Privacy Notice

Ada Partners LLP [“Ada”] respects the privacy of every individual whose personal information it handles. This Privacy Notice explains how Ada collects, stores and uses that personal information and sets out our approach to the General Data Protection Regulation and UK laws such as the Data Protection Act.

Table of contents

About us

This site is owned and operated by Ada. Ada is the data controller for the purpose of the Data Protection Legislation.

Please note that our website and other digital platforms may contain links to third party websites / digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our own digital platforms. We recommend that you check the privacy and security policies and procedures of each and every other website / digital platform that you visit.

Personal Data

Personal data is defined by the Data Protection Legislation as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Data subjects’ rights

Under the Data Protection Legislation, you have the following rights, which Ada will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more.
  2. The right to access the personal data we hold about you, or to have it rectified if it is inaccurate or incomplete. See ‘Your Rights to See and Correct Data’ below.
  3. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us to find out more.
  4. The right to restrict (i.e. prevent) the processing of your personal data.
  5. The right to object to us using your personal data for a particular purpose or purposes.
  6. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact Matt Penneycard at matt@adaventures.com in the first instance. Please note that these rights are subject to some statutory qualifications.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed.

Depending on the context in which we encounter your personal data, we may collect, store and process some of that data, as set out below. With the exception of information regarding the gender and ethnicity of potential founders (which we deal with below), we do not collect any ‘special category’ or ‘sensitive’ personal data, or personal data relating to children, or data relating to criminal convictions and/or offences.

Business Contacts

As a part of its day-to-day operations Ada meets large numbers of business contacts at meetings and receives emails about investment opportunities. It is likely to receive and store personal information on those it meets.

If you have had contact with Ada, for example through emailing us or meeting a colleague, it is likely that we will want to make a note of that email or meeting and may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details. We will collect and store this personal information for the purposes of: maintaining a record of contacts; providing periodic business updates; drawing to your attention working opportunities which may be of mutual benefit to us as described below; and organizing meetings with you.

The personal information we hold about business contacts may be shared with: professional advisors; companies who hold or ‘process’ personal information on our behalf, including but not limited to Affinity, our CRM provider, or cloud-based products such as Google Drive, OneDrive or Box.

The legal basis for collecting and storing such personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.

Personal information of Suppliers and Professional Advisors

As a part of its day-to-day operations Ada is likely to receive and store personal information to enable it to buy office and other supplies or engage with professional advisors.

If you are a supplier or professional advisor to Ada, we will capture and use limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation and contact details, as well as information relating to the services you have provided. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received, and commissioning further services.

The personal information we hold about suppliers and professional advisors may be shared with: other professional advisors; companies who hold or ‘process’ personal information on our behalf, including but not limited to Affinity, our CRM provider, or cloud based products such as Google Drive, OneDrive or Box; We store and process information in this way because it is necessary to: perform a contract to which you are likely to be a party; comply with a legal or regulatory obligation; and/or protect our legitimate interests in running and promoting our business.

Personal information collected during a transaction

Ada is likely to receive and store personal information as part of its investment evaluation process. If you are involved in a transaction that Ada and/or the funds that it manages or advises enters into, or a potential transaction that Ada considers, we may store personal information relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.

We collect and store this information for the purposes of:

  • evaluating a transaction and your role in it;
  • executing transactions;
  • managing an investment once made;
  • maintaining records of investments;
  • meeting regulatory and legal obligations e.g. KYC checks;
  • safeguarding our legal rights and interests;
  • seeking and receiving advice from our professional advisors, including accountant’s lawyers and other consultants; and/or
  • providing periodic business updates, as described below.

The personal information we hold about the members of management teams may be shared with professional advisors, such as accountants, lawyers or other consultants; financial intermediaries; credit and other reference agencies; other persons who have an interest or involvement in, or who are considering an interest or involvement in, an Ada transaction, including co-investors, other providers of finance and investors in Ada’s funds; companies who hold or ‘process’ personal information on our behalf, including but not limited to Affinity, our CRM provider or cloud based products such as Google Drive, OneDrive or Box.

