Aviso legal

LEGAL NOTICE

Bullnet Capital (i.e. Bullnet Gestión SGEIC SA), in accordance with article 10 of Law 34/2002 of July 11, of the Information and E-Commerce Services, makes the following general information available to users of the website www.bullnetcapital.com (the “Website”) whose owner is:

Name: Bullnet Capital SGEIC SA
Tax ID number: A83595314
Registered address: Parque Empresarial La Finca, Paseo del Club Deportivo 1, Edificio 3, 28223 Pozuelo de Alarcón (Madrid), Spain
Company registry data: Companies Registry of Madrid, Volume 149, Foil 149, Page M-324816, Registration 2. Spanish Securities Market Commission Register (CNMV), section of Venture Capital Management Companies Administrative Register, Register Number 31
Contact email: info@bullnetcapital.com

The users of the Website shall comply at all times with the following terms and conditions of use:

TERMS OF USE OF THE WEBSITE

1. Acceptance of the Terms of Use
The Website that Bullnet Capital places at the disposal of users, provides information about its activities, being itself considerate as an Introduction.

The Legal Notice, together with the Cookies Policy, constitute the terms and conditions governing access to and use of our website.

By accessing and using the website, the user fully accepts and agrees to comply with the Terms of Use of the Website. Therefore, the user must carefully read these Terms of Use of the Website in each of the occasions on which he intends to access and use the Website, as they may undergo modifications that would be communicated to the user with the new access. Bullnet Capital reserves the right to update, modify or eliminate these Terms of Use of the Website.

Website access by the user is free and does not require any previous subscription or register.

2. Terms of use of the website
The user shall make lawful use of the website in accordance with current law, good faith and public order. Similarly, the user agrees not to use the Website for fraudulent purposes, and not to carry out any activity that may damage the image, interests and rights of Bullnet Capital or any third parties.

It is expressly prohibited to reproduce, communicate to the public including making available, and to distribute of all or part of the contents for commercial purposes, except if the contents of the Website are used privately, without any commercial or profit purpose or is expressly authorized by Bullnet Capital.

3. Content of the Website
Contents of the Website have been both elaborated and included by Bullnet Capital, and, in some cases, by the investee companies, with the utmost care, but without any guarantee, and no derivate liability, or that could be derived, being assumed by Bullnet Capital, of the use of the information and contents of the Website made by users, and particularly, of the bad use of said contents.

4. Quality and availability of the service
Likewise, Bullnet Capital will make reasonable efforts to include useful, accurate and up-to-date information on the Website, but does not assume any liability for the information offered, for the inaccuracy, errors or omissions that may exist, especially the information and contents provided by third parties.

Bullnet Capital reserves the right to modify or to update in any moment the contents contained in the Website, as well as the right to delete, to restrict or block the access to them, temporarily or conclusively.

Bullnet Capital is not responsible for any kind of damages and losses arising from:

  • The lack of availability, maintenance and effective continuity of the Website and/or its services or contents.
  • The transmission of virus, worms or other harmful computer elements, despite having the appropriate tools available for detecting and disinfecting harmful or damaging software.
  • The reliability and veracity of the information provided by third parties in the Website, directly or through hyperlinks or links, as well as the modification or manipulation of this Website by third parties.

5. Modifications
Bullnet Capital may at its own discretion update, modify or delete information contained on the Website, including its content and/or services, also may limit or deny access to such information at any time without prior notice. Bullnet Capital reserves the right to eliminate, limit or prevent access to the Website when technical difficulties or circumstances arise from technical difficulties beyond the control of Bullnet Capital, at its discretion, reduce or remove the standard levels of security adopted for the proper operation of said website. In this respect, Bullnet Capital reserves the right to decide on the continuation of the information and services provided through the Website.

6. Links
The hyperlinks or links that could be included in the Website can lead the user to other third party sites, over which Bullnet Capital has no control. Bullnet Capital shall not be held liable for the information, services, general content or availability of such third party’s sites.

The insertion of links does not imply necessarily the existence of any kind of association between Bullnet Capital and the said third parties.

