Privacy Notice

Ada Partners LLP (“Ada Ventures”) respects the privacy of every individual whose personal information it handles. This Privacy Notice explains how Ada Ventures collects, stores and uses that personal information and sets out our approach to the UK General Data Protection Regulations, the Data Protection Act, the Privacy and Electronic Communications Regulations 2003 and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (the “Data Protection Legislation”).

Table of contents

About us

Ada Ventures is the data controller of your data for the purpose of the Data Protection Legislation. Being a Controller means that we are trusted to look after and deal with your personal information in accordance with this notice. We determine the ways and means of processing your data and must therefore be accountable for it.

We are registered at UK Companies House under number: OC423404 and registered with the ICO as a fee payer under number ZB313388

Our address is 16 Great Queen St, London, WC2B 5AH.

If you have any queries about the way we handle your data or wish to exercise your rights, you can contact us on matt@adaventures.com

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

As a data subject, you have a number of rights over your personal data under the Data Protection Laws.

  • Right of access: You can request access to a copy of the personal data which we hold about you as well as details about why and how we use;
  • Right to rectification: You can ask us to change or complete any personal data we hold about you which is inaccurate or incomplete;
  • Right to be forgotten/erasure: You have a right, under certain circumstances to ask us to delete any personal data we hold about you. Please note that there may be situations where we must retain your personal data after a request for erasure where we have a lawful basis for doing so.
  • Right of restriction: You can ask us to restrict (i.e.: prevent) the processing of your personal data where you have objected to our use of it and we have no lawful basis to continue processing your personal data.
  • Right to data portability: In certain circumstances, you can ask us to transfer the data we hold about you to another. This would be sent in a structured, commonly used, electronic form.
  • Right to object: You can object to us using your personal data for particular purposes.
  • Automated decision making: You have a right not to be subjected to automated decision making and profiling in certain circumstances. Note: Ada Ventures do not make any automated decisions on you.

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

You also have the right to lodge a complaint about our processing with a supervisory authority – in the UK that is the ICO whose details are here: https://ico.org.uk/global/contact-us/postal-addresses/

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.

1. Business Contacts

As a part of its day-to-day operations Ada Ventures 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 Ventures, 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 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.

We retain this data for as long as we have a relationship with you.

2. Personal information of Suppliers and Professional Advisors

As a part of its day-to-day operations Ada Ventures 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 Ventures, 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.

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.

We will retain this data for the length of our relationship plus 7 years

3. Personal information collected during an investment transaction

Ada Ventures is likely to receive and store personal information as part of its investment evaluation process. If you are involved in a transaction that Ada Ventures and/or the funds that it manages or advises enters into, or a potential transaction that Ada Ventures considers, we 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 also process sensitive and special category data about our founders, Ada Scouts and Ada Angels. This is entirely optional, and more details can be seen in section 6.

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;
  • providing periodic business updates, as described below; and/or
  • purposes of equal opportunity or monitoring.

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.

Please also see section 7 below for the special category data we process if you have chosen to supply it.

We retain this data for the length of our relationship plus 7 years

4. Personal information collected on Ada Scouts or Ada Angels or potential Ada Scouts or Ada Angels

Ada Ventures is likely to receive and store personal information as part of its recruitment and evaluation for Ada Ventures’ scout network and Ada’s Angel program (collectively, the “Ada Scouts and Angels”). If you apply to be an Ada Scout or Ada’s Angel or become an Ada Scout and/or Ada’s Angel, we process personal information relating to you. This includes 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 also process sensitive and special category data about our Ada Scouts and Ada’s Angels. Providing this data is entirely optional, and more details can be seen in section 7.

We collect and store this information for the purposes of:

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

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.

Please also see section 7 below for the special category data we process if you have chosen to supply it

The data we process about our Ada Scouts and Angels is held for the length of our relationship plus 7 years.

5. Personal data collected during visits to our website

When you interact with our digital platforms, we 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.

For more information relating to our use of third-party cookies, see the ‘Cookies’ section below. We use consent when we place cookies on your device and we 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.

6. 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 Ventures will only process the personal information you provide to Ada Ventures 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.

