data. Once a company is shortlisted, we may use contact information of individuals such as shareholders, directors, or representatives in order to initiate discussions, provide information about us, and arrange introductory meetings. If the discussions are successful, this stage may culminate in the signing of a Letter of Intent (“LOI”). Furthermore, as part of fostering strong and long-term relationships, we may occasionally send you tokens of appreciation, such as gifts, in line with our business ethics and applicable legal requirements.
Personal data processed:
At the company-assessment stage:
Information about companies, sectors, and markets, which concerns legal persons and does not fall under the definition of personal data.
At the contact stage:
● Contact details (name, role, title, company, phone number, email address);
● Professional background and role within the company;
● Ownership or shareholding details (where relevant);
● Communication content and other information that you share with us that is relevant to the above-mentioned purposes.
At the LOI stage:
Contractual data necessary for preparing, reviewing, and signing the LOI (e.g. names, roles, signatures, and related correspondence)
Legal bases:
- In relation to contacting you, the legal basis we rely on depends on the requirements applicable in the country where you are located:
● Legitimate interest: We have a legitimate interest in identifying and reaching out to relevant company representatives, shareholders, or directors in order to explore potential partnerships.
● Consent: Where required under applicable marketing or communications laws, for example when sending certain types of information or promotional materials by email, we will only contact you if you have provided your consent.
- At the LOI stage:
Performance of a contract / steps prior to entering into a contract since the processing is necessary to negotiate and sign the LOI.
In relation to the sending of gifts as tokens of appreciation, this processing is carried out on the basis of our legitimate interest in developing and maintaining strong business relationships.
Retention time
The below serve as general criteria for determining retention periods. However, depending on the specific circumstances, we may retain your personal data for a longer period than indicated as the retention time may vary depending on the purpose of processing and applicable legislation:
● Contact and correspondence data are retained for up to 24 months after the last interaction if no transaction proceeds.
● LOI documentation is retained for up to 10 years for legal and evidentiary purposes, in line with the Swedish Limitation Act (Preskriptionslagen, 1981:130).
2.1.2 Transaction Process
Purpose:
To carry out the transaction process, including due diligence and the the steps leading up to the drafting and signing of the Share Purchase Agreement (“SPA”), as well as the signing/closing administration (including any required regulatory filings). This ensures that both parties can evaluate the proposed transaction and comply with legal, financial, and regulatory requirements. As part of this process, certain personal data may be shared with our external legal advisors. These advisors act as independent controllers and will process the data in accordance with their own privacy notices.
Personal data categories processed (depending on applicable jurisdiction):
● Contact and identification data of shareholders and/or their representatives, directors, and company representatives;
● Ownership and shareholding details of shareholder;
● Information provided from shareholders, company representatives, advisors, consultants, or service providers in the context of due diligence;
● Financial, contractual, and regulatory documentation provided or reviewed;
● Transaction data;
● Correspondence and records of negotiations.
● Where applicable, AML checks which in special circumstances could also include criminal conviction
Legal bases:
● Legitimate interest: Our legitimate interest in carrying out due diligence and structuring the partnership, as well as to be able to defend, establish, or exercise legal claims.
● Legal obligation: To comply with legal, tax, or anti-money laundering requirements, as well as the Swedish Companies Act.
● Performance of a contract: Where processing is necessary to prepare and enter into the SPA.
Retention time
The below serve as general criteria for determining retention periods. However, depending on the specific circumstances, we may retain your personal data for a longer period than indicated as the retention time may vary depending on the purpose of processing and applicable legislation:
● Due diligence records and transaction documentation are generally retained for up to 10 years after the closing of the transaction, in line with the Swedish Limitation Act (Preskriptionslagen, 1981:130).
● Certain records (e.g. accounting materials) must be retained for at least 7 years after the end of the financial year, in accordance with the Swedish Accounting Act (Bokföringslagen, 1999:1078).