7. Liability
Users shall know that communications through open networks are exposed to a number of threats that makes them unsafe. It is their responsibility to take all appropriate measures to reasonably control these threats, including having updated malware detection systems, such as viruses, etc. software technical measures as well as having updated security patches of the internet browsers. To the maximum extent permitted by applicable law, Bullnet Capital is not responsible for damages caused to the user as a result of the risks inherent in the means employed, or those caused by vulnerabilities in your systems and tools. Bullnet Capital does not guarantee total security of its systems and although it has taken appropriate security measures cannot completely exclude the existence of vulnerabilities and, consequently, the user must be cautious when interacting with the Website.

In any case, BULLNET is not responsible for:

  • Any damages of any kind to the user’s computer caused by viruses, worms, trojans or any other harmful elements.
  • Any damages of any kind caused to the user resulting from failures or disconnections in telecommunications networks that produce the suspension, cancellation or interruption of the Website service during the provision thereof. In this regard, the user acknowledges that access to the Website requires reliance on services provided by third parties beyond control of BULLNET (for example: telecommunications network operators, service providers, etc.) which reliability, quality, continuity and operation does not correspond to BULLNET, nor is part of its responsibility to ensure the availability of the service.
  • The information of third parties in cases where BULLNET acts as a provider of intermediation services in the sense given by the LSSI, except when actual knowledge exists and the corresponding information has not been removed from the Website.

Bullnet Capital will not be liable for any damages, direct or indirect, that users may suffer derived from the improper use of this Website or its contents, not assuming any obligation to notify changes or modify the contents thereof.

8. Privacy
For more information about the processing of personal information of users derived from the use of the Website please read our Privacy Policy.

9. Miscellaneous
The applicable laws to the services of the information that Bullnet Capital provides through this Website will be those of Spain. Therefore, in any dispute or conflict related to or arising from the Website between the user and Bullnet Capital, the Spanish law shall apply.

PRIVACY POLICY

Bullnet Capital (i.e. Bullnet Gestión SGEIC SA) is committed to protecting and respecting your privacy and the confidentiality of your personal data. This Privacy Policy sets out when and how we use the personal information that you provide to us, including through this website (the “Website”). It also describes what information we collect, how we use it, and the rights you have in relation to that collection and usage.

Whenever you provide Personal Information, we are legally obliged to use it in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and the Organic Law 3/2018 of 5 December (LOPDGDD) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Bullnet Capital is the Data Controller of your personal data. By “personal data” we refer to data collected by Bullnet Capital that identifies and relates to you as an individual.

This policy applies to Bullnet Capital and all venture capital companies managed by Bullnet Capital.

1. Who is responsible for processing your personal data?

Bullnet Gestión SGEIC SA, with registered office at Paseo del Club Deportivo 1, Edificio 3, Parque Empresarial La Finca, 28223 Pozuelo de Alarcón (Madrid), E-mail address info@bullnetcapital.com.

2. Which personal data do we process about you?

We collect and use your personal data to the extent necessary in the context of our activities. We may collect various types of personal data about you depending on the nature of the service, for example your name, date of birth, address, financial information, bank details, email-address, telephone number, etc. But we may also collect technical information about you when you visit our website like the IP address, cookies ID, etc.

3. On which basis do we process your data?

We always ensure that a lawful basis exists for all of the personal information we process at Bullnet Capital.

4. What do we use your personal data for?

We use your personal data to manage any request for specific information or service, but also for statistics and to comply with legal obligations.

5. How do we process your data?

We ensure that the processing of personal data is limited to the specific, explicit and legitimate purposes for those that were collected, and that will not be further processed in a manner incompatible with said purposes.

6. For how long do we store your data?

The personal data provided shall be stored for the period necessary for managing the requested service, and subsequently they shall be stored, but locked, for as long as necessary to formulate, exercise and defend any claims arising from the data processing.

7. To whom do we disclose your personal data?

No communication of personal data to third parties is foreseen except, if necessary and only after having signed a confidentiality and data processor contract required by current privacy regulation.