7. Sensitive and special category personal data

Ada Ventures 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 Ada Scouts, Ada Angels, 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;
  • monitoring our performance against our stated mission to build a community of Ada Scouts and Ada Angels from a diverse range of backgrounds and ethnicities, in service of the above mission to identify and invest in founders from a diverse range of backgrounds and ethnicities;
  • reporting the data, on an aggregated 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 2022 IWC Annual Progress Report here for information;
  • assessing our progress and compliance with the Diversity VC Standard Level 2 certificate; and/or
  • monitoring the efficacy of our Ada Scout and Ada Angel network in referring more high quality, diverse dealflow to us (see below). If you provide any sensitive or special category data to us in the course of applying to be an Ada Scout or Ada Angel, it will be used to monitor the efficacy of the programs as a whole, and will also help us to form a fuller picture of each member in the Ada Scout and Ada Angels group.

We will request most of the above information when you submit a pitch to us or otherwise interact with us in respect of a transaction or potential transaction, when you are applying to be an Ada Scout and/or Ada Angel or in our normal course of business when pursuing the objectives above. Providing this information to us is entirely optional. The derogation under which we process ethnicity for the purposes of the UK GDPR and Data Protection Act 2018 is for the purposes of equality of opportunity or treatment, with limited special category data being processed for the purposes of research and public interest, as set out above.

University College London (UCL) research

We entered into a partnership with UCL in 2022 to analyse the diversity of our scout network and the founders they have referred to us. The purpose of the research was to monitor our progress against our mission stated earlier in this section. This research was finalised in August 2022.

For this project, any information passed on to UCL on Ada Scouts or founders was pseudonymised (no actual names were passed on). This included: (1) personal data collected from Ada Scouts (including location, gender and ethnicity, including perceived location, perceived gender and perceived ethnicity, as insufficient data was collected by the deadline we had specified of 6 June 2022); and (2) information on founders and companies referred to us by Ada Scouts, including the location, perceived gender and perceived ethnicity of these founders. See below for the process for how we perceived gender & ethnicity.

As the key purpose of the project is to analyse the success of the Ada Scouts in increasing the diversity of our pipeline, and whether ‘better’ Scouts could in fact diversify venture capital, this information is integral to the project and helping us to measure our progress against our stated aims. Please note that nothing in this project will influence any investment decision-making, and will only be used to help to improve and iterate on the Ada Scout program (including through the UCL research project). If you have any questions, please contact scouts@adaventures.com. Please note that you will have the same data subject rights as are listed at the top of the privacy notice.

Process for perceiving ethnicity and gender

  1. Manually by looking at a picture of the person on LinkedIn, company websites or pitch decks. If gender could be perceived through the use of pronouns on LinkedIn, we used this instead of pictures.
  2. In perceiving gender & ethnicity, we used basic binary groupings:
    • Gender: Male/Female/Unknown (if there is no picture)
    • Ethnicity: Black/White/Asian/Mixed/Other/Unknown (if there is no picture)
  3. We assigned 2 people from Ada Ventures to look at all pictures and independently perceive gender/ethnicity. They completed 2 separate spreadsheets and did not have any access to the other’s spreadsheet until after they have both finished their perception exercise.
  4. If any discrepancy, we asked a third person to perceive ethnicity or gender of that specific founder. They did this on a third spreadsheet, without having looked at the spreadsheet for the first 2 people.

We then used the majority perceived data in the study, or marked the founder as ‘unknown’ if all 3 people have said something different.

8. Transfers of personal data

“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 if we transfer your data outside the UK and EEA, 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.

9. Sharing personal data

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

Ada Ventures 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, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority, or to comply with our obligations under FCA regulations.

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.

10. 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. Our lawful basis for this is legitimate interest.

11. Technical and Operational 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.

When you submit your data to us, we use industry standard Secure Sockets Layer (SSL) encryption technology to guard your information.

All data is password protected, access controlled, backed up securely and encrypted when appropriate.

All employees are trained in data protection and are aware of their obligations to ensure the privacy of all data subjects.

Ada Ventures 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.

12. Use of Cookies

Cookies are small text files placed on your computer or device by Ada Ventures’ website when you visit certain parts or use certain features of that website (“Cookies”). Ada Ventures’ 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 Ventures’ 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 Ventures’ 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 Ventures’ 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 Ventures’ website for the purposes of Ada’s analytics system. These Cookies are not integral to the functioning of Ada Ventures’ 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.

13. Changes to Ada Ventures’ 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 in October 2022.