With this Privacy Notice, 55 North Ventures Management ApS (hereinafter “55 North Ventures”, “we”, or “us”) provides information on how we process personal data as a manager of alternative investment funds.
This Privacy Notice is provided according to the articles 13 and 14 under the EU Regulation (EU) 2016/679 on General Data Protection Regulation (“GDPR”) and the Danish Data Protection Act (Act 2024/289). Where the Privacy Notice uses terms defined in the GDPR, those terms shall have the same meaning as defined in the GDPR.
The information is provided to our website visitors and stakeholders such as business partners and suppliers, potential investors and individuals who contact us or otherwise interact with us via our social media platforms (hereinafter referred to as the “data subjects” or “you”).
If you are an investor in one of our investment funds, or a stakeholder in such investor, we have provided a specific Privacy Notice for Investors, which is available on our Investor Database Platform, or you may contact us for a copy. This Privacy Notice does not cover our processing of investor personal data.
The Privacy Notice provides information as set forth below:
CONTENT
1. WHO IS THE DATA CONTROLLER AND HOW DO YOU CONTACT US
2. OUR PROCESSING OF YOUR PERSONAL DATA
3. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES.
4. TRANSFERS TO THIRD COUNTRIES
5. FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA.
6. SECURITY MEASURES FOR PROTECTING YOUR PERSONAL DATA
7. YOUR RIGHTS
8. QUESTIONS OR COMPLAINTS
1. WHO IS THE DATA CONTROLLER AND HOW DO YOU CONTACT US
55 North Ventures Management ApS is a data controller when we collect, process and/or store your personal data. If you have questions or want to assert your privacy rights, you may contact us at our address below, or by e-mail or phone.
55 North Ventures Management ApS
BioInovation Institute,
Ole Maaløes Vej 3,
2200 København,
Denmark
CBR-no.: 45 50 52 35
Contact us at:
2. OUR PROCESSING OF YOUR PERSONAL DATA
Business Partners and Suppliers
We process personal data about you if you are a business partner or supplier to us, or if you are a contact person or representative thereof. We collect the information either directly from you or from your employer.
a) The categories of personal data we collect: We collect and process general personal data as your contact details, such as your name, email address, telephone number, your job title and information about your place of employment.
b) The purpose of our processing: We process your personal data to negotiate a contract and/or for performance of a contract with you and/or your employer, and to provide you with information on our activities.
c) Our legal basis: We process your personal data for entering into or the performance of a contract, cf. Article 6(1)(b) of the GDPR. We may also process your personal data in our legitimate interests on the basis of Article 6(1)(f) of the GDPR, always balancing our interests against your interests or fundamental rights and freedoms.
Website Visitors and Contact
We process personal data about you when you contact us via our website, email, or telephone.
a) The categories of personal data we collect: We collect and process general personal data as you provide to us, such as your name, contact details, and the subject matter of your inquiry. We also collect and process cookies when you use our website. Please refer to our cookie banner and cookie policy using the fingerprint icon in the bottom left of the website. We will collect technical cookies for the operation and functionalities of our website. For other cookies, we request your consent.
b) The purpose of our processing: We process your personal data to contact you and to respond to your inquiry and we collect cookies to support your user experience when visiting our website.
c) Our legal basis: we process your personal data with your consent, cf. Article 6(1)(a) of the GDPR, or, if a consent has not been requested or a consent is required, we may base our processing activities on our legitimate interest, cf. Article 6(1)(f) of the GDPR, always balancing our interests against your interests or fundamental rights and freedoms, and the basis for your contact to us.
Social Media
We use social media platforms such as LinkedIn to connect with potential investors and business partners.
We process personal data about you if you have interacted with us and/or contacted us on social media platforms. We may also have integrated a LinkedIn plug-in on our website, which allows you to be directed to our LinkedIn page.
a) The categories of personal data we collect: We process general personal data which you provide to us, directly or on your social media profile, such as your name, your contact details, and the subject matter of your inquiry.
b) The purpose of our processing: We process your personal data to register your interaction with us, and to contact you if you have made an inquiry to us.
c) Our legal basis: We process your personal data based on our legitimate interest on the basis of Article 6(1)(f) of the GDPR, always balancing our interests against your interests or fundamental rights and freedoms, and the basis for your contact to us.
3. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
We will collect and process personal data through our service providers, such as our system providers, administration service providers, or other service providers who process personal data on our behalf and in accordance with our specific instructions, pursuant to a data processing agreement and the legal basis for our data processing. With such processing, the personal data will be disclosed to the third-party providers.
