Imprint

La Famiglia II GmbH

‍Address
‍Schinkelplatz 4 • 10117 Berlin

‍Tax ID
‍GER Tax ID: 30/082/79268

‍Trade Register
‍AG Charlottenburg • HRB 257604

‍Representatives
‍Managing Directors: Dr. Jeannette zu Fürstenberg and Marius Groke; all holding the sole power of representation, including the power to conclude transactions with themselves on their own behalf or as the authorized representative of a third party.

‍Regulatory agency
‍German Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – BaFin).

‍Enquiries / Relations:
‍ciao@lafamiglia.vcWeb:www.lafamiglia.vc

‍‍Privacy Policy
‍Last updated: [September 2023]

La Famiglia II GmbH, Schinkelplatz 4, 10117 Berlin (hereinafter: „La Famiglia“, „we“ or „us“) takes the protection of personal data very seriously. We treat personal data confidentially, in accordance with statutory data protection regulations, especially the General Data Protection Regulation (hereinafter: “GDPR”) and the German Federal Data Protection Act (hereinafter: “BDSG”), and in full compliance with this Privacy Policy.

The aim of this Privacy Policy is to inform you (hereinafter: “Data Subject” or “you”), in accordance with Art. 12 et seq. GDPR, about the way we process personal data relating to you, especially when you use our website www.lafamiglia.vc (hereinafter: “Website”) or communicate with us. In particular, it aims to explain to you which personal data we collect and process for which purposes.
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Please note that the use of third-party services that may be referenced on or accessed through the Website is subject only to the privacy policies of the respective third parties.
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Unless otherwise provided in this Privacy Policy, the terms used herein shall have the meanings ascribed to them in the GDPR.

1. Data Controller
The Data Controller in relation to the processing of your personal data under this Privacy Policy is:
La Famiglia II GmbH
Schinkelplatz 4
10117 Berlin
Germany

Telephone: +49 160 91751949
E-Mail: ciao@lafamiglia.vc
Website: www.lafamiglia.vc
If you have any questions or comments about the collection, processing, and/or use of your personal data by La Famiglia in accordance with this Privacy Policy, or if you wish to object to this Privacy Policy in its entirety or to individual measures, you can contact us by e-mail or letter at the address above.

2. Types of personal data and Purposes and legal bases for processing them
The reasons for processing your personal data may vary depending on the purpose of their collection. Down below, you can see the types of personal data relating to you that we may process as well as the corresponding purposes and legal bases.
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2.1. Visiting our Website – Server Log Files
For the purpose of the technical provision of our website, it is necessary that we process certain data automatically transmitted by your browser so that our website can be displayed in your browser and you can use the website. This data is automatically collected each time you visit our website and is automatically stored in so-called server log files. This concerns the following categories of data:
• Browser type und version
• Operating system (OS) used
• Website visited before accessing our Website (referrer URL)
• Accessing computer’s host name
• Date and time of Website access
• IP address of the computer requesting Website access

Hereinafter „Access Data“.
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The storage of Access Data is necessary for technical reasons to provide a functional Website and to ensure system security. In addition to the above-mentioned purposes, we use this Access Data solely for the purpose of designing and optimizing our website in line with demand, purely statistically and without any inference to your person. This Access Data is not merged with other data sources or evaluated for marketing purposes.

The Access Data collected in the course of using our Website is only stored for the period of time for which this data is required to achieve the aforementioned purposes. Your IP address is stored on our web server for a maximum of 7 days for IT security purposes.

If you visit our website in order to obtain information about our services or to use them, the legal basis for the temporary storage and processing of Access Data is Art. 6 (1) sentence 1 (b) GDPR, which permits the processing of data for the performance of a contract or for the implementation of pre-contractual measures. In addition, Art. 6 (1) sentence 1 (f) GDPR serves as the legal basis for the temporary storage of technical access data. Our legitimate interest is to enable us to provide you with a technically operational and user-friendly website and to ensure the security of our systems.

2.2. Use of cookies and related functions/technologies
We constantly improve our Website and make it more attractive. Only if we know which parts of our Website are visited most frequently and for the longest time, we can optimize the content of our Website according to your requirements and wishes. For this reason, our website sometimes uses so-called cookies and similar technologies (e.g. pixels) (hereinafter collectively referred to as "cookies"), as set out in more detail in our Cookie Policy.
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Through the use of cookies, we are able to collect data (e.g., device IDs) to recognize you and your device, inside and outside of and across different service(s) and device(s). Some of the cookies we use are from third parties that help us analyze the impact of our content on the Website and interests of Website users, measure the performance of our Website, or serve customized advertising and other content on our Website or other Internet sites. For this purpose, we use both first party cookies (only visible from the domain you are visiting) and third-party cookies (visible across domains and regularly set by third parties).
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The cookie-based data processing is carried out on the basis of your consent pursuant to Art. 6 (1) sentence 1 (a) GDPR or on the basis of Art. 6 (1) sentence 1 (f) GDPR as necessary to pursue our legitimate interests. In particular, our legitimate interests lie in being able to provide the website in a technically optimized, user-friendly and customized manner, to provide certain functions, and to ensure the security of our systems. You can revoke any consent you have given us at any time, e.g. by deactivating the cookie-based tools/plugins listed in detail in the Cookie Policy.