8. What are your rights when you provide us with your data?

In accordance with the applicable regulations, you have various rights, namely:

Right of access: You will be able to consult your personal data included in our files.

Right of rectification: You can modify your personal data when they are inaccurate.

Right to erasure: You may request your personal data be deleted.

Right to restrict: You may request the restriction of the processing of your personal data.

Right to object: You can object to the processing of your personal data, on grounds relating to your specific situation.

Right to data portability: Where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.

Right to withdraw consent: If you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time.

You may exercise the rights listed above by writing to Bullnet Capital info@bullnetcapital.com. This request shall contain the following information: name and surname, address for notification purposes, copy of your current ID or passport and the rights exercised. These rights can be exercised at no cost.

For information about cookies on our website which we use to collect user’s standard internet log information and behaviour information please read our Cookies Policy.

If you believe that your personal data have not been processed in accordance with the regulations, you are also entitled to submit a complaint to the Spanish Data Protection Agency www.aepd.es.

COOKIES POLICY

This Website uses cookies in order to facilitate the navigation, remembering the User´s preferences and improving the provision of our services.

By visiting our Website, and the acceptation of the Terms and Conditions, you accept and consent the installation of cookies.

1. What are cookies?

Cookies are small text files which are downloaded onto your computer, smartphone or other device when you visit websites. They are designed to store and provide information to the owner of the website about the navigation of its users (connection time, operation of the page …), and this in order to make statistics, improve the service offered, allow certain technical features and, sometimes, offer personalized advertising.

2. What cookies do we use and for what purpose?

Our website uses the following types of cookies:

3. Technical and personalization cookies

These cookies are essential in order to enable you to access and use the features of the secure areas of our website. Without these cookies, services you have asked for cannot be provided. You cannot opt out of these cookies.

  • _dc_gtm_UA-109487845-1:  This cookie is associated with using Google Tag Manager to load other scripts and code into a page. Where it is used it may be regarded as Strictly Necessary as without it, other scripts may not function correctly.
  • devicePixelRatio: This cookie is used to know what kind of screen the user´ computer has, to display an image quality or another.

4. Analytics and advertising cookies

These cookies collect information about how you use our website.  This information is aggregated and therefore anonymous and it is only used to improve how our website works.

Google

  • _ga, _gid: our site uses Google Analytics, an analysis service provided by Google Inc. to get statistical information of an aggregate type that are useful to assess the use of the website and the activities carried out by the user. It can use a set of cookies to collect information and provide statistics without personally identifying Google visitors.
  • Advertising – Those cookies are used by Google for advertising. Those cookies are set up by doubleclick.net. DoubleClick uses cookies to improve advertising. Some common applications are to target advertising based on what’s relevant to a user, to improve reporting on campaign performance and to avoid showing ads that the user has already seen.

5. How can you disable the use of cookies?

If you do not wish to accept cookies you can amend your browser options on your computer or any other device.

The instructions to amend the browser settings are the following, depending on the browser used:

  • Internet Explorer: Tools> Internet Options> Privacy> Configuration.
  • Firefox: Tools> Options> Privacy> History> Custom Settings.
  • Chrome: Settings> Show advanced options> Privacy> Content settings.
  • Safari: Preferences> Security.

To prevent Google Analytics cookies being set, you may install the  Google Analytics Opt-out Browser Add-on.

6. Changes to the Cookies Policy

This Cookies Policy may be altered at any given time whenever required by current legislation or whenever there is a change to the type of cookies used.

7. Processing of personal data in connection with the use of cookies

 The use of cookies will involve the processing of personal data. In our Privacy Policy you can read about our processing of your personal data and your rights. Find out more about who we are, how to contact us and how we process personal data in our Privacy Policy.

RESPONSIBLE INVESTMENT POLICY

1. Introduction

Investors’ sentiment has experienced a powerful shift from companies with poor ESG ratings towards more responsible ones. There is also evidence that strong ESG performance serves to mitigate risks and enhance employee and structural efficiency.

At Bullnet Capital we are committed to integrating gradually ESG best practices into our operating philosophy and investment process. We do not only invest in companies that are financially rewarding but also environmentally oriented and socially responsible.

