Privacy & Cookie Policy
Climentum Capital Management ApS
Last updated: May 2026 • Version 2.0
1. Data Controller
Climentum Capital Management ApS is the data controller for the personal data we process. If you have any questions about this Policy or wish to exercise your rights, please contact us:
Company
Climentum Capital Management ApS
CVR
42573388
Address
Matrikel 1, Højbro Plads 10, DK-1200 Copenhagen C
hello@climentum.com
Website
www.climentum.com
Data protection queries
hello@climentum.com (subject: Data Protection)
2. Scope of This Policy
This Privacy & Cookie Policy ("Policy") describes how Climentum Capital Management ApS ("Climentum VC", "we", "us", "our") collects, uses, stores and shares personal data in connection with:
Visitors to our website at www.climentum.com
Founders and companies submitting pitch decks or investment-related materials
Portfolio company founders, employees, and board members
Investors and limited partners (LPs) in our funds
Co-investors, deal network contacts, and business partners
Suppliers and service providers
This Policy applies to personal data collected via our website, by email, and in the course of our investment activities. It does not apply to data collected exclusively offline unless otherwise stated.
3. Categories of Personal Data, Purposes, and Legal Basis
3.1 Website Visitors
We collect data about visitors to our website automatically through log files and session cookies. This includes:
IP address, browser type and version, operating system and device type
Referring/exit pages, date and time of visit, language settings
This data is used to analyse website traffic, improve user experience, and maintain security. It is not linked to individually identifiable persons.
Legal basis: Legitimate interest (Article 6(1)(f) GDPR) in delivering and optimising our website.
3.2 Newsletter Subscribers
If you subscribe to our newsletter, we collect and process your name and email address to send you news and updates about Climentum VC and our investment activities.
Legal basis: Your consent (Article 6(1)(a) GDPR). You may withdraw consent at any time by unsubscribing via any newsletter or by contacting hello@climentum.com. Withdrawal does not affect the lawfulness of prior processing.
3.3 Pitch Deck Submitters and Founders
When you submit a pitch deck or other investment-related materials via our website, by email, or through other channels, we collect and process information about you and your company, including:
Your name, email address, phone number, and job title
Company name, registration details, and sector
Information contained in your pitch deck or other submitted documents
Information about co-founders, employees, or other individuals named in submitted materials
We process this data to evaluate your company as a potential investment opportunity, conduct due diligence, maintain records of our investment decisions, and follow the development of your company for potential future funding rounds.
Submitting your personal data is voluntary. However, if you do not provide the relevant information, we will not be able to consider your company for investment.
If your submission contains personal data about other individuals (such as co-founders or employees), you are responsible for ensuring you have a lawful basis for sharing that data with us, and that those individuals have been informed about how their data may be used.
Legal basis: Legitimate interest (Article 6(1)(f) GDPR) in evaluating investment opportunities and managing our deal pipeline.
3.4 Portfolio Company Personnel
Once we have invested in a company, we process personal data about founders, employees, and board members in connection with our ongoing management of that investment. This may include:
Contact information (name, email, phone, address)
Professional background and employment details
Financial performance data and reporting
Information arising from board meetings and governance activities
Legal basis: Legitimate interest (Article 6(1)(f) GDPR) in managing our investment portfolio; performance of a contract (Article 6(1)(b) GDPR); and compliance with legal obligations (Article 6(1)(c) GDPR) where applicable.
3.5 Investors and Limited Partners (LPs)
We process personal data about individual investors and limited partners in connection with fund administration, investor relations, and our legal and regulatory obligations. This may include:
Identity and contact information
KYC (Know Your Customer) and AML (Anti-Money Laundering) documentation
Financial and tax information required for fund administration
Subscription and investment documentation
Legal basis: Performance of a contract (Article 6(1)(b) GDPR); compliance with legal obligations including KYC/AML requirements (Article 6(1)(c) GDPR); and legitimate interest (Article 6(1)(f) GDPR) in managing investor relations.
3.6 Co-Investors, Deal Network Contacts and Business Partners
We maintain a network of co-investors, advisors, and deal-flow contacts. We store contact information (name, email, company, role) in our CRM for the purposes of deal-sourcing, co-investment, and business development.
Legal basis: Legitimate interest (Article 6(1)(f) GDPR) in developing and maintaining our professional network in connection with our investment activities.
3.7 Suppliers and Service Providers
We process contact information about individuals at our suppliers and service providers to manage our contractual relationships.
Legal basis: Performance of a contract (Article 6(1)(b) GDPR) or legitimate interest (Article 6(1)(f) GDPR) in managing supplier relationships.
4. Transfer of Personal Data
We may share personal data with the following categories of recipients:
Technical service providers and system suppliers (e.g. CRM platform, cloud hosting, email distribution) under data processing agreements
Legal, financial, and tax advisors where necessary for our activities or legal obligations
Tax authorities and other public institutions where required by law (Article 6(1)(c) GDPR)
Co-investors, where sharing your pitch deck or investment information may optimise your funding opportunity — we will inform you when this is relevant
We do not sell personal data to third parties.
