Legal & Privacy
In the United Kingdom ("UK"), Hg is the trading name of HgCapital LLP and Hg Pooled Management Limited (together with their affiliates, hereinafter referred to as “Hg” or “we”), both of which are authorised and regulated by the Financial Conduct Authority with the following FCA registration numbers:
HgCapital LLP: 478870
Hg Pooled Management Limited: 122466
In Germany, Hg operates through Hg Advisory GmBH & Co KG, which provides services directly to Hg Pooled Management Limited.
In the United States (“US”), Hg operates through Hg (US) Inc., which provides services directly to Hg Pooled Management Limited.
In France, Hg operates through Hg France SAS, which provides services directly to Hg Pooled Management Limited.
Hg acts for its funds or affiliates and for no one else in relation to its business. It will not advise, provide services to or be responsible for providing client protections to any other person, including anyone accessing this site.
The trademarks, service marks and logos shown on this website are registered and unregistered trademarks of Hg and others. Nothing in these Terms, or on this website, should be construed as granting any licence or right to use any of these trademarks.
Downloading or other copying from this site does not transfer to you title to any material or software. Should you download or copy material from this site no copyright or other proprietary notices should be removed. Hg reserves all rights with respect to copyright and trademark ownership of all material on this site and will enforce such rights to the full extent permitted by law.
The contents of this site have been prepared solely for information purposes and Hg’s communications are only directed at professional clients and eligible counter-parties. They are not directed at any other person. Funds managed by Hg are not available to members of the general public. In addition, no information on this site constitutes investment, tax, legal or any other advice and nothing on this site is intended to constitute an invitation or inducement to engage in investment activity in any jurisdiction.
Access in Non-UK Jurisdictions
Hg does not represent that any materials on this site are appropriate for use, or permitted by local laws, in all jurisdictions or by all investors. Those accessing the site do so of their own initiative and are responsible for compliance with applicable laws and regulations of any relevant jurisdiction. In particular, the site is not directed at any person resident in any jurisdiction where, under local law or regulation, the publication or availability of this site is prohibited. Persons to whom such restrictions apply must not access this site.
No Representation or Warranty
The information on this site is published in good faith but no representation or warranty, express or implied, is made by Hg or by any of its partners or employees, as to its accuracy or completeness and it should not be relied on as such. Nothing in these Terms attempts to exclude liability that Hg may have under the UK Financial Services and Markets Act 2000 (“FSMA”).
To the extent permitted by applicable law, Hg does not warrant that this site will be available at any time or that your access to the site will be uninterrupted, timely or free from viruses.
These Terms are governed by and construed in accordance with the laws of England and Wales.
Hg respects your privacy and recognises the importance of protecting the personal information that we hold.
This statement sets out the rights that you have in respect of your personal information. It also details examples of when we collect personal information, what personal information we collect, what purposes we use that information for, who we share that information with and how long we hold certain personal information for.
Scope of this Notice
This Policy applies to actual and potential investors, consultants, suppliers, advisers, business partners and associates, recruitment candidates and visitors to our office, events and website.
Hg may change this Policy over time by updating this page. You can determine if the Policy has been revised since your last visit by referring to the “last updated” date at the bottom of the page.
This privacy statement was updated on 21 February 2020.
When we collect personal information
Hg collects information from or about you, e.g. when:
you are an actual or potential investor, consultant, supplier, advisor or business partner or associate;
you are a business owner, entrepreneurial leader or talented individual who is or may be interested in the work we do or the opportunities we provide;
you visit our website, sign up to our news notifications via any registration form on our website, or you engage with us on social media;
you contact us by any means with queries, interests or concerns or complete surveys we send you;
you have an appointment with us or have or will attend an event of ours, including one of our forums or networking dinners;
you visit one of our offices which have CCTV systems which record your image and operated for the security of both visitors and staff; and / or
you choose to provide us with your personal information during business encounters, for example in the form of a business card.
Hg may collect personal information from you directly, from public sources or from third parties, such as business associates or recruitment agents.