We store and process information in this way because it is necessary to:

  • perform a contract to which you or we are likely to be a party;
  • comply with a legal or regulatory obligation; and/or
  • protect our legitimate interests in running and promoting our business.

Personal information collected on Ada Scouts or potential Ada Scouts

Ada is likely to receive and store personal information as part of its recruitment and evaluation for Ada’s scout network (collectively, the “Ada Scouts”). If you apply to be an Ada Scout or become an Ada Scout, we may store personal information relating to you. This might include your work experience, your contact details (including your location, email address, associated organisation and social media handles and phone number) and results of other due diligence carried out.

We collect and store this information for the purposes of:

  • evaluating your suitability to be an Ada Scout;
  • managing the Ada Scout community;
  • evaluating the Ada Scout network as a whole;
  • maintaining records of the Ada Scout network;
  • safeguarding our legal rights and interests;
  • seeking and receiving advice from our professional advisors, including accountant’s lawyers and other consultants; and/or
  • providing periodic business updates, as described below.

The personal information we hold about the Ada Scouts may be shared with professional advisors, such as accountants, lawyers or other consultants; financial intermediaries; credit and other reference agencies; companies who hold or ‘process’ personal information on our behalf, including but not limited to Affinity, our CRM provider, or cloud based products such as Google Drive, OneDrive or Box. Data relating to the Ada Scout network may be reported to the investors or potential investors in Ada funds from time to time on an aggregated and anonymised basis.

We store and process information in this way because it is necessary to:

  • perform a contract to which you or we are likely to be a party;
  • comply with a legal or regulatory obligation; and/or
  • protect our legitimate interests in running and promoting our business.

Personal data collected during visits to our website

When you interact with our digital platforms, we may also automatically collect the following information about your visit. This is primarily to help us better understand how people use our digital platforms to enable us to create better content and more relevant communications:

  • how you have reached our digital platform and the internet protocol (IP) address you have used;
  • your browser type, versions and plug-ins, and your operating system;
  • your journey through our digital platform, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information;
  • what content you like or share; and/or
  • information collected in any forms you complete.

We collect this information using analytics software provided by Google Analytics, Microsoft Clarity or other similar third-party analytics software providers. For more information relating to our use of third-party cookies, see the ‘Cookies’ section below. We collect, store and process this information to protect our legitimate interest in administering our website and our business, and in ensuring that relevant content is provided to you.

Mandatory provision of information

In some cases we will not be able to deal with you further without receiving certain information – e.g. ‘Know Your Customer’ information. In such circumstances we will explain this to you including the possible consequences of not providing particular information. In any event Ada will only process the personal information you provide to Ada for the purposes listed above, and to protect its legitimate interests in administering its business and complying with the laws and regulations that apply to its business.

Sensitive or special category personal data

Ada avoids wherever possible receiving information on ethnicity, religion, political views and your mental or physical health. However, we collect and process data regarding the gender and ethnicity of potential founders and their teams for the purpose of our legitimate business interests in:

  • monitoring our performance against our stated mission to identify and invest in founders from a diverse range of backgrounds and ethnicities;
  • reporting the data, on an anonymised basis, to the investors and potential investors in our fund and to the UK government as part of our commitment to the Investing in Women Code. The data reported as part of the Investing in Women Code will be aggregated and used by the UK Department for Business in the Investing in Women Code Annual Progress Report. This data will be used to inform, promote and support the advancement of female entrepreneurship in the UK. Please see the 2021 IWC Annual Progress Report here for information; and/or
  • assessing our progress and compliance with the Diversity VC Standard Level 2 certificate.

We will request the above information when you submit a pitch to us or otherwise interact with us in respect of a transaction or potential transaction, but providing this information to us is entirely optional. If you do choose to provide this information, you will be consenting to our collection, storage and processing of this sensitive personal data for the purposes stated above, and this will be made clear at the time of collection. The information we hold about the members of management teams may be shared with professional advisors, such as accountants, lawyers or other consultants; financial intermediaries; credit and other reference agencies; other persons who have an interest or involvement in, or who are considering an interest or involvement in, an Ada transaction, including co-investors, other providers of finance and investors in Ada’s funds; companies who hold or ‘process’ personal information on our behalf, including but not limited to Affinity, our CRM provider, or cloud based products such as Google Drive, OneDrive or Box.