Otherwise, we do not disclose your personal data to third parties unless such disclosure is necessary for the performance of our obligations towards you in accordance with Article 6(1)(b) of the GDPR, for compliance with our legal obligations under applicable law in accordance with Article 6(1)(c) of the GDPR, or if we have obtained your consent to such disclosure in accordance with Article 6(1)(a) of the GDPR.
In certain cases, we may also disclose your personal data to our legal advisors for the purpose of establishing, exercising, or defending legal claims. In such cases, the disclosure is based on our legitimate interests in accordance with Article 6(1)(f) of the GDPR.
When your personal data is disclosed to a third party located within the EU/EEA, your personal data will be protected under the GDPR and the applicable national regulation.
4. TRANSFERS TO THIRD COUNTRIES
In certain cases, we may transfer personal data to service providers located in third countries. Even though the location of our data processing activities and hosting is placed in the EU, our IT systems providers are or have group companies located in the United States or other third countries and, therefore, we have established appropriate safeguards to protect your data subject rights. The providers must either have signed up and self-certified under the voluntary EU-US Data Privacy Framework and are, thereby, operating under the adequacy decision issued by the European Commission, or the providers musth have committed to the European Commission’s Standard Contractual Clauses and adopted necessary additional measures.
5. FOR HOW LONG DO WE RETAIN YOUR PERSONAL DATA
We retain your personal data only for as long as necessary for the specific purpose for which the personal data was collected. Under our retention policies and schedules for deletion of data, we make an assessment to determine when we no longer need to retain your personal data, at which point the data will be deleted.
For business partners and suppliers, we will retain your personal data for the duration of the contractual relationship, or as long as you are a business contact. Thereafter, we will retain your personal data for as long as necessary to serve a legitimate purpose as stated in section 2.
For persons contacting us, we will for a reasonable period keep your contact data, the inquiry and our response, depending on the qualification of your inquiry.
We will continue to store and process your personal data to comply with applicable laws including the Danish bookkeeping and accounting regulations which requires a storage period of 5 years as of the end of a fiscal year.
In certain cases, we may retain your personal data for a longer period in order to protect our legitimate interests, including to establish or defend legal claims. In such cases, we will have conducted a balancing test between our legitimate interest in establishing, exercising, or defending a legal claim and your interest in having your personal data deleted or your fundamental rights and freedoms, in accordance with Article 6(1)(f) of the GDPR.
6. SECURITY MEASURES FOR PROTECTING YOUR PERSONAL DATA
In processing your personal data, 55 North Ventures will apply the data protection principles of lawful and transparent processing of personal data; we apply procedures for data minimization and storage limitation, and we maintain the integrity and accountability required for the fairness of the processing.
When we store your personal data in our systems, we have provided appropriate technical and organizational measures to protect the data against unauthorized access, loss, or destruction. Only individuals who have a legitimate purpose for processing the personal data will have access to it.
7. YOUR RIGHTS
According to the GDPR, you have certain rights you may exercise in respect to the processing of your personal data. These rights include:
Right of access
You have the right to be informed about the personal data that we process about you, and to receive a copy of your personal data stored with us.
Right to rectification
lf you inform us that we hold incorrect or inaccurate personal information about you, we will correct this as soon as we have been made aware of it.
Right to erasure
You may on certain grounds request to have your personal data deleted when processed by us, prior to deletion under our general storage policy.
Right to restrictions for processing
You may on certain grounds require restrictions in our processing of your personal data, and except for storage, we will then restrict our processing as provided with your consent or as necessary for our purpose of the establishment, exercise, or defence of legal claims, or for protection of the rights of another natural or legal person, or for reasons of public interest.
Right to object
You can object to our processing of your personal data that we base on our legitimate interests, and we shall cease the processing unless we demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or we process your personal data to establish, exercise, or defence a legal claim. You always have the right to object to our processing of your personal data to direct marketing.
Right to data portability
You can obtain a digital copy of your personal data which we process in our IT-systems. You may also, when technically feasible, receive your personal data stored with us, in a structured, commonly used and machine-readable format and have the data transferred to another data controller.
Right to withdraw your consent
When your consent is the legal basis for our processing of your personal data, you have the right to withdraw your consent at any time. If you choose to withdraw your consent, it does not affect the lawfulness of our processing based on your previously given consent and up to the time of withdrawal.
In connection with the data subject’s exercise of the above-mentioned rights, we may request relevant identification.
8. QUESTIONS OR COMPLAINTS
lf you have a question or have concerns or wish to make a complaint about how 55 North Ventures processes your personal data, please contact us by e-mail using the mailing address listed in section 1.
For more information on your rights, please see the Danish Data Protection Agency’s guidelines describing the data subject’s rights on www.datatilsynet.dk.
