Provider: Brightpoint Fund Services GmbH
Address: Hopfenmarkt 33, 20457 Hamburg
Phone: +49 40 98 66 01 76 - 0
E-Mail: contact@brightpoint-group.com
Web: www.brightpoint-group.com
Legal representatives: Maren Eckloff-Böhme, Mario Stefan Oelkers
Responsible for the content: Brightpoint Fund Services GmbH
Hopfenmarkt 33
20457 Hamburg
contact@brightpoint-group.com
HR-No.: HRB 136231
Register Court Amtsgericht Hamburg
Sales tax no.: DE 299551095
Photos by Robert Horvick, Ivan Bandura, Victor Freitas, Edgar Castrejon, Jason Edwards, Erika Harano, Wesley Tingey, Bernad Hermant, Camila Damásio, Andy White and Damon Hall on Unsplash.
Portraits of team members by Sebastian Schmitt.
Data protection officer: Mauß Datenschutz GmbH, Neuer Wall 10, 20354 Hamburg, 040 – 99 99 95 20, datenschutz@datenschutzbeauftragter-hamburg.de
Liability for contents
As a service provider, we are responsible for our own content on these pages in accordance with the general laws pursuant to § 7 para. 1 TMG. According to §§ 8 to 10 TMG, we are not obligated to monitor transmitted or stored information or to investigate circumstances that indicate illegal activity. Obligations to remove or block the use of information under the general laws remain unaffected. However, liability in this regard is only possible from the point in time at which a concrete infringement of the law becomes known. If we become aware of any such infringements, we will remove the relevant content immediately.
Liability for links
Our offer contains links to external websites of third parties, on whose contents we have no influence. Therefore, we cannot assume any liability for these external contents. The respective provider or operator of the sites is always responsible for the content of the linked sites. The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not recognizable at the time of linking.
However, a permanent control of the contents of the linked pages is not reasonable without concrete evidence of a violation of the law. If we become aware of any infringements, we will remove such links immediately.
Copyright
The contents and works created by the site operators on these pages are subject to German copyright law. Duplication, processing, distribution, or any form of commercialization of such material beyond the scope of the copyright law shall require the prior written consent of its respective author or creator. Downloads and copies of this site are only permitted for private, non-commercial use. Insofar as the content on this site was not created by the operator, the copyrights of third parties are respected. In particular, third-party content is identified as such. Should you nevertheless become aware of a copyright infringement, please inform us accordingly. If we become aware of any infringements, we will remove such content immediately.
Brightpoint Capital Invest’s policy on the integration of sustainability risks in the investment decision‐making process (according to article 3 SFDR)
Brightpoint Capital Invest partly considers adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated principal adverse sustainability impacts statement of Brightpoint Capital Invest GmbH (LEI: 391200QBZWNXSO895F05) and all funds under management by Brightpoint Capital Invest GmbH.
This principal adverse impacts statement covers the reference period from 1 January 2022 to 31 December 2022.
Brightpoint Capital Invest has mainly a fund of funds activity or a management activity for funds. Brightpoint Capital Invest excludes for now funds that would harm environmental, social, ethical or governance factors and currently works on introducing a formal check as part of the due diligence. Impacts on sustainability factors are partly considered in the due diligence process taking due account of our fund management activities, our fund and the specificities of the venture capital business (investments in start-ups). Brightpoint Capital Invest applies the proportionality principle.
Brightpoint Capital Invest considers sustainability risks, as integral part of the risk analysis, in the investment decision making process. The results of this Due Diligence are taken into account for the investment decision. Brightpoint Capital Invest has decided to improve, to develop a more systematic ESG policy, to appoint a Sustainability Officer and to introduce an ESG management system. Work is in progress. As a first step Brightpoint Capital Invest has become 2020 climate neutral.
After Board’s decision on ESG policy and management system, we will publish more information about our policies on the identification and prioritisation of principal adverse sustainability impacts and indicators as well as any actions in relation thereto taken or planned.
In this context we will check a possible adherence to responsible business conduct codes and internationally recognised standards and reporting and if relevant the degree of its alignment with the objectives of the Paris Agreement.