The personal information collected
The type of personal information that Hg collects depends on the legitimate purposes for which it is collected (see 2.3 below) but may include:
names, email addresses, phone numbers, job titles, places of work, work addresses, photos, career biographies, dietary requirements;
if you are an actual or potential investor, consultant, supplier, adviser or business partner, information required to verify your identity, including passports, identification documents and proof of home addresses for Know Your Customer, anti-money laundering, references, background checks and other similar checks;
any personal information that is contained in consultancy agreements, engagement letters or other forms of written or oral agreements; and/or
information gathered in relation to a recruitment opportunity, including your CV, which we may have received directly from you (e.g. via the email address email@example.com), or, with your consent, from Hg staff or a third-party.
Hg also collects certain information about you automatically when you use our website. Cookies allow Hg to record certain information about you when you use our website, including details of your domain name, IP address, operating system and browser. This helps Hg to understand your use of our website and enables the monitoring and improvement of our website. If you prefer to block cookies please refer to the instructions or help service on your internet browser.
Use of your personal information
We collect and use your information on the basis that:
it is in our or others’ legitimate interests to do so (as described below), and such interests are not overridden by your privacy interests;
it is reasonably necessary to meet our legal or regulatory responsibilities, including our fiduciary duties and FCA obligations to our clients or when we make disclosures to courts, tribunals, authorities, regulators or supervisory or governmental bodies;
in some cases, it is necessary or desirable for us to enter into, and perform our obligations under our contract with you; and/or
we have obtained your consent.
Hg may use your information for the purposes of the following legitimate interests:
compliance with our legal and regulatory obligations, including our fiduciary duties and FCA obligations to our clients; requests for disclosures from a court, tribunal, authority, regulator or supervisory or governmental body; compliance with Know Your Customer and anti-money laundering requirements and references, background and other similar checks on or conducted by Hg;
performing activities relating to client management, financial management, reporting and administration (such as promotion of our business to potential clients, performing accounting, auditing and other internal functions, managing existing investments, and providing updates of investments to clients);
facilitating business opportunities, including communicating with you about potential business, partnership or career opportunities; searching and assessing potential investment and value creation opportunities for Hg and the portfolio companies we manage; conducting market due diligence or other due diligence in respect of potential or actual investment opportunities; discussing merger or acquisitions with a potential buyer or merger partner, including their advisers; administering relationships, meetings and travels for employees, clients, business partners and experts;
recruitment activities, including assessing your application for employment with us or one of our portfolio companies; evaluating potential candidates for recruitment processes;
ensuring our marketing efforts and publications are appropriately focused, including communicating with you about service updates, marketing and promotions based on your communication preferences; responding to your enquiries and resolving your complaints; and improving our marketing materials to tailor their relevance to those visiting our website and social media channels; and/or
obtaining professional services from our lawyers, accountants, consultants, auditors and other advisers.
If you would like further information on how we have balanced our and others’ legitimate interests against your privacy interests, please contact firstname.lastname@example.org.
Who we share your information with
Hg shares your information within the Hg group, including our portfolio companies (details of which you can find on our website) and in certain circumstances, e.g. in relation to recruitment opportunities, prospective portfolio companies.
Hg may share your information with third parties, including independent contractors or subcontractors (such as individuals who are engaged to assist Hg or its portfolio companies on specific projects), agents (such as recruitment agents and corporate secretarial services agents) and service providers (such as legal, consultancy, financing and paper archiving providers) who need to receive your information in the course of providing services for or on behalf of us for the purposes specified in this Policy.
Hg also engages trusted third-party IT service and software providers to host, store and process data, e.g. information relating to employees is stored in payroll and HR software systems; information about employment candidates and event attendees is recorded on a CRM system; information relating to our investments and investment activities is retained on accounting and reporting software systems.
Information will only be transferred or provided to third-party providers where reasonably necessary to enable us to fulfil the purposes set out in this Policy. We will ensure that each such provider has agreed to protect and maintain the confidentiality and security of information Hg shares with them.
We may share information with an actual or potential buyer, seller, co-investor or joint venture partner and our and their advisers in connection with any actual or potential acquisition, sale, co-investment, joint venture or similar transactions in connection with Hg and/or the portfolio companies managed and/or invested by Hg.