The integration of ESG factors into our investment decisions is an important part of fulfilling our mission to deliver strong returns to our investors. Analysing and mitigating sustainability risks is crucial for protecting our investments as well as our reputation and top position in the Spanish and European venture capital sector.

Bullnet Capital, through its investment activity, aims to comply with best practices and as responsible investor. Bullnet Capital commits to the United Nations Principles of Responsible Investment (UN PRI):

  • Incorporate ESG issues into investment analysis and decision-making processes.
  • Be active owners and incorporate ESG issues into our ownership policies and practices.
  • Seek appropriate disclosure on ESG issues by the entities in which we invest.
  • Promote acceptance and implementation of the Principles within the investment industry.
  • Work together to enhance our effectiveness in implementing the Principles.
  • Report on our activities and progress towards implementing the Principles.

Furthermore, Bullnet Capital has the opportunity to positively influence the companies we invest in by helping them not only to drive value and enhance returns but also to be more environmentally and socially oriented by helping them to achieve the Sustainable Development Goals (SDGs) and implement their own ESG policies and practices.

2. Purpose and Scope of Policy

At Bullnet Capital we believe that Environmental, Social and Governance (ESG) principles are not only crucial for shaping a better future for our planet and society but also for developing resilient companies and assets that deliver long-term value for our investors.

Our ESG Policy outlines our firm-wide approach to integrating ESG criteria into our investment analysis, decision-making processes and asset management practices.

3. Implementation Approach

Bullnet Capital’s approach is aimed at identifying and evaluating key ESG aspects of an investment from origination to exit. Additionally, we advocate the companies we invest in to incorporate ESG factors into their management practices to work towards implementing, measuring, and reporting on sustainability practices.

Specifically, Bullnet Capital aims to:

  • Identify key material ESG risks and opportunities as part of the due diligence, investment decision and ownership phases of its investment process
  • Map material ESG issues to the United Nations Sustainable Development Goals (“SDG”), and consider SDG alignment in its investment decisions; and
  • Encourage implementation of ESG best practices and support the building of long-term sustainable businesses in an environmentally and socially responsible manner.

4. Pre-Investment

Bullnet Capital seeks to ensure that material ESG risks and opportunities are considered as part of our evaluation of any prospective investment.

Each prospective investment is first reviewed against a set of excluded activities: pornography, weapons and ammunition (unless these activities are part or accessory to explicit European Union policies), betting and casinos, abusive finance or financial services, producing or promoting tobacco and distilled alcoholic beverages, related to any illegal economic activities and human cloning or GMOs. If revenues are derived from these activities, the investment opportunity is automatically rejected.

Bullnet has also incorporated the “do no significant harm” (DNSH) principle to our due diligence process. A DNSH certification is required, evidencing that the company’s activity contributes to the protection of the environment without causing any significant harm. This certification has to be issued by an independent certified firm,

During Bullnet Capital’s initial due diligence, early red flags relating to ESG are identified for each prospective investment, and a prospective investment’s potential alignment with Sustainable Development Goals is also highlighted.

Bullnet Capital’s investment due diligence process then includes assessment of the ESG risks and opportunities unique to each prospective investment. Prioritization is based on sector specific risks. Bullnet Capital gathers relevant information through posing questions to prospective investment companies.

Bullnet Capital’s Investment Committee considers findings from ESG related due-diligence in deciding whether to proceed with an investment, as well as in its determination of what post-acquisition processes and practices should be implemented in order to improve and properly manage ESG-related risks.

5. Post-Investment

During its investment ownership, Bullnet Capital seeks to ensure that ESG issues are regularly assessed through ongoing monitoring of ESG related information. Bullnet Capital engages regularly with the companies we invest in, in an effort to support them constructively on the effective management of ESG issues.

6. Transparency and Reporting

Bullnet Capital recognizes the benefits of transparency and is committed to continuously improving our ESG related disclosures and communication to all our investors. Presently, our ESG Investment Responsible Policy is available on our website.