According to article 5 SFDR we will include a statement on how those policies are consistent with the integration of sustainability risks in our remuneration policies information.
The following privacy policy is divided into:
Thank you for visiting our website www.brightpoint-group.com and for your interest in our company. We take the security and protection of your personal data entrusted to us very seriously and want you to feel safe and comfortable when visiting our website and using our services.
It is important to us that you know what personal data is collected when you use our offers and services and how we use it afterwards.
We are active in the area of financial services. The range of services includes administrative activities for third parties and the provision of consulting services to third parties. Insofar as our company processes personal data, this is done for the purposes stated in this data protection declaration in each case.
In addition, numerous technical and organizational measures have been implemented to ensure the most complete protection of personal data processed through this website. Nevertheless, there is always a residual risk (e.g. security gaps in data transmissions), so that absolute protection cannot be guaranteed. For this reason, you are free to transmit personal data to us by other means.
The responsible party pursuant to Article 4 (7) of the EU General Data Protection Regulation (DSGVO) is Brightpoint Fund Services GmbH, Hohe Bleichen 21, 20354 Hamburg, Germany (see our imprint).
You can reach our data protection officer by e-mail E-Mail: kontakt@bluedatex.de, Phone: +49 30 88 71 24 53. When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your questions. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations. If we make use of commissioned service providers for individual functions of our offer or would like to use your data for advertising purposes, we will inform you in detail about the respective processes below. In doing so, we will also state the specified criteria for the storage period.
Calling up our website
The website of our company collects a series of general data and information with each call of the website by a data subject or an automated system. This general data and information is stored in the log files of the server. The following data is collected
– IP-address
– Date and time of the request
– Time zone difference to Greenwich Mean Time (GMT)
– Content of the request (specific page)
– Access status/HTTP status code
– Amount of data transferred in each case
– Website from which the request comes
– Browser
– Operating system and its interface
– Language and version of the browser software.
Insofar as these aforementioned data are used by our company, no conclusions are drawn about the data subject. Rather, this information is required in order to
The legal basis for the temporary storage of the aforementioned data is Art. 6 para. 1 lit. f) DSGVO. Therefore, these anonymously collected data and information are evaluated by our company on the one hand statistically and on the other hand with the aim of increasing the data protection and data security of our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.
The controller will provide you with information about which personal data is stored about you at any time upon request. Furthermore, the controller will correct or delete personal data at your request or indication, provided that this does not conflict with any statutory retention obligations. A data protection officer named in this data protection declaration is available to the data subject as a contact in this context.
Other purposes
Personal data is also processed if you provide it to us of your own accord, for example in the context of an inquiry or booking an appointment or ordering information material or a newsletter. The legal basis is Art. 6 para. 1 lit. b DSGVO. In this respect, the data processed by us includes customer data, employee data and data from service providers and suppliers, insofar as this is necessary for the purposes named in the context of this data protection declaration.
Insofar as we process your data, as described above, for the purposes of receiving and processing your respective inquiry, booking or (newsletter) order, you are contractually obligated to provide us with this data. Without this data, we are not able to carry out the corresponding processing.
The controller shall take appropriate technical and organizational measures to ensure that, by default, only personal data whose processing is necessary for the respective specific processing purpose is processed.
If you have consented to the processing of personal data, cf. Art. 6 para. 1 lit. a DSGVO, you may revoke your consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until revocation. You can find the text of Art. 6 DSGVO here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
The personal data you enter will be collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be passed on to one or more processors, who will also use the personal data exclusively for an internal use attributable to the controller. The transfer of data to processors is based on Art. 28 (1) DSGVO.
A sale of your data to third parties and/or transfer of the data for the purpose of marketing is hereby excluded.
Your personal data may be forwarded to law enforcement authorities and, if applicable, to injured third parties without your express consent if it is necessary to clarify an illegal use of our services or for legal prosecution. However, this only happens if there are concrete indications of unlawful or abusive behavior. A transfer may also take place if this serves the enforcement of terms of use or other agreements. We are also legally obligated to provide information to certain public authorities upon request. These are law enforcement agencies, authorities that prosecute administrative offenses subject to fines and the tax authorities.