You may also file a complaint with the Danish Data Protection Agency if you are dissatisfied with our processing of your personal data. You can find the contact details of the Danish Data Protection Agency on www.datatilsynet.dk.
Last updated: 28 June 2025.
Sustainability-related disclosures.
Website Disclosures
Publication date: 27/06/2025
Publication version: Version 1.0
Publication URL: https://www.55n.vc/english-privacy-policy
1. BASIC INFORMATION
1.1 Integration of sustainability risks in the investment decision-making process (art. 3(1))
55 North Ventures Management ApS, CVR-no. 45505235 (“Fund Manager”) manages the alternative investment fund 55 North Ventures Fund I K/S, CVR-no. 45557960 (the “Fund”).
Awareness of sustainability risks is built into all of the Fund Manager’s key processes, from screening and due diligence of potential target companies to portfolio governance and monitoring of portfolio companies and shall always comply with the Fund’s ESG and investment policy. Thus, the awareness and integration of sustainability risks are firmly integrated in the Fund Manager’s investment decision and the processes in relation hereto.
The Fund Manager has looked at the sustainability risks likely to have a negative impact on the returns of the Fund.
To ensure that such risks are sufficiently reduced, the Fund Manager will perform an initial screening before entering into a term sheet to make sure that the investment opportunity does not engage with any of the following categories:
Activities being illegal in the jurisdiction where such activities take place;
activities or persons (physical or legal) that are subject to or is managed or otherwise affiliated with Persons that are subject to restrictive measures (sanctions) imposed by the United Nations, the European Union or Denmark from time to time;
the manufacture, sale or distribution of cigarettes, cigars, tobacco, paper used by end consumers for rolling cigarettes, filters and snuff tobacco, E-cigarettes and/or nicotine products and any other products categorized as tobacco by the relevant authorities;
the cloning of human beings for reproductive purposes;
the manufacture, production, sale and/or storage of UN defined unconventional weapons and/or controversial weapons, (including but not limited to cluster weapons, biological weapons, anti-personnel mines, biological weapons, chemical weapons, cluster munitions, depleted uranium, white phosphorus, and nuclear weapons in breach of the Treaty of the Non-Proliferation of Nuclear Weapons);
activities which can be considered as pornography, adult entertainment or which can be associated with prostitution;
fishing activities and/or fishing gear such as bottom trawling, beam trawling, spinning rods and dredges etc., which levels out the sea floor, disrupts the biodiversity and risks bycatching other species;
activities within fossil raw materials including fossil fueled power plants as well as activities which have drilling, investigations, extractions, refining and sale of crude oil, natural gas and thermal coal or storage of fossil fuels and the underlying infrastructure (pipelines etc.) as its purpose;
activities within the fossil fuel-based energy sector, including (i) the development, ownership, or operation of fossil-fuelled power plants, (ii) the exploration, drilling, extraction, refining, or sale of crude oil, natural gas, or thermal coal and/or (iii) the storage, development, or operation of supporting infrastructure, including to pipelines, transportation, logistics, or services primarily dedicated to fossil fuel-related activities;
the exploration and production of fossil fuels including oil and gas, thermal coal, artic oil, shale energy and oil sands);
gambling (including the operation of casinos, lotteries, bookmaking and online gambling);
the production of cannabis for recreational use (including the cultivation of cannabis or the development of cannabis products);
the operation of predatory lending practices (meaning lending practices that are in violation of local laws and involve exploitive lending practices using high interest rates and/or other unfavorable terms to borrowers; and/or
the production of palm oil.
If the business activity falls within any of the categories above, the Fund Manager will abstain from moving further with the investment opportunity.
1.1 Integration of sustainability risks in the investment decision-making process (art. 3(1))
55 North Ventures Management ApS, CVR-no. 45505235 (“Fund Manager”) manages the alternative investment fund 55 North Ventures Fund I K/S, CVR-no. 45557960 (the “Fund”).
Awareness of sustainability risks is built into all of the Fund Manager’s key processes, from screening and due diligence of potential target companies to portfolio governance and monitoring of portfolio companies and shall always comply with the Fund’s ESG and investment policy. Thus, the awareness and integration of sustainability risks are firmly integrated in the Fund Manager’s investment decision and the processes in relation hereto.
The Fund Manager has looked at the sustainability risks likely to have a negative impact on the returns of the Fund.
