Privacy Policy

About Pale Blue Dot Advisors AB and this privacy policy

Pale Blue Dot Advisors AB, Reg. No. 559246-5461, Bredgatan 4, 211 30 Malmö, Sweden (“Pale Blue Dot” or “we”) is a seed-stage venture capital firm, which invests in climate tech startups in Europe and the U.S. that reduce and reverse the climate crisis.

As part of our business, Pale Blue Dot processes personal data for which Pale Blue Dot is the data controller. This means that Pale Blue Dot is responsible for ensuring that the processing of personal data is carried out in accordance with applicable law and this privacy policy. We take all necessary measures to make sure that your personal data are being processed by us in a lawful, fair and transparent manner.

It is important to us that you feel comfortable with how we process your personal data. This privacy policy covers all necessary information about our personal data processing and it is important that you read and understand this privacy policy before you use any of our services. You should not use any of our services if you do not approve of how we process your personal data. Should you have any questions regarding our personal data processing, please contact us by using the contact details below.

Please note that our website may contain links to websites provided by third parties. These websites have their own privacy policies and Pale Blue Dot is not responsible for their business or their information policies. We recommend users who submit information to or through these third-party websites to review the privacy policies on these websites before submitting any personal data to them.

For the collection, administration and retention of information collected via cookies, please refer to our cookie policy.

What personal data do we collect and where from?

The types of personal data that we collect may, depending on the context, include:

  • name and contact information including address, mobile number and e-mail address;

  • personal identity number;

  • job applications, including cover letters, resumé, and photos (as applicable); and

  • other information that is relevant for customer surveys, advertisement/marketing or offers.

We may collect your personal data from the following sources:

  • when you contact us by e-mail or phone;

  • on Pale Blue Dot’s website, e.g. when you subscribe to our newsletter, submit an investment application or submit a job application;

  • by way of agreement, invoice, or other business contact, e.g. if you are a contact person for any of our business partners; or

  • from third parties including affinity.com and crunchbase.com.

Why do we process your personal data?

Pale Blue Dot may use your personal data for the following purposes and based on the following legal grounds:

Performance of a contract:

  • For the administration of investment applications and our performances of services related thereto.

  • To make payments.

  • For recruitment processes.

Compliance with a legal obligation

  • We save invoice documentation and recruitment documentation in accordance with applicable accounting laws and regulations.

  • We process personal data when carrying out certain mandatory risk, security, and anti-fraud controls.

Legitimate interests

  • We process your personal data in order to communicate with you (by e-mail or other communication tools).

  • In order to handle any business transaction made by a business contact on behalf of a company, we process the contact person’s personal data.

  • For marketing purposes.

Consent

  • If you have subscribed to our newsletter, we process your personal data in order to provide you with the newsletter.

Retention of personal data

Pale Blue Dot takes all reasonable steps to ensure that your personal data is processed and stored securely. Your personal data will never be stored longer than permitted by applicable law or longer than necessary to fulfil the above stated purposes. Your personal data will be processed by us during the following time periods, after which they will be deleted:

Contact person for a company:

  • Your personal data are saved for as long as you are an appointed contact person for a company doing business with Pale Blue Dot.

Performance of a contract:

  • Personal data (name, personal identity number, address, telephone number and e-mail address), which are submitted to Pale Blue Dot in connection with an investment application are stored for as long as necessary for Pale Blue Dot’s performance of the agreement with you.

Communication:

  • If you are in contact with Pale Blue Dot by, for example, e-mail your personal data are saved for as long as it is necessary for us to answer your question and complete any follow-up inquiries.

Job applicants:

  • Pale Blue Dot saves your application documentation, including your resumé, cover letter and photo, as applicable, during the recruitment process and for a following period of two years, in order for us to defend potential legal claims.

Legal obligation:

  • Pale Blue Dot saves any documentation that constitutes accounting information in accordance with applicable accounting legislation.

Consent:

  • In the event that we process your personal data based on your consent, we only save your personal data for as long as we still have your consent.

Transfer of personal data

Pale Blue Dot only transfers personal data as described below. We always observe great caution when transferring your personal data and your personal data is only transferred in accordance with this privacy policy and after taking appropriate security measures. We do not sell personal data to third parties. Pale Blue Dot may transfer your personal data in the following situations:

Group companies:

  • Pale Blue Dot may transfer your personal data to other group companies for the purpose of evaluating an investment opportunity or when investing in a company.

Business partners which are not group companies:

  • Our business partners will get access to your personal data to the extent necessary for them to fulfil their obligations relating to an investment due diligence.

Business transactions:

  • If all or part of Pale Blue Dot’s operations is sold or integrated with any other business, operation or company, your personal data may be disclosed to our advisors, potential buyers and their advisors, and be transferred to the new owners of the operation.

Third-party service providers:

  • Some companies provide services on our behalf. These services include, inter alia, providing newsletters to subscribers via e-mail. These companies will get access to your personal data to the extent necessary for them to fulfil their obligations, but they may not use or share the information for any other purposes.

Legal obligations:

  • Your personal data may also be disclosed for the purpose of Pale Blue Dot’s compliance with certain legal obligations and it may be transferred to relevant public authorities if and when permitted and required by law.

Under certain circumstances, personal data may be transferred to countries outside of the EU/EEA, more specifically to the U.S.A., as Pale Blue Dot has engaged certain American service providers. When such transfers are carried out, Pale Blue Dot takes all appropriate measures to ensure that your personal data is adequately protected and that all processing is performed in accordance with applicable data protection laws and this privacy policy. This may include, for instance, that:

  • the EU commission has decided that the receiving country ensures an adequate level of protection; or that

  • an agreement including certain standard contractual clauses issued by the European Commission (e.g. as per Commission Implementing Decision (EU) 2021/914 of 4 June 2021) has been entered into between Pale Blue Dot and the recipient.

You have the right to obtain a copy of the safeguards that we use when transferring personal data to a country outside of the EU/EEA by contacting Pale Blue Dot.

Withdrawal of consent

In the event that we process your personal data based on your consent, it is important that you are aware of your right to withdraw your consent at any time. You may withdraw your consent by contacting us on the contact details provided below. Such withdrawal may be made in whole or in part. Please note that if you withdraw your consent, you may not be able to use parts or all of our services.

Your rights

You have the right to request information about what personal data concerning you that we are processing and how it is being used by contacting us in writing (see contact details below). You also have the right to request correction of incorrect, incomplete or ambiguous personal data concerning you by contacting us. For the protection of your privacy and your personal data, we may require that you identify yourself in connection with our assistance.

In accordance with applicable data protection laws, you also have the right to request that your personal data be erased or that the processing of your personal data be restricted. In certain situations, you also have the right to object to the processing of your personal data and request that your personal data be transmitted in an electronic format.

You may file a complaint with the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten) if you believe that Pale Blue Dot’s processing of your personal data is not carried out in accordance with applicable laws.

Changes to the privacy policy

Please note that the terms of the privacy policy may be changed or amended. Any new version will be published on Pale Blue Dot’s website. Consequently, you should review these terms on a regular basis to make sure that you are satisfied with the changes. In case of any material changes we will, however, e-mail you, if you have given us your e-mail address, to make you aware of any changes made.

Contact us

If you have any questions related to this privacy policy, if you suspect that a breach of this privacy policy has occurred, or if you would like to contact us for any reason stated in this privacy policy, please contact us using the contact details provided below.


Pale Blue Dot Advisors AB
Bredgatan 4
211 30 Malmö
Sweden