The transfer of this data is based on our legitimate interest in combating abuse, prosecuting criminal offenses and securing, asserting and enforcing claims provided that your rights and interests in the protection of your personal data do not prevail, Art. 6 (1) lit. f DSGVO.
A transfer to third countries does not take place.
In order to make our website user-friendly for you and to optimally adapt it to your needs, we use cookies in some areas. A cookie is a small file that is stored locally on your computer as soon as you visit a website. If you visit the website again with the same terminal device, the cookie indicates, for example, that it is a repeat visit. Cookies also enable us to analyze the use of our website. The cookie does not contain any personal information, it is not capable of identifying you on third party websites, including the websites of analytics providers.
We use the following types of cookies:
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 p.1 lit. f) DSGVO. Persistent cookies are deleted automatically after a specified period of time, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.
You can declare your consent or rejection of cookies - also for web tracking - via the settings of your web browser. You can configure your browser so that the acceptance of cookies is refused in principle or you are informed in advance when a cookie is stored. In this case, however, the functionality of the website may be impaired (e.g. when placing orders). Your browser also offers a function to delete cookies (e.g. via Delete browser data). You can find more information on this in the operating instructions or, as a rule, under settings of your Internet browser.
In order to better adapt this website to the needs of our patients, we analyze visits to our website. We use your IP address, which we anonymize beforehand (and possibly similar numbers exchanged between computers during normal Internet use) with the intention of being able to analyze data, among other things, about the web pages visited, about your browser and your computer. Cookies are also set for this purpose. Our cookie only contains a unique number to recognize you on our web sites, but not on third party web sites. The stored data is evaluated exclusively for statistical purposes; in particular, the IP address is not associated with a specific person. The data will not be passed on to third parties.
This website uses Google Universal Analytics, a web analytics service provided by Google, Inc. ("Google"). The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The legal basis for the processing of personal data using Google Analytics is Art. 6 para. 1 p.1 lit. f) DSGVO.
Google Universal Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
On this website, IP anonymization has been activated so that the IP address of users is truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Universal Analytics will not be merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link http://tools.google.com/dlpage/gaoptout?hl=de verfügbare Browser-Plugin herunterladen und installieren.
For more information on terms of use and data protection, please visit http://www.google.com/analytics/terms/de.html bzw. unter http://www.google.de/privacy.html.
We would like to point out that this website uses Google Universal Analytics with the code extension "anonymizeIp" to ensure anonymized collection of IP addresses (so-called IP masking) and to exclude direct personal reference.
Our website uses buttons for each of the social networksey
The buttons are marked with the logo of the respective social network. However, they are not the usual social plugins, but buttons with deposited links. The buttons must be activated (clicked) separately by you by clicking on them. As long as these buttons are not clicked, no data is transmitted to the social networks. Only when you click on the buttons and thus declare your consent to communication with the servers of the social network, the buttons become active and the connection is established.
After clicking, the button corresponds to a so-called share plugin. The social network is provided with information about the visited page, which you can share with your contacts in your social network. If you want to "share" the information, you must be logged in. If you are not logged in, you will land on the login page of the social network you clicked on and you will no longer be on our websites. If you are logged in, the information is transmitted that you would like to recommend the respective article.
By activating the button, the social networks then also receive, among other things, the information that and when you accessed the corresponding page of our website, as well as, for example, your IP address, information on the browser used and the language settings. When you click the button, your click is transmitted to the social network and used according to its data usage guidelines.
When the button is activated, we have no influence on the collected data and data processing operations and are not responsible for this data processing and, in this respect, are not the responsible party in the sense of the DSGVO. We are also not aware of the full scope of the data collection, its legal basis, the purposes as well as the storage periods. Therefore, the information provided here is also not necessarily complete.
The transmission of data takes place regardless of whether you actually have an account with the provider or are logged in there. If you are logged in to the provider, your data will be directly assigned to your account. If applicable, the providers also use cookies on your computer to track you.