● Anti-money laundering rules (e.g. the Swedish Anti-Money Laundering Act, Penningtvättslagen, 2017:630) require retention of due diligence documentation for 5 years after the end of the business relationship.
2.1.3 Group Value Creation- Post-transaction stage
Purpose:
To collaborate with entrepreneurs and their companies after a transaction, supporting growth and integration into the group. This includes strategic development, as well as the administration of the incentive program that we offer to our employees and update any changes to the share registers.
Personal data categories processed:
To do that, we will process the following personal data categories from our portfolio company representatives, employees, and other relevant stakeholders within the group:
● Contact details and professional information of company representatives and employees;
● Information necessary for group communication, reporting, and coordination;
● Information related to the incentive program offered to Group employees
Legal bases:
● Legitimate interest: Our legitimate interest in managing and supporting portfolio companies and ensuring effective group collaboration and value creation, as well as defending, establishing, or exercising legal claims.
● Performance of a contract: Where processing relates directly to obligations under the transaction agreements or related cooperation arrangements.
Retention time
The below serve as general criteria for determining retention periods. However, depending on the specific circumstances, we may retain your personal data for a longer period than indicated as the retention time may vary depending on the purpose of processing and applicable legislation:
● Contact details and work-related information will be stored for as long as relevant.
● Certain records may be retained for up to ten (10) years in order to defend against potential legal claims, in line with the Swedish Limitation Act (Preskriptionslagen, 1981:130).
● Records relevant for accounting purposes are retained for at least 7 years after the end of the financial year, in accordance with the Swedish Accounting Act (Bokföringslagen, 1999:1078).
2.2 When you communicate with us
Purpose:
To respond to your inquiries regarding our services when you fill in relevant forms on our website or when you contact us via other communication channels.
Personal data categories processed:
When you contact us, whether through the contact form on our website or by other means, we may process contact details such as your name, email address, phone number, title, address, and any other information you choose to provide related to your request.
Legal basis:
We base the processing on our legitimate interest in responding to your inquiries about our business operations and communicating with you.
Retention time:
Personal information collected during your contacts with us is stored during the time we have an ongoing relationship with you. If we have not heard anything from you in the past 24 months, we will delete your information.
2.3 When we send you insightful communication
Purpose:
From time to time, we may share updates about our business activities, industry insights, and news we consider relevant to our market with you if you are a contact person of a Target Company or a company within our portfolio group.
Personal data processed:
For this purpose, we only process your name and email address.
Legal basis:
Our legal basis for this processing is our legitimate interest in keeping relevant stakeholders informed, maintaining relationships, and strengthening brand awareness.
Retention time:
We will process your personal data until you object to receiving such communications which you can do by contacting us at privacy@sygrowth.com.
2.4 To plan and execute day-to-day business operations
Purpose:
We process personal data to manage and administer our relationships and agreements with partners, suppliers, and other external parties. This includes maintaining and updating our contact lists and ensuring smooth communication with relevant stakeholders and defending, establishing, or exercising legal claims.
Personal data categories processed:
The types of personal data we may process about representatives of client companies, partners, suppliers, and other external parties for these purposes include:
• Contact details such as name, address, email address, and phone number;
• Work-related information, such as employer, role, and job title;
• Case- or agreement-related information, for example, data provided in connection with managing client or supplier engagements;
• Transaction related information, for example invoice reference number.
Legal basis
Our legal basis for this processing is our legitimate interest in managing the relationship with the specific legal entity and its representatives, as well as defending, establishing, or exercising legal claims.
Retention time
The below serve as general criteria for determining retention periods. However, depending on the specific circumstances, we may retain your personal data for a longer period than indicated as the retention time may vary depending on the purpose of processing and applicable legislation:
● Contact details and work-related information will be stored for as long as relevant, for example, while you are a contact person with a partner or supplier, or as long as we maintain a business relationship with them.
● Personal data included in documents that must be retained for accounting purposes will be stored until the end of the seventh (7th) year following the end of the calendar year in which the financial year was closed, in accordance with the Swedish Accounting Act (Bokföringslagen, 1999:1078).
