1. Who we are and what this policy covers
BVP Investments Limited, trading as Business Venture Partners (“BVP”, “we”, “us”, “our”), is the controller of the personal data described in this policy. We are regulated by the Central Bank of Ireland.
- Registered office: Unit 4, Aspen Court, Bray Road, Cornelscourt, Dublin D18 K400, Ireland
- Company registration number: 395161
- Data protection contact: hello@bvp.ie, or write to us at the address above
This policy explains how we collect, use, share and protect personal data under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. It applies to:
- visitors to www.bvp.ie;
- investors and prospective investors in funds and products we manage, including the BVP EII Funds;
- brokers, financial advisors and other intermediaries we work with;
- directors, employees and other contacts at companies we invest in or consider investing in; and
- anyone who contacts us, subscribes to our insights or registers for our events.
For investors, this policy is our full Data Protection Notice, as referred to in our Information Memoranda.
2. Personal data we collect
We collect only the personal data we need for the purposes in section 4.
| Who | What we hold |
|---|---|
| Investors and prospective investors | Identity details (name, date of birth, nationality, PPS number and other tax reference numbers); contact details; anti-money laundering records (copies of ID, proof of address, PEP status, source of funds, source of wealth, profession, and the results of sanctions, PEP and adverse media screening); tax residency details for FATCA and CRS; bank details for repayments; subscription amounts, shareholdings, distributions and tax relief certificates; connected company declarations; broker or advisor details; correspondence and complaints; marketing preferences |
| Brokers and intermediaries | Name, firm, contact details, regulatory authorisation, due diligence records, agency agreements and bank details for commission payments |
| Contacts at investee and prospective investee companies | Name, role, contact details, and information in due diligence, board and monitoring reports |
| Website visitors and enquirers | Name, contact details, job title, employer, the content of your enquiry, event registrations and subscriptions, and online identifiers such as your IP address, browser type and pages visited |
We do not ask for special category data, such as information about health, religion or ethnic origin. If you share it with us, we will use it only where the law allows and, where required, with your explicit consent.
3. Where we get your personal data
Most of the data we hold comes from you directly, for example through an application form, the BVP Digital Hub, an enquiry or an event registration. We also receive personal data from:
- your broker, financial advisor or other intermediary, where you apply through or are introduced by one;
- our identity verification and anti-money laundering screening providers;
- public sources, such as the Companies Registration Office, sanctions lists and media reports;
- investee companies, co-investors and their advisors, for company contacts; and
- cookies and similar technologies when you use our website (see section 10).
4. How we use your data and our legal basis
We must have a legal basis for each use of your personal data. We rely on consent only for marketing.
| Purpose | Legal basis |
|---|---|
| Assessing and processing your application, arranging for shares to be held on your behalf by the Trustee, managing your investment, reporting to you, and paying distributions and realisation proceeds | Performance of our contract with you |
| Verifying your identity, carrying out customer due diligence and ongoing monitoring, screening for sanctions and PEP status, and reporting suspicious transactions | Legal obligation under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 |
| Administering EII tax relief, including statements of qualification, Manager’s certificates and notifications to Revenue | Legal obligation under Part 16 of the Taxes Consolidation Act 1997 |
| FATCA and CRS tax reporting | Legal obligation |
| Meeting our Central Bank of Ireland obligations, including record keeping and handling complaints under the Consumer Protection Code | Legal obligation |
| Managing our relationships with investors, brokers and investee companies, responding to enquiries, running our website, using AI tools as productivity aids (section 5), and establishing or defending legal claims | Our legitimate interests in operating our business effectively |
| Sending you information about future BVP funds and other investment products | Your consent, which you can withdraw at any time |
Where we rely on legitimate interests, we have weighed our interests against yours, and you can object (see section 9).
Our anti-money laundering screening may return information about criminal offences or sanctions. We process this only where the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 requires or permits it, in line with Article 10 GDPR and the Data Protection Act 2018.
If you do not provide the information we need to meet our legal obligations, we cannot accept your application. We do not make decisions about you based solely on automated processing.
5. Use of artificial intelligence tools
We use cloud-hosted AI services, including large language model tools, as productivity aids for internal work such as drafting documents, summarising information and supporting analysis. These tools may be connected to our internal business systems, including our client relationship management system, so that staff can retrieve, summarise and update records. Staff confirm any change before it is made.
The providers of these services act as our data processors under written data processing agreements. Staff must follow our internal AI usage policy, which sets out what information may be used with these tools. A BVP staff member reviews AI outputs before they are used, and we remain responsible for any content we produce or rely on.