Authorities as required or permitted by law
We may disclose your personal information: (a) as required or permitted by, or to comply with, applicable law, regulation, court or tribunal processes or other statutory requirements; (b) respond to requests from or disclosures required by any court, tribunal, authority, regulator or supervisory or governmental body or (c) to comply with Know Your Customer and anti-money laundering requirements and references, background and other similar checks on or conducted by Hg.
Retention and deletion of information
Standard retention period
The personal data we collect will only be retained for as long as it is needed to fulfil the purposes set out in this privacy statement. This period is maximum 10 years, subject to certain variations described below.
Deletions will be carried out in accordance with Hg’s retention policy. Any information stored in hard copy format (in paper form) is treated as confidential and will be shredded at the point of soft copy deletion.
Variations to retention period
We will retain your information for longer than the standard retention period where permitted or required by law, including to comply with the duration of any statutory or contractual limitation periods. For example, we will retain information about investors for the lifetime of the fund plus an additional seven years.
In relation to data collected about visitors to the website, data is retained for 50 weeks.
In relation to personal data collected about potential candidates for Hg or its portfolio companies who have not been hired by Hg or one of its portfolio companies, data may be retained for up to six years in case such candidates are suitable for other employment opportunities which arise at Hg or across its portfolio.
Data protection laws in some countries provide you with various rights. In particular, in the European Union, data protection laws provide rights to:
object to the processing of your information, e.g. because you would prefer us not to keep your details as part of recruitment opportunities;
be removed from our marketing lists or change your marketing preferences by contacting
request a copy of the information we hold about you;
withdraw consent to our processing of your information (to the extent that such processing is based on consent);
restrict our processing of your information;
ask that we delete or correct the information that we hold about you; and
ask for personal data you have made available to us to be transferred to you or a third party in machine-readable formats.
These rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.
To exercise any of these rights, or if you have any other questions about our use of your information, please contact us at email@example.com.
Protecting your information
Transferring information internationally
Like many global organisations, we have offices in a number of countries (listed here), use global systems and interact with other parties globally. For example, Hg engages third-party IT service and software providers which host, store and process data in and outside of the European Economic Area (the “EEA”) and the United Kingdom. This means that your information may be transferred to a country outside the EEA – such as the US, the UK or other non-EEA countries – or to a country outside the UK. These countries may not offer the same level of data protection as in your home country, and may not be deemed as providing an adequate level of data protection under applicable data protection laws (“Non-Adequate Countries”). Where your information is transferred from within the EEA or from within the UK to a Non-Adequate Country, care is taken to ensure that the transfer is subject to appropriate safeguards in accordance with applicable data protection laws. To obtain a copy of these safeguards, please contact firstname.lastname@example.org.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect.
If you have any questions about this privacy notice, or our privacy related practices, you can contact: email@example.com
If you are unhappy with the way we have handled your information you have a right to complain to your local data protection regulator.
In the UK, your local regulator is the Information Commissioner, whose website is available at https://ico.org.uk
In Germany, your local regulator is the Bavarian Data Protection Authority, whose website is available is https://www.lda.bayern.de
What are cookies?
remember settings, so you do not have to keep re-entering them whenever you visit a new page;
remember information you give to a website; and
measure how you use the website so we can make sure it meets your needs.
To learn more about cookies and how to manage them, visit https://ico.org.uk/for-the-public/online/cookies/.
What cookies does Hg use?
The cookies used by the Hg website include:
Cookies set by our web platform, WordPress
to enable admin functions such as information about your browser settings, to understand which functionality to enable on the site, as well as to remember your choices. For example, if you filter a list of information we will remember your choice and default to that selection if you visit the page again. These choices are not tied to any personally identifiable information.
Cookies set by a third-party security service, Incapsula
to protect the site against malicious requests (e.g. DDOS attacks); and/or
Cookies set by Google Analytics to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. We do not link this information to your personal details.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Cookies expires after a set amount of time, for example the expiry of cookies used by Google Analytics are set out below under “Measuring website usage”.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website and affect our ability to provide certain services to you.