● Agreements and related records may be stored for up to ten (10) years in order to defend against potential legal claims, in line with the Swedish Limitation Act (Preskriptionslagen, 1981:130).
3. Cookies and similar technologies
We collect information about you through Cookies or other similar technologies. These cookies will collect and share technical data with us, such as your IP address and the browser you use. For more information about the types of Cookies we use, what we use them for and how you can prevent the use of cookies, please read our Cookie Notice [here].
4. Recipients of personal data
We may share your personal data with trusted third parties with whom we have agreements ensuring that your personal data is processed in accordance with this Notice. Where relevant, such third parties may include, for example:
● Professional advisors (e.g., legal counsel, auditors, consultants)
● Group companies
● Group portfolio companies
● Third-party service providers, such as those providing IT infrastructure, Cloud services, CRM and email , and other support functions
● Authorities and regulators, where required by law
● Potential acquirers, investors, or other parties in connection with a merger, acquisition, or restructuring
5. Transfers of personal data outside the EU/EEA
We try to process your personal data within the EU/EEA. Sometimes, however, your data may be transferred to countries outside the EU/EEA (“Third Countries”), either by us or by our service providers.
When this happens, we make sure your personal data is protected by putting appropriate safeguards in place. These may include:
● Transfers to countries recognized by the EU Commission as having strong data protection equivalent to the EU/EEA (so called “adequacy decision”); or
● Using approved transfer mechanisms, such as the EU Standard Contractual Clauses (“SCCs”), when the destination country is not considered to provide adequate protection.
If the laws in a Third Country make these clauses less effective, we make sure to add supplementary technical, organisational, or contractual measures to ensure your data stays protected.
For more information about how we handle international data transfers and the safeguards we use, please contact us at privacy@sygrowth.com.
6. Your rights
You have certain data protection rights in relation to how we process your personal data. You can contact us at any time at privacy@sygrowth.com to exercise your rights as set out below. Once we receive your request we will respond as promptly as possible and, in any event, within one month. Please note that, before taking any action, we may ask you to verify your identity to ensure your request is handled securely.
Right to access
You have the right to request access to and information about how we process your personal data. In addition, you may request a copy of the personal data we process about you. Please note that your request must not adversely affect the rights and freedoms of others, such as their right to privacy and confidentiality. In such cases, we may need to limit the information we disclose.
Right to rectification
You have the right to challenge the accuracy of your personal data at any time. Depending on the purpose of the processing, you may also request that your personal data be completed. Where relevant, we may ask you to provide an additional statement to clarify or complete the information.
Right to erasure
In certain circumstances, you have the right to request the deletion of your personal data (the “right to be forgotten”), for example when the data is no longer necessary for the purpose for which it was collected or we no longer have a legal basis to continue processing it.
Please note that this right is not absolute. There are legal reasons why we may need to retain your personal data, such as to comply with a legal obligation to retain the data, to establish, exercise, or defend legal claims, or when there is another lawful basis for processing your personal data.
Right to object
You have the right to object to the processing of your personal data at any time. This means we must stop processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.
You have an absolute right to object to receiving marketing communications from us at any time.
Right to data portability
When our processing is based on your consent or on a contract with you, you have the right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format and to transmit that data to another controller. Where technically feasible, you may also request that we transmit your personal data directly to another controller.
Right to Withdraw Consent
If we process your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent applies only to future processing and does not affect the lawfulness of processing carried out before consent was withdrawn.
Right to Lodge a Complaint
You have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), which supervises the processing of personal data in Sweden.
Contact details:
Integritetsskyddsmyndigheten
Box 8114, 104 20 Stockholm
Email: imy@imy.se
Phone: 08-657 61 00
Website: www.imy.se
We do not make decisions based solely on automated processing, including profiling, that would produce legal effects concerning you or otherwise significantly affect you.