To our knowledge, the provider stores this data in usage profiles, which it uses for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (also for users who are not logged in) for the display of needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles. To exercise this right of objection, please contact the respective provider.
The purpose and scope of the data collection and the further processing and use of the data by the respective social network, as well as your rights in this regard and setting options for protecting your privacy, can be found in the information:
If you do not want the social network to receive data about you, do not click the button.
The legislator has enacted a wide range of retention periods and obligations - particularly for service providers in the healthcare sector. After these periods have expired, the corresponding data is routinely deleted. If data is not affected by this, it will be deleted or anonymized if the purposes stated in the context of this data protection declaration cease to apply. Unless this Privacy Policy contains other, deviating provisions regarding the storage of data, the data collected by us will be stored by us for as long as it is required for the aforementioned purposes for which it was collected.
Other data uses and data deletion
Further processing or use of your personal data will generally only take place if permitted by law or if you have consented to the data processing or use. In the event of further processing for purposes other than those for which the data was originally collected, we will inform you of these other purposes prior to further processing and provide you with the other relevant information.
Abuse detection and tracking
We retain information for abuse detection and tracking, in particular your IP address, for a maximum of 7 days. The legal basis in this respect is Art. 6 (1) lit. f DSGVO, you can find the text of Art. 6 DS-GVO here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
Our legitimate interest in retaining data for 7 days is to ensure the proper functioning of our website and the transactions conducted via it, as well as to be able to defend against cyber attacks and the like. We may use anonymous usage information to tailor our website to your needs.
Right to information
You have the right to receive from us at any time, upon request, information about the personal data we have processed concerning you within the scope of Art. 15 DS-GVO. For this purpose, you can submit a request by mail or e-mail to the addresses below. You can find the text of Art. 15 DSGVO here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
Right to rectify inaccurate data
You have the right to request that we correct personal data concerning you without delay if it is inaccurate,
Art. 16 DSGVO. To do so, please contact us at the contact addresses below. You can find the text of Art. 16 DSGVO here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
Right to erasure
You have a right to the immediate erasure ("right to be forgotten") of personal data concerning you in the event of the existence of legal grounds under Art. 17 DSGVO. You can find the text of Art. 17 DSGVO here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
Legal grounds exist, for example, if the personal data are no longer necessary for the purposes for which they were originally processed or you have withdrawn your consent and there is no other legal basis for the processing; the data subject objects to the processing (and there are no overriding reasons for processing - this does not apply to objections to direct marketing). To exercise your above right, please contact us at the contact addresses below.
Right to restriction of processing
You have a right to restrict processing if the conditions are met and in accordance with Art. 18 DSGVO. You can find the text of Art. 18 DSGVO here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
According to this, the restriction of processing may be required in particular if the processing is unlawful and the data subject refuses the erasure of the personal data and instead requests the restriction of the use of the personal data or the data subject has objected to the processing pursuant to Art. 21 (1) DSGVO, as long as it has not yet been determined whether our legitimate grounds override theirs. To exercise your above right, please contact us at the contact addresses below.
Right to data portability
You have a right to data portability according to Art. 20 DSGVO. You can find the text of Art. 20 DSGVO here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
In this regard, you have the right to receive the data relating to you that you have provided to us in a common, structured and machine-readable format and to transfer this data to another controller, such as another service provider. The prerequisite for this is that the processing is based on consent or on a contract and is carried out with the help of automated processes. To exercise your above right, please contact us at the contact addresses below.
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out, inter alia, on the basis of Article 6(1)(e) or (f) DSGVO, in accordance with Article 21 DSGVO. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims. To exercise your above right, please contact us at the contact addresses below.