Storage and transfer of personal data

Ada may transfer your personal data outside the UK for storage and processing. For example, your personal data may be stored and processed by Affinity, our CRM provider. Affinity’s Privacy Policy is available here. By providing any information, including personal data to us, you consent to the transfer of your data outside the UK for storage and processing.

“Third countries” outside the EEA may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, for example by using contracts with external third parties that require the same levels of personal data protection that would apply under the Data Protection Legislation.

Sharing personal data

Ada will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

Ada may have to share your personal data with service providers who provide IT and system administration services, companies who hold or ‘process’ information on our behalf and on occasion with our professional advisers such as lawyers, auditors and insurers.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above.

Keeping You Informed

We wish to build a long-term relationship with you and (with your permission or where permitted by law) we would like to use personal information that we hold to send you updates about our business, activities and opportunities to work together. We would usually do this by email and/or post. You will not be sent any unlawful marketing or spam. You can opt out of receiving updates at any time by contacting us using the information below, or by clicking the “Unsubscribe” link in any email that you receive.

Retention of personal information

The period for which Ada will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. As a general principle, we store and process personal data for no longer than is necessary in light of the reason(s) for which it was first collected (including for the purposes of satisfying any legal, accounting or reporting requirements).

When deciding what the correct time is to keep the data, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means, and the legal requirements.

In some circumstances, we may anonymise your personal data for research of statistical purposes in which case we may use this information indefinitely without further notice to you.

Security

We will take all reasonable steps to protect the confidentiality and security of your personal information, but cannot guarantee the security of any that you disclose online for example when it is sent by email. You accept the inherent security risks of providing information online over the Internet and will not hold Ada responsible for any breach of security unless this is due to Ada’s negligence or wilful default.

When you submit your data to us, we may use industry standard Secure Sockets Layer (SSL) encryption technology to guard your information. In addition, we have security procedures in place to protect our paper-based systems and computerised databases from loss and misuse, and only allow access to them when it is absolutely necessary to do so, and then under strict guidelines as to what use may be made of the personal information contained within them.

Ada also has in place procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the relevant authorities where we are legally required to do so.Where a password is required to access certain areas of our digital platforms, you are responsible for keeping your password secure and confidential. Please do not share or disclose your password to any other person.

Use of Cookies

Cookies are small text files placed on your computer or device by Ada’s website when you visit certain parts or use certain features of that website (“Cookies”). Ada’s use of Cookies is governed by the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003, unless and until the said Regulations are no longer directly applicable in the UK, and subsequently any legislation which succeeds them (the “Cookie Law”).

Ada’s website may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Ada’s website and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Ada’s website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Ada’s website for the purposes of Ada’s analytics system. These Cookies are not integral to the functioning of Ada’s website and your use and experience of the website will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up asking you to give your consent to set those Cookies. By consenting to the placing of Cookies you are enabling us to provide the best possible experience and service to you.

Ada’s website uses Google Analytics and Microsoft Clarity analytics services, provided by Google and Microsoft respectively. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Ada to better understand how our website is used. This, in turn, enables us to improve the website and the services offered through it. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

The above services used by Ada’s website use third party Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of the website, it does enable us to continually improve it, making it a better and more useful experience for you.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Ada’s website more quickly and efficiently.

Accessing your personal data

If you want to know what personal data Ada holds about you, you can ask for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in in the ‘Questions and Further Information’ section below. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

Ada will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Questions and Further Information

If you have any questions about this Privacy Notice or about your personal data please email us at matt@adaventures.com

Changes to Ada’s Privacy Notice

We aim to meet high standards and so our policies and procedures are constantly under review. From time to time we may change this privacy notice, for example if the law changes or if we change our business in a way that affects data protection. Accordingly we recommend that you check this page periodically in order to review the latest version. This version of our Privacy Notice was last updated on 1 November 2021.

Where to Make a Complaint

If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the above address. If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office at the following address: Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/email/