7. Notice of changes to the NOTIce
We reserve the right to update or amend this Privacy Notice at any time. If we make material changes that affect how your personal data is processed, we will inform you in advance and explain what the changes mean for you. Where required by applicable law, we will also seek your consent.
You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.
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Cookie Notice
This cookie policy describes how Systematic Growth, with the registered name of Systematic Management AB”, org. number 559220-0496, at the registered address Birger Jarlsgatan 20, 114 34 Stockholm, Sweden, (“Systematic Growth”, “we” or “us”) uses cookies on our websites https://www.systematic-growth.com/ (the “Website”). [S1]
This cookie notice applies to all visitors of our Website and describes how we use cookies and similar technologies, by explaining what these technologies are, how they function, why we are using them, as well as your rights in regards to the processing that takes place through these technologies..
1. WHAT IS A COOKIE?
A cookie is a small piece of data sent from a website and stored on your device, mobile phone, or another device while you browse that website. A cookie can help us recognize your device and/or browser the next time you visit our Website, provide you with access to certain functions on the Website, and/or provide reporting functions, among others.
There are other technologies such as web beacons (also known as clear GIFs, web bugs, or pixel tags) that may carry similar functions as cookies. In this cookie notice, we use the term “cookies” for cookies and all such similar technologies.
2. WHICH TYPES OF COOKIES DO WE USE?
We use the following cookies:
Strictly necessary cookies – These cookies are strictly necessary in order to enable you to move around the website and use its features. These cookies are necessary for the Website to function properly. Strictly necessary cookies do not require your consent as they enable services you have specifically asked for and which cannot be provided otherwise.
Functionality cookies – These cookies enable a website to save details that visitors have provided in order to offer a better experience, such as to allow the Website to remember the visitors’choices such as language preferences, username, or the region they are in. It is possible that some parts of our Website will not function properly without these cookies.
Performance cookies – These cookies are used by us to analyse the performance and design of the Website and to detect any potential errors or malfunctions. They also enable us to recognise previous visits to our Website, which parts of the Website visitors visit most frequently, and how much time visitors spend on the Website. The purpose of these cookies is to improve the performance of the Website by understanding how visitors interact with it.
Advertising cookies – These cookies are used to track your visits across websites to display relevant and tailored ads based on the visitor’s interests .
We use cookies that are set directly from us on our Website, as a publisher web server, which are called “first-party cookies” and only work on a single domain. We also use cookies from third parties, which are called “third-party cookies”. This means that these cookies are created by domains that are not the Website (or domain) that you are visiting.
When browsing on our Website, you will encounter embedded content, such as the social media share function, or links to other websites. Please note that this cookie notice does not apply to these embedded content and websites, which are governed by their own cookie notice. [S2]
3. information about our cookies[S3]
3.1 First-party cookies
3.2 Third-party cookies
1. HOW TO MANAGE YOUR COOKIE PREFERENCES
The storage of cookies on your device and the processing that occurs through cookies is based on your consent as a legal ground for the processing whether the processing concerns personal data or not personal data. This means that you have a choice to allow or deny some or all of the cookies, except for strictly necessary cookies.
You can accept, decline or otherwise customise your cookie preferences by clicking the relevant button on the cookie banner that appears on the Website when you visit it. For example, by clicking "I Accept" or on our cookie banner on the Website you consent to the use of cookies.
You can change your cookie preferences at any time. To do so, simply revisit our website and update your choices via the cookie banner.
Another way to manage the cookies is by changing the setting of your browser. In general, most browsers allow you to check what cookies are used and allow you to remove or block the cookies. The process to manage your cookie preferences may vary, depending on your browser. Please note that if you remove the cookies, your saved preferences could be deleted.
2. Your rights
When we process your personal data, you have certain rights according to applicable data protection laws. You have the absolute right to withdraw your consent to the use of cookies at any given time. If you want to read more about your rights, please read our Privacy Notice https://www.systematic-growth.com/privacy-policy
CONTACT US
If you have any questions or comments about our use of cookies, please contact as at Privacy@sygrowth.com.
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