Who are we?
- We are Emerge Venture Partners LLP (“we”, “us”, “our”, “Emerge Venture Partners LLP.”, “Emerge Education”, “Emerge”) and operate under the name of Emerge.
- We are committed to protecting and respecting the privacy of our users. If you have any questions about how we process personal information please email us at [email protected], or write to us at 15 Fetter Lane, London, EC4A 1BW.
- We are committed to following best practices in ESG and adhering to UK and EU legislation. If you have any questions about how we integrate ESG into our business please email us at [email protected], or write to us at 15 Fetter Lane, London, EC4A 1BW
PRIVACY POLICY
- Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you.
This policy is intended to help you understand:- Who we are, our official role and our legal basis for processing;
- What data we collect and how we use it;
- How we collect the data;
- How we share the data we collect;
- How we secure your data;
- How you can access and control your data;
- What happens if we change our policy.
- This Privacy Policy covers the information we collect about you when you use our website, apply to join our programmes, or otherwise interact with Emerge. It also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Service or interact with any other aspect of our business.
The Service
- Emerge is a hands-on early-stage investment, growth services, and consulting firm focused exclusively on the education technology and HR technology sectors.
Roles
- When you share data directly with us, we act as the Data Controller for that data. There may also be cases where we act as a Data Processor on behalf of third parties, such as partners in our acceleration programmes.
- The name and address of your company;
- Your name and email address.
Legal Basis for Processing Your Data
- We have the following legal bases for processing your data based on the General Data Protection Regulation (GDPR) and any other relevant data protection laws applicable to our jurisdiction;
- Legitimate interest: when we collect data that you provide to us through our website, we are fulfilling your legitimate interest of finding out more about our services or receiving information through our newsletter. When we process your data to provide our service, we are fulfilling your legitimate interest in providing you or your company with the services necessary for investment, growth, or innovation.
- Contractual: if we are in a contractual agreement with your company to deliver a service to you, we may need to process the data listed above in order to deliver that service. Where appropriate, we may also serve as a data processor in order to deliver services according to contractual agreements with third parties.
- Legal obligation: where necessary, we will collect and store personal data to fulfil our legal obligations as an investment firm.
- Consent: before you give us your data or use our service, we seek explicit agreement to this privacy policy from you or your employer.
What data Do We Collect and How Do We Use It?
Information you provide to us through our website
- Your full name;
- Your email address;
- Your phone number;
- The country you live in;
- Information about your company as part of the application process.
How we use this information
- Make decisions about your company’s participation in our programme/investment process.
We use this data to
- Deliver our service to you as requested
- Improve our service based on your feedback in completed surveys.
- Communicate about updates and changes to our services.
If your company joins one of our programs or gets investment from us, we may store:
- The name and address of your company;
- Your name and email address.
- Your KYC details and detailed company information
We use this information to
- Deliver our services to you;
- Communicate about updates and changes to our services;
- Charge you for our service.
If you are an investor in Emerge’s portfolio companies, we are legally obligated to collect and store certain types of personal data through a standard KYC (‘Know your customer’) form, including a copy of your identification data.
Information we collect automatically when you use our service
We collect the following data
- Your behaviours when you visit our website. For example, we track where you click and how long you spend on our site. This data is not linked to any other piece of data and cannot be used to identify you as an individual.
How do we collect the data?
- As a participant in our programmes, you give us data about yourself and your company directly through our desktop and mobile site or by email. As a visitor to our website, you enter your data directly to our website.
Sharing with third parties
- We share information with third parties that help us operate, provide, improve, integrate, customise, support and market our service
- Organisations which support the operation of our service are as follows;
- Mailchimp, Google Suite, Slack, Trello, Dropbox, Typeform, Airtable, Hotjar, Eventbrite, Notion, physical filing systems, and printed attendee lists. Please visit the websites of these services to understand more about their privacy policies
- In addition, we may use third-party services such as Google Analytics, which may also place cookies on your device. Please read their privacy policy to ensure that you’re comfortable with how they use cookies: https://policies.google.com/privacy?hl=en
- If you have any questions about how we use these organisations as subprocessors of your data, please contact us by emailing [email protected] or writing to us at 15 Fetter Lane, London, EC4A 1BW
- We will not share your data with any other third parties unless you give us explicit permission to do so, or unless we are required to by law or court order
Cookies
- Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
- Like many sites, we use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
How do we secure your data?