The text of Art. 21 GDPR can be found here:
http://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32016R0679&qid=1474615617790
Right to lodge a complaint with a supervisory authority
If you believe that the processing of personal data concerning you by us is unlawful, you have the right to lodge a complaint with the supervisory authority responsible for us. You can access the contact details of the state data protection authority responsible for you at:
https://www.datenschutz-wiki.de/Aufsichtsbehörden_und_Landesdatenschutzbeauftragte
The current version of this data protection declaration is always available at www.brightpoint-group.com.
k) Data protection officer
If you have any further questions regarding the processing of your personal data, you can contact our data protection officer directly, who is also available in the event of requests for information, applications or complaints:
Data Protection Officer:
Mauß Datenschutz GmbH
Neuer Wall 10, 20354 Hamburg
datenschutz@datenschutzbeauftragter-hamburg.de
Tel: +49 40 – 99 99 95 20
Art. 3 Integration of sustainability risks in BPL investment decisions
Pursuant to EU Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”), financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐making process.
Brightpoint Luxembourg S.à r.l. (“BPL) recognizes for each fund it manages that various sustainability risks can threaten the investments at individual asset level and portfolio level. In accordance with SFDR, “sustainability risks” refers to an environmental, social or governance event or condition that, if it occurs, may cause an actual or potential material negative impact on the value of the investment.
These sustainability risks may be from an environmental perspective (climate change transition and physical risks, natural resources depletion, waste intensity, energy consumption), a social perspective (labor retention, turnover and unrest, supply chain disruption, corruption and fraud and reputational concerns associated with human rights violations) and a governance perspective (fair, responsible and sustainable conduct from the management of partners, transparency, application of code of conducts etc.).
BPL applies the environmental, social and governance policy implemented at the level of Brightpoint Group (the “ESG Policy”) in its investment decision-making process. In accordance to the ESG Policy, BPL applies a negative screening process and, where applicable, the ESG integration, ESG engagement and Impact investing policy.
BPL is considering materially relevant sustainability risks into the negative screening process, valuation, asset selection, portfolio construction, and ongoing investment monitoring alongside with other material risk factors. The degree to which BPL will take into account that sustainability risks may vary from one product to another, depending on the product and concrete structuring of the individual product and its orientation to ESG projects
The manner in which the sustainability risks are integrated into the investment decision are disclosed at the level of each fund managed by BPL.
Additionally, as and where the product so requires, BPL will conduct top-down sustainability investment risk analysis of the portfolio. This may include, for example, exposure to sustainability risks (using third party ratings and data), controversial business exposures, compliance with UN Global Compact, and the potential impact of different climate change and transition risk scenarios.
When delegating the portfolio management function to a third-party or appointing an investment advisor, BPL will make sure that the third party applies the appropriate due diligence process to assess the sustainability risks in accordance with the characteristics of the product and have the required expertise and implemented procedures to integrate adequately the sustainability risks into the investment advice.
Art 4 : “No consideration of sustainability adverse impacts”
Pursuant to EU Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”), financial market participants shall publish on their websites information about whether or not consider principal adverse impacts of investment decisions on sustainability factors.
BPL does currently not consider directly and at its level the adverse impacts of its investment decisions on sustainability factors, (i) because its business as third-party alternative investment fund manager may include the servicing of various investment funds with diverging ESG profiles and (ii) because the size and scale of BPL’s activities is currently limited. BPL continues to review and consider its obligations with respect to whether it considers principal adverse impacts of investment decisions on sustainability factors at the level of BPL.
All the KIID Documents for the TVGF in German and English can be found here:
https://brightpoint-group.com/bib/tvgf_deAll the KIID Documents for the TVGF in Italian can be found here:
https://brightpoint-group.com/bib/tvgf We are happy to provide the passwords for the documents for the LP´s.The information that Brightpoint Fund Services GmbH, as the operator of the website www.brightpoint-group.com, makes available on its pages has been carefully selected, researched and compiled by us and is continuously updated as necessary. It is not possible for us to guarantee the accuracy, completeness and up-to-dateness of the content and the information contained herein.
Brightpoint Fund Services GmbH is also not liable for the content of third party websites that can be accessed via links on the website www.brightpoint-group.com. Brightpoint Fund Services GmbH is not responsible for the content of third party websites. Brightpoint Fund Services GmbH expressly distances itself from the content of third party websites. The respective provider or operator is responsible for the content of linked pages.