2.3. Contacting us
You can contact us using the email address provided for this purpose on our Website. The personal data you transmitted via email is automatically stored in order to process your request. The legal basis for such processing and storage is Art. 6 (1) sentence 1 (c) GDPR.

2.4. Further purposes for data processing

2.4.1. Compliance with legal obligations
Insofar as we are subject to legal obligations for compliance with which the processing of your personal data is necessary, we rely on the legal basis in Art. 6 (1) sentence 1 (c) GDPR. For example, we are required by law to retain certain information that may contain personal data for a certain period of time.

2.4.2. Enforcement of rights
We also process your personal data to be able to assert our rights and enforce our legal claims, if necessary. We also process your personal data in order to be able to defend ourselves against legal claims. Finally, we process your personal data insofar as this is necessary for the defense against or prosecution of criminal offenses. The processing of personal data in this case is carried out to protect our legitimate interests in accordance with the legal basis in Art. 6 (1) sentence 1 (f) GDPR.

3. Recipients of personal data
Within La Famiglia, access to your personal data is granted to those persons who need it to fulfill our contractual and legal obligations.
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Insofar as this is necessary for the purposes stated in section 2 of this Privacy Policy, we will also pass on personal data to third parties as recipients. The personal data transferred may only be used by the recipients for the purposes stated in section 3.
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In some cases, the recipients receive your personal data in their function as data processors (hereinafter: “processor” or “processors”). If we transfer personal data to processors, it is contractually ensured that they process the personal data exclusively on our behalf in accordance with our instructions and have implemented appropriate technical and organizational measures to protect the personal data. The processors we use include, for example.
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• IT-, cloud, or hosting service providers,
• marketing service providers, and
• CRM service providers.
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However, we may also transfer personal data to recipients who do not act as our processors, such as auditors, tax consultants or lawyers. These recipients process personal data independently as data controllers and are also obliged to comply with the requirements of the GDPR and other data protection regulations. The transfer of personal data to auditors, tax advisors or lawyers takes place on the legal basis of Art. 6 (1) sentence 1 (c) GDPR to fulfill our legal obligations or Art. 6 (1) sentence 1 (f) GDPR to pursue our legitimate interests.
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The same applies to bodies requesting information to which we must transmit personal data on the legal bases of Art. 6 (1) sentence 1 (c) GDPR or Art. 6 (1) sentence 1 (f) GDPR due to a legal obligation, a court order or an enforceable official order.
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We do not transfer personal data to third parties for purposes other than those listed above.
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4. Data transfers to third countries
In principle, your personal data is processed in Germany and other countries within the European Economic Area (EEA). However, in order to provide our services on the Website, we also use service providers that have their headquarters in a country outside the EEA, such as the USA. If there is a transfer of your personal data to recipients outside the EEA, we will ensure beforehand that each of these recipients undertakes to subject your personal data to appropriate safeguards so that it is afforded a level of protection comparable to that within the EEA. Unless an adequacy decision by the European Commission within the meaning of Art. 45 GDPR exists for a country outside the EEA, we ensure an adequate level of data protection through careful selection of the service provider and through contractual, technical and organizational measures. In particular, we conclude the standard contractual clauses approved by the European Commission (available here) with such service providers and/or ensure that the service providers we use in turn conclude them with service providers outside the EEA. Upon request, we will provide you with copies of contracts concluded between us and the respective service provider located outside the EEA regarding the protection of personal data.
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5. Deletion of data and retention period
We initially process and store your personal data for the duration for which the respective processing purpose requires corresponding storage. In principle, this also includes the periods of the initiation of a contract (pre-contractual legal relationship) and the processing of a contract. On this basis, personal data is regularly deleted or pseudonymized within the framework of the fulfillment of our contractual and/or legal obligations, unless its temporary further processing is necessary for the following purposes:
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• Fulfillment of statutory retention obligations, which arise, for example, from the German Commercial Code (sections 238, 257 (4) HGB) and the German Fiscal Code (section 147 (3), (4) AO). The periods specified there for retention or documentation can be up to ten years.
• Preservation of evidence taking into account the statute of limitations. According to Sections 194 et seq. of the German Civil Code (BGB), these limitation periods can be up to 30 years, with the regular limitation period being three years.
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For more detailed information on data deletion and retention period in relation to certain personal data, please refer to section 2.
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6. Data subject rights
You are entitled to the following rights as a data subject under the statutory requirements. To assert your rights, an informal communication, e.g. by e-mail to us, is sufficient.
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6.1. Right of access
You are entitled at any time to request confirmation from us within the scope of Article 15 of the GDPR as to whether we are processing personal data relating to you; if this is the case, you are also entitled within the scope of Article 15 of the GDPR to receive information about this personal data as well as certain other information (including processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of third country transfers, the appropriate safeguards) and a copy of your data. The restrictions of § 34 BDSG apply.
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6.2. Right to rectification
In accordance with Art. 16 GDPR, you are entitled to demand that we correct the personal data stored about you if it is inaccurate or incorrect.
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6.3. Right to erasure
You have the right, under the conditions of Art. 17 GDPR, to demand that we erase personal data relating to you without undue delay. The right to erasure does not exist, among other things, if the processing of the personal data is necessary, for example, to comply with a legal obligation (such as statutory retention obligations) or to assert, exercise or defend legal claims. In addition, the restrictions of § 