Information storage and security
- We use data hosting service providers in the United Kingdom to host the data we collect, and we use technical measures to secure your data
- We carry out assurance on the organisations we use as data sub-processors that are hosted in the United States. These organisations hold either the EU-US Privacy Shield or model contract clauses that state that EU companies can use them with assurance that they store data in a secure way
- We have rigorous patching policies that ensure our machines, systems and servers are always secured by up-to-date protection. All of our staff receive regular training in data protection best practice
How long do we keep information?
- We are required under UK tax law to keep your basic personal data, if provided, (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information
If something goes wrong
- In the case of a breach of our own systems or the systems of one of our sub-processors that could compromise your data, we will notify you straight away. We will work to secure your data as quickly as we can
How do you access and control your data?
Your Choices
- You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), request the rectification deletion or restriction or erasure of your information, or to request your information in a structured, electronic format. In order to do any of these things, please email [email protected] or write to us at 15 Fetter Lane, London, EC4A 1BW
Accessing, amending or deleting data
- You can also contact us directly through the details above to amend or correct your data. The process of deletion is gradual: initially deleted data is moved to a ‘deleted’ area in case it was deleted in error. After a delay, it is then permanently deleted from our main systems
- You can request to know what data we hold on you by contacting us through the details above. We will respond in line with the timelines set by the General Data Protection Regulation. You can request that we delete all data that we hold on you.
Changes to this policy
- Any material changes we make to our privacy notice in the future will be communicated to you through your provided contact information. An up-to-date privacy policy will always be available on our website. We will update this privacy policy every year as standard and at other times if it is deemed necessary to do so. This policy was last updated in January 2024.
ESG Policy
- We look to the FCA and SFDR principles to govern our decisions on transparency requirements as regards the integration of sustainability risks into our investment decisions, the result of the assessment of the impacts of sustainability risks on the returns of the Partnership and the consideration of adverse effects, and the disclosure of environmental, social, and governance (“ESG”), as well as sustainability-related information. The Partnership discloses below its sustainable and ESG risk management processes in readiness to comply with UK and European Regulations on sustainability-related disclosures in the financial services sector.
Introduction to sustainability risks
- Sustainability risks are ESG events or conditions that, if they occur, could cause an actual or a potential material adverse impact on the value of the Partnership’s investments. Sustainability risks can either represent a risk of their own or affect or contribute to other risks such as market, operational, liquidity, and counterparty risks. Accordingly, integrating sustainability risks in the Partnership’s investment operations is critical in ensuring the generation of sustainable long-term risk-adjusted returns for investors.
- The Partnership is an early-stage venture capital fund that focuses on driving the success of technology-enabled education businesses, which all help to democratise access to opportunity. In addition, the Partnership focuses and proactively works on creating value and supporting founders, thereby highlighting the importance of sustainable activities at the Partnership and Portfolio Companies levels.
- Preventing the risk of negative impact is the basis for the Partnership’s education technology investments; hence, the Management Company has designed processes to assess the education impact/outcome of their potential investments. Thoughtful management and consideration of ESG risks and opportunities will drive long-term value creation for the Partnership’s Portfolio Companies. In addition to ensuring that the Partnership’s investments are consistent with its edtech investment thesis, the Partnership will strive, where practicable, to generate value beyond financial returns by continuously enhancing its ESG risk management processes and incorporating these within its investment decisions.
- Sustainability-related risks are at the core of the Partnership’s Investment Policy and practices. Accordingly, the Partnership considers these risks by selecting or excluding certain investments based on that investment’s objective, such as its reach potential and inclusivity.
- The Partnership has committed to:
- Incorporate ESG issues into investment analysis and decision-making processes.
- Incorporate ESG issues into internal policies.
- Ensure transparency on ESG issues at the level of Portfolio Companies.
Impact and ESG Management Process
- The Management Company’s processes incorporate sustainability across the lifecycle of the Partnership’s investments. The Partnership has an Edtech Impact Framework that includes a Democratistinv Access to Opportunity Impact Thesis and an Impact Measurement Methodology which discloses the ESG maturity level for each company and their reach, inclusivity and diversity.