To ensure that such risks are sufficiently reduced, the Fund Manager will perform an initial screening before entering into a term sheet to make sure that the investment opportunity does not engage with any of the following categories:
Activities being illegal in the jurisdiction where such activities take place;
activities or persons (physical or legal) that are subject to or is managed or otherwise affiliated with Persons that are subject to restrictive measures (sanctions) imposed by the United Nations, the European Union or Denmark from time to time;
the manufacture, sale or distribution of cigarettes, cigars, tobacco, paper used by end consumers for rolling cigarettes, filters and snuff tobacco, E-cigarettes and/or nicotine products and any other products categorized as tobacco by the relevant authorities;
the cloning of human beings for reproductive purposes;
the manufacture, production, sale and/or storage of UN defined unconventional weapons and/or controversial weapons, (including but not limited to cluster weapons, biological weapons, anti-personnel mines, biological weapons, chemical weapons, cluster munitions, depleted uranium, white phosphorus, and nuclear weapons in breach of the Treaty of the Non-Proliferation of Nuclear Weapons);
activities which can be considered as pornography, adult entertainment or which can be associated with prostitution;
fishing activities and/or fishing gear such as bottom trawling, beam trawling, spinning rods and dredges etc., which levels out the sea floor, disrupts the biodiversity and risks bycatching other species;
activities within fossil raw materials including fossil fueled power plants as well as activities which have drilling, investigations, extractions, refining and sale of crude oil, natural gas and thermal coal or storage of fossil fuels and the underlying infrastructure (pipelines etc.) as its purpose;
activities within the fossil fuel-based energy sector, including (i) the development, ownership, or operation of fossil-fuelled power plants, (ii) the exploration, drilling, extraction, refining, or sale of crude oil, natural gas, or thermal coal and/or (iii) the storage, development, or operation of supporting infrastructure, including to pipelines, transportation, logistics, or services primarily dedicated to fossil fuel-related activities;
the exploration and production of fossil fuels including oil and gas, thermal coal, artic oil, shale energy and oil sands);
gambling (including the operation of casinos, lotteries, bookmaking and online gambling);
the production of cannabis for recreational use (including the cultivation of cannabis or the development of cannabis products);
the operation of predatory lending practices (meaning lending practices that are in violation of local laws and involve exploitive lending practices using high interest rates and/or other unfavorable terms to borrowers; and/or
the production of palm oil.
If the business activity falls within any of the categories above, the Fund Manager will abstain from moving further with the investment opportunity.
If the business activity does not fall within any of the categories, the Fund Manager will proceed its due diligence after signing the term sheet to screen and identify any additional, potential sustainability risks which due to the Fund’s investment scope typically cover:
During the investment phase, the Fund Manager leverages the due diligence findings to ensure that the relevant sustainability risks are identified, assessed, and appropriately addressed in the investment memo that forms the basis of the investment decision and, if the decision to invest is made, the legal documentation pertaining to the investment. This includes obligating the portfolio company to regularly report on sustainability risks and how they are mitigated.
Following the investment and throughout the holding period, the Fund Manager maintains an ongoing process to evaluate, mitigate, and report on sustainability risks. Relevant information will thus be collected from the portfolio company through a structured reporting process. This ensures that the most material sustainability risks relevant to the Fund are continuously identified and managed. The process is implemented and overseen by the Managing Partners of the Fund Manager.
In addition, the Fund Manager ensures that the portfolio company actively engages with the identified sustainability risks post-investment. Where the Fund Manager holds significant influence over the portfolio company’s structure and governance, it exercises that influence —particularly at the board level — to support effective management and oversight of these risks.
Based on the above, the Fund Manager deems the sustainability risks’ negative impact on the returns of the Fund to be low
1.2 Remuneration policies (art. 5)
The Fund Manager does not have a remuneration policy, and Fund Manager’s remuneration structures are not linked to the integration of sustainability risks. Thus, they are not structured to the effect that they encourage excessive risk taking with respect to sustainability risks.
NO CONSIDERATION OF ADVERSE IMPACTS OF INVESTMENT DECISIONS ON SUSTAINABILITY FACTORS
Publication date: 27/06/2025
Publication version: Version 1.0 Publication
URL: https://www.55n.vc/english-privacy-policy
Fund Manager: 55 North Ventures Management ApS, CVR-no. 45505235
Fund: 55 North Ventures Fund I K/S, CVR-no. 45557960
The Fund Manager does not consider any adverse impacts of its investment decisions on sustainability factors and, hence, does not use the indicators listed in Annex 1 of the Commission’s delegated regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 (the ”SFDR”) in its investment decisions, as these currently include metrics that the Fund Manager does not consider to be applicable to the early-stage investments undertaken by the Fund. The Fund Manager will on a continuous basis assess this approach. If and to the extent this should change to the effect that the indicators become more practicable to use in early-stage investments, the Fund Manager will re-evaluate whether to consider the principal adverse impacts set out in Table 1-3 of Annex 1 of its investment decisions in due course.