Measuring website usage
Google Analytics is in use to collect information about how visitors use this site. This provides us with important information that can enable the site to work better. We do not link this information to your name or address.
The following cookies are used by Google Analytics:
Cookie expires after
Randomly generated ID
Randomly generated ID
Randomly generated ID
When you close your web browser
Randomly generated ID
Disclaimer: Please note that the ESG Report or communication is not a marketing document and is provided for information purposes only. The environmental, social and governance (“ESG”) or impact goals, commitments, incentives and initiatives outlined in this report are purely voluntary, are not binding on investment decisions and/or Hg’s management of investments and do not constitute a guarantee, promise or commitment regarding actual or potential positive impacts or outcomes associated with investments made by Hg or funds managed or invested by Hg. Hg has established, and may in the future establish, certain ESG or impact goals, commitments, incentives and initiatives, including but not limited to those relating to net zero, greenhouse gas emissions reductions and diversity, equity and inclusion. Any ESG or impact goals, commitments, incentives or initiatives referenced in any information, reporting or disclosures published by Hg are not being promoted and do not bind any investment decisions made in respect of, or stewardship of, Hg or any funds managed or invested by Hg for the purposes of Article 8 of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector. Any measures implemented in respect of such ESG or impact goals, commitments, incentives or initiatives may not be immediately applicable to the investments of any funds managed by Hg and any implementation can be overridden or ignored at the sole discretion of Hg.
Transparency of Sustainability Risk Policies
Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector dated 27 November 2019 (“SFDR”)
TRANSPARENCY OF SUSTAINABILITY RISK POLICIES (Article 3, SFDR)
Hg Pooled Management Limited and its affiliates consider sustainability risks associated with investment opportunities including but not limited to risks associated with climate change, health & safety, cybersecurity and bribery and corruption. In particular, Hg evaluates ESG risks, mitigating factors and opportunities applicable for the asset type, geography and the industry as a whole. Hg tracks relevant data, and, where appropriate, integrates such data into the investment research, acquisition, onboarding, post-acquisition, value creation and realisation, risk monitoring and exit processes.
Hg’s targeted investment approach means we have extensive knowledge and a clear focus on the ESG metrics that are most material to the software and service sector. These ESG metrics are outlined in Hg’s Sustainable Business framework.
Hg maintains a Responsible Investment Policy that sets out its approach to the identification and management of sustainability and ESG related risks and opportunities throughout the investment activities, including the management of investee companies. HgCapital LLP has been a signatory to the United Nations Principles for Responsible Investment (“UNPRI”) since 2012 and is dedicated to the UNPRI’s six principles.
Further information on Hg’s policies on the integration of sustainability risks in our investment decision‐making process is located on Hg’s website at: Hg | Responsibility.
NO CONSIDERATION OF ADVERSE SUSTAINABILITY IMPACTS AT ENTITY LEVEL (Article 4, SFDR)
While Hg will continue to take into account ESG factors in its investment process, Hg does not consider adverse impacts of investment decisions on sustainability factors as set out in the SFDR. Hg has chosen not to do so presently as we consider that our existing ESG approach is appropriate, proportionate and tailored to the investment strategy we pursue.
While Hg does not currently intend to consider adverse impacts of investment decisions on sustainability factors, we continue to monitor regulatory developments with respect to the SFDR and other relevant laws and regulations, including the implementation of related and secondary legislation and regulatory guidance. Where required or otherwise appropriate, Hg will accordingly make changes to its existing policies and procedures.
TRANSPARENCY OF SUSTAINABILITY RISK POLICIES (Article 5, SFDR)
Hg pays their staff a combination of fixed remuneration and variable remuneration. Variable remuneration for relevant staff takes into account compliance with all of Hg’s policies and procedures, including those relating to risk management and the integration of sustainability risks. ESG is embedded into the performance process through one performance objective, applying across all teams, which relates to how the employee has contributed to ESG & Diversity across the firm or its portfolio. Furthermore, variable remuneration also depends on the performance against Hg’s values as part of the annual review process. One of Hg’s values is ‘Win right’ where the employees are asked to consider the firm’s long-term ESG performance.