We only transfer personal data to recipients outside the European Economic Area (EEA) in compliance with Chapter V of the GDPR, using Standard Contractual Clauses (SCCs) adopted by the European Commission or another appropriate safeguard under Article 46 GDPR. You may request a copy of the relevant safeguards by contacting us at hello@climentum.com.
5. Retention Periods
We retain personal data only as long as necessary for the purposes described in this Policy, or as required by law. Specific retention periods are set out below:
Website visitor / log file data: Up to 12 months, then anonymised or deleted
Newsletter subscribers: Until consent is withdrawn, then deleted within 30 days
Pitch decks — investment made: 5 years after the portfolio company is removed from our active investment management system, unless a longer period is required by law
Pitch decks — investment not made: Until the end of the active investment period in which the decision was made. Retained under legitimate interest to follow company development for potential future rounds. You may request deletion at any time.
Portfolio company personnel: For the duration of the investment and 5 years thereafter, unless a longer period is required by law
LP / investor data: For the duration of the fund relationship and 5 years thereafter, or as required by applicable financial and AML regulations
Supplier contact data: 5 years after termination of the contractual relationship
Deal network / CRM contacts: Until you object or request deletion; reviewed at least every 3 years
6. Your Rights
Under applicable data protection law (GDPR), you have the following rights:
Right of access: You may request a copy of the personal data we hold about you.
Right to rectification: You may request correction of inaccurate or incomplete personal data.
Right to erasure: You may request deletion of your personal data under certain conditions.
Right to restrict processing: You may request that we restrict how we process your personal data in certain circumstances.
Right to object: Where processing is based on legitimate interest (Article 6(1)(f) GDPR), you may object at any time on grounds relating to your particular situation. We must cease processing unless we can demonstrate compelling legitimate grounds that override your interests, or the data is needed for legal claims. Where data is processed for direct marketing, you have an unconditional right to object.
Right to data portability: Where processing is based on consent or contract, you may request your data in a structured, machine-readable format.
Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
We will respond to requests within one month of receipt. To exercise any of these rights, contact us at hello@climentum.com.
You also have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet): www.datatilsynet.dk.
7. Data Security and Breach Notification
We have implemented appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or disclosure. Access is restricted to personnel with a legitimate need. We review and update our security practices regularly.
In the event of a personal data breach likely to result in a risk to individuals' rights and freedoms, we will notify Datatilsynet within 72 hours of becoming aware of the breach (Article 33 GDPR). Where the breach is likely to result in a high risk to individuals, we will also notify affected individuals directly without undue delay (Article 34 GDPR).
8. Cookie Policy
8.1 What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They are widely used to make websites function correctly and to provide information to the website owner. Under Danish law (the Danish Executive Order on Cookies) and the GDPR, we are required to obtain your prior consent before setting any cookies that are not strictly necessary.
8.2 How to Manage Your Cookie Preferences
When you first visit our website, a cookie consent banner will allow you to accept or decline each category of cookie. You can change your preferences at any time via the cookie settings link in the footer of our website, or by adjusting your browser settings. Note that declining certain cookies may affect the functionality of the website.
You are never required to accept non-essential cookies to use our website.
8.3 Categories of Cookies We Use
Strictly necessary: No consent required
Required for the website to function. These include session management and security cookies. They cannot be disabled via our cookie banner.
Analytical / statistical: Consent required (opt-in)
We use Google Analytics to understand how visitors use our site (pages visited, time on site, traffic sources). These cookies collect data that is associated with your IP address. Google Analytics will only be activated after you have given your consent.
Functional: Consent required (opt-in)
Cookies that remember your preferences (e.g. language, newsletter subscription status) to improve your experience.
Marketing: Consent required (opt-in)
Cookies used to deliver relevant content or measure the effectiveness of our communications. These are only set with your explicit consent.
8.4 Third-Party Cookies
Our website uses Google Analytics, provided by Google LLC. Google may process data outside the EEA. Where this occurs, we rely on Standard Contractual Clauses as the appropriate safeguard. For more information, see Google's privacy policy at policies.google.com/privacy.
We do not use any other third-party advertising or tracking cookies at this time. If this changes, this Policy will be updated accordingly.
8.5 Log Files
Our hosting provider automatically logs technical data including IP addresses, browser type, ISP, date/time stamps, and referring pages. This data is used solely for security and performance purposes and is not linked to individually identifiable persons.
9. International Data Transfers
We store and process personal data within the European Economic Area (EEA) where possible. Where we transfer personal data to recipients outside the EEA (for example, via Google Analytics), we do so only in compliance with Chapter V of the GDPR, relying on:
Standard Contractual Clauses (SCCs) adopted by the European Commission, or
An adequacy decision covering the recipient country
You may request a copy of the relevant safeguards by contacting us at hello@climentum.com.
10. Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or applicable law. The latest version will always be available at www.climentum.com. Where changes are material, we will notify relevant individuals as required by law.
This Policy was last updated in May 2026 (Version 2.0).
11. Contact
For any questions about this Policy or your personal data:
Company
Climentum Capital Management ApS
Address
Matrikel 1, Højbro Plads 10, DK-1200 Copenhagen C
CVR
42573388
Email
hello@climentum.com
Website
www.climentum.com
To lodge a complaint with the Danish supervisory authority:
Datatilsynet
www.datatilsynet.dk