Privacy Notice – Polaris

At Polaris Management A/S (“Polaris”), we are committed to protecting your privacy and handling your personal data with transparency, integrity, and care. This Privacy Notice explains how we collect, use, store, and protect your personal information when you visit our website or interact with us (collectively, the “Services”).

This Privacy Notice outlines:

• What personal data we collect and how,
• The purposes for which we process your data,
• Your rights in relation to your personal information, and
• How you can contact us with questions or concerns.

We may amend this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of the notice and, depending on the specific amendments; we may provide you with additional notice.

We encourage you to review the Privacy Notice whenever you access our Services to stay informed about our information practices and the ways you can protect your privacy in accordance with the General Data Protection Regulation (the “GDPR”) and the Danish Data Protection Act.

1. Data controller and contact information

Polaris Management A/S
CVR-no. 28 50 17 65
Malmøgade 3, 1.
DK-2100 København Ø

2. Collection of personal data

At Polaris we process personal data for several purposes. Below, we describe the nature of
the personal data and how we process it in more detail:

Commercial partners
We primarily collect and process your personal data when you enter into a commercial relationship, hereunder when you are an investor in a Polaris fund. To enter into contracts, deals and other agreements, business partnerships, consultancy agreements, etc. and fulfilling such agreements, including subsequent invoicing etc. we process ordinary personal data such as your name, contact information, position, cost information, CV, home address, bank account or credit card number, date of birth, home address. If you act as representative of a company that has invested in a Polaris fund, we will process your name, title and contact details.

The legal basis for such processing is the performance of the contract according to the GDPR art. 6(1)(b), (c) and (f).

In situations where you have entered into a Subscription Agreement with Polaris (acting as Investment Manager) a separate privacy notice for the purpose of the Subscription Agreement may be issued.

Compliance
In order to comply with legal and other requirements related to KYC, bookkeeping, tax, reporting etc. and to meet requests from government or other public/regulatory authorities, we process ordinary personal data, such as payment/money transfer data (bank account number, payment of invoices, transfer of money), personal details and contact information (e.g. name and surname, gender, date of birth, e-mail and telephone details, home address, personal identification number (CPR-no.) etc.) and KYC-information (eg. driver license number, passport number, information on beneficial owners of the company etc.).

The legal basis for such processing is the GDPR art. 6(1)(c) and (f) and the Danish Data Protection Act section 11(2)(1).

Board members
When you are a board member of Polaris or any fund related to Polaris, Polaris may process your personal data, hereunder name, contact details, professional background and bank details for the performance of the contract according to the GDPR art. 6(1)(b).

As Polaris is comprised by the financial legislation, Polaris will also process personal data in relation to the fulfilment of the fit-and-proper requirement, hereunder criminal record and financial background.

The legal basis for such processing is the GDPR art. 6(1)(c) and the Danish Data Protection Act section 8(2).

Workshop, events and SoMe
We may collect information you provide directly to us when you participate in a Polaris workshop or investor event, if you communicate with Polaris via third party social media sites (e.g. LinkedIn) or if you otherwise interact with us. The types of information we may collect about you include your name, social networking screen names or IDs, email address and any other information you choose to provide.

The legal basis for such processing is the performance of the contract according to GDPR art. 6(1)(b) or the GDPR art. 6(1)(f) by Polaris’ legitimate interest in responding to your inquiry in relation to the Services.

Website visitors
In addition to personal data you may provide directly to us, we also use cookies and similar technologies to enhance your experience on our website. These tools help us understand how visitors interact with our content and improve site functionality and performance.

We use both essential cookies (which enable core functionality such as security and accessibility) and optional cookies (which enable optional functionality).

Where required by law, we seek your consent before setting non-essential cookies. You can read more in our Cookie Policy and manage your cookie preferences at any time via our cookie banner.

The legal basis for such processing is Polaris’ legitimate interest in being able to technically support the website's functions (personal data collected by means of necessary cookies) - article 6(1)(f) of the GDPR and your consent (personal data collected via other cookies) -
Article 6(1)(a) of the GDPR.

Whistleblower scheme
As part of our whistleblower scheme, which allows for reporting of violations of various laws and regulations, we process personal data.

Please refer to our Whistleblower Policy for further information.

3. Use of personal data

We may use information about you for various purposes, including to:

• Provide, maintain and improve our current Services;
• Develop new Services;
• Provide and deliver the Services you request and send you related information;
• Enter into an agreement etc. with you
• Respond to your comments, questions and requests;
• Communicate with you about products, services, offers, promotions and events offered by Polaris and others, and provide news and information we think will be of interest to you.

We may share information about you with the following parties or as otherwise described in this Privacy Notice:

• Relevant authorities, hereunder the Danish Financial Supervisory Authority, SKAT, etc.
• Suppliers, vendors and other third parties that we work with to assist our company (meaning service providers, technical support, supply services, and financial institutions)
• In response to a request for information if we believe disclosure is in accordance with any applicable legal requirement
• Relevant Data Processors
• Legal-, tax or financial advisors.

4. Third country transfers

If your personal data is transferred to data controllers or data processors which are located in countries outside the EU/EEA, including group entities, not ensuring an adequate level of data protection, such transfer will be safeguarded by the EU Commission’s standard contractual clauses (SCCs) together with any supplementary measures assessed as necessary, or other measures safeguarding an adequate level of data protection.

5. Security

We have implemented security measures to ensure that our internal procedures meet our high security policy standards. Accordingly, we strive to protect the quality and integrity of your personal data. This includes encryption of data and use of pseudonymisation, whenever applicable.

6. Your rights

In relation to our processing of your personal data, you have the right to:

• Request access to and rectification or erasure of your personal data.
• Object to the processing of your personal data and have the processing of your personal data restricted.
• Withdraw your consent at any time, if our processing of your personal information is based on your consent. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent. You may withdraw your consent by sending a request to .
• Receive your personal information in a structured, commonly used and machine-readable format (data portability).

There may be conditions or limitations on these rights. It is therefore for example not certain that you will have the right to deletion of data in every case. This will depend on the specific circumstances of the processing activity, which Polaris will assess in each case.

You can take steps to exercise your rights by sending an email to

You may always lodge a complaint with the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, e-mail .