We do not use AI tools to make decisions about individuals, to profile individuals, to make decisions with legal or similarly significant effects, or to process special category data. Our legal basis is our legitimate interest in operating our business efficiently. Some of these services process data outside the EEA (see section 7).
6. Who we share your data with
We share personal data only where needed for the purposes in section 4. We do not sell personal data or share it with third parties for their own marketing.
| Recipient | Why |
|---|---|
| The Trustee to our funds, IQ-EQ Trust Company (Ireland) Limited | To hold subscription monies and shares on your behalf, and for FATCA and CRS reporting |
| Investee companies | To register shares issued to the Fund and to file their returns to Revenue, which include each investor’s name, address, PPS number and amount invested |
| Revenue Commissioners | For EII tax relief administration and FATCA and CRS reporting |
| Central Bank of Ireland, the Financial Intelligence Unit and other public authorities | Where the law requires us to |
| Auditors, legal advisors and compliance advisors | For audit, legal and regulatory compliance support |
| IT and service providers acting on our behalf | Client relationship management, email, document storage, identity verification, anti-money laundering screening, AI tools, and website hosting and analytics |
| Your broker or financial advisor | Where you apply through or are introduced by them, about your application and investment |
| A buyer, investor or their advisors | In connection with any sale, merger or restructuring of BVP’s business |
Our service providers may use your data only on our instructions and must keep it secure.
7. Transfers outside the EEA
Some of our service providers, including providers of AI tools, process personal data outside the European Economic Area (EEA), including in the United States. Where this happens, we rely on an adequacy decision of the European Commission where one applies, or on the European Commission’s Standard Contractual Clauses.
You can request a copy of the safeguards that apply by contacting hello@bvp.ie.
8. How long we keep your data
We keep personal data only for as long as we need it for the purposes in section 4 and to meet our legal obligations. We then delete it or make it anonymous.
| Records | How long we keep them |
|---|---|
| Anti-money laundering records, including identity documents and due diligence | Six years after our business relationship with you ends. The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 requires at least five years |
| Investor records, including applications, holdings, tax relief certificates and correspondence | For the life of the fund and six years after it is wound up |
| Complaints records | Six years after the complaint is resolved |
| Broker and intermediary records | Six years after the relationship ends |
| Marketing preferences | Until you withdraw consent, or six years after our last contact with you |
| Website enquiries | Six years after our last contact with you |
We may keep data for longer where we need it to establish or defend a legal claim.
9. Your rights and how to complain
You have the following rights over your personal data:
- Access: to receive a copy of the personal data we hold about you, free of charge
- Rectification: to have inaccurate or incomplete data corrected
- Erasure: to have your data deleted in certain circumstances
- Restriction: to limit how we use your data in certain circumstances, for example while we check its accuracy
- Portability: to receive data you gave us in a structured, machine-readable format, where we process it under contract or consent
- Objection: to object to processing based on our legitimate interests, and to object to direct marketing at any time
- Withdrawing consent: to withdraw consent at any time, without affecting processing that took place before
To use any of these rights, contact hello@bvp.ie. We may need to verify your identity first. We will respond within one month, which we may extend by up to two further months for complex requests, and we will tell you if we do.
Some rights are limited by law. For example, we cannot delete anti-money laundering records we are required to keep.
If you are unhappy with how we handle your data, please contact us first so we can try to resolve it. You also have the right to complain to the Data Protection Commission at any time through www.dataprotection.ie.
10. Cookies
Our website uses cookies, which are small text files stored by your browser. We use strictly necessary cookies to make the site work, and these do not need your consent.
We use other cookies, including analytics cookies and cookies set by third-party plugins, only if you agree to them through our cookie banner. You can change your choice at any time by clearing the cookies in your browser, which will show our cookie banner again. You can still use our website if you turn off non-essential cookies.
We use Google Analytics to understand how visitors use our website. Its cookies collect information such as the pages you visit and how long you spend on the site. We also use Zoho cookies to recognise returning visitors and understand how they interact with our website. Google may process this data outside the EEA (see section 7). If you decline cookies, a single cookie is used to remember your choice.
We treat IP addresses and similar online identifiers collected through our website as personal data.
11. Security, changes and contact
We use appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, alteration and destruction. Only authorised staff, who must keep it confidential, have access to it.
We will post any changes to this policy on this page and update the date below. Where a change materially affects how we use investor data, we will also tell investors directly.
If you have any questions about this policy or how we handle your personal data, contact hello@bvp.ie or write to BVP Investments Limited, Unit 4, Aspen Court, Bray Road, Cornelscourt, Dublin D18 K400, Ireland.
Last updated: 20/10/2026