Integration of Sustainability Risks into the Investment Decisions of the Partnership
- The Partnership thoroughly assesses the alignment of potential new investment with its investment thesis. During the due diligence process, the Partnership conducts an ESG risk assessment via a checklist and further analyzes the expected education impact of the Portfolio Company. These analyses are part of the investment decision. Please note that as the Partnership invests in early-stage companies, it is common for these companies to lack an ESG framework at the time of investment. As a result, the Partnership assesses the company’s ESG baseline at the time of investment and analyzes the risks of negative impact. The investment memorandum summarises the findings of these assessments. The Investment Committee’s investment decision incorporates the review of ESG factors. If significant ESG risks are identified, the Partnership does not proceed with the investment if the Portfolio Company cannot mitigate ESG-related risks to a satisfactory extent.
Pre-Investment (Due Diligence Phase)
Investment (Onboarding Phase)
- Once the Investment Committee approves the investment decision, the Partnership identifies and defines, during the onboarding phase, the selected impact targets to be monitored and reported on throughout the holding period. In addition, the Portfolio Company also has to consider, monitor, and report on ESG risks.
Post-Investment (Monitoring Phase)
- During the holding period, the Management Company monitors the impact data reported by the Portfolio Company at the agreed-upon frequency. The Management Company may carry out additional in-depth education impact analyses on data availability and resources. If the Management Company identifies specific ESG risks, the Management Company evaluates the progress reported by the Portfolio Company in monitoring and mitigating those risks. As an investor, the Management Company strives to oversee and contribute as much as possible to the Portfolio Companies’ education/ access to opportunity impact performance alongside financial matters. Throughout its portfolio of investments, the Partnership collects, analyzes, and consolidates the impact metrics of Portfolio Companies. The Partnership informs investors of any development that can affect the impact of portfolio investments.
Divestment (Exit Phase)
- The Partnership seeks to divest to trustworthy and like-minded investors with an aligned interest in improving access to opportunity. The Partnershio encourages founders to choose Investors that will allow and enable the Portfolio Company to pursue its mission and vision while providing support to the founders. The Partnership aims for organised, simple, fair, and transparent divestment processes. The Management Company will quantify the impact creation from the investment date to exit as part of its annual impact measurement process.
Our Approach to Principal Adverse Impact Disclosures
- Currently, we do not make a Principal Adverse Impact (the “PAI”) assessment regarding sustainability factors when making investment decisions, as defined in the Sustainable Finance Disclosure Regulation (the “SFDR”).
- This decision by the Management Company is primarily based on the unique characteristics of investment strategy that is focused on the early stage where little data is often available. Therefore, Emrege is currently not assessing PAI of investment decisions on sustainability factors.
Commitment to Annual Review
- There is a commitment to review our ability to provide PAI disclosures. The Company will reassess the decision not to consider principal adverse impacts at least once a year.
- Emerge will keep our partners and investors informed of any developments or changes regarding our ability to provide PAI disclosures. In case of changes in the Company’s position, we will revise this statement accordingly and provide the Fund’s investors with the statement on due diligence policies on PAI of investment decisions as required under Article 4(1)(a) of the SFDR.
Sustainability Risk Linked To Remuneration
- At the Management Company level, the whole investment team coordinates ESG activities. Each investment team member is responsible for ensuring that ESG criteria are integrated into an investment decision and implemented by the Portfolio Companies. The Partners validate the final assessment during the Investment Committee, where the Compliance officer and ESG officer supervise the decision.
- The Management Company’s compensation policies are designed to incentivize the investment team to maximise sustainable growth within the Portfolio Companies, which they supervise and represent from the company’s perspective. Emerge’s compensation includes a carry component for all staff to incentivise the whole team to maximise the impact potential of the portfolio.
Changes to this policy
- Any material changes we make to our privacy notice in the future will be communicated to you through your provided contact information. An up-to-date privacy policy will always be available on our website. We will update this privacy policy every year as standard and at other times if it is deemed necessary to do so. This policy was last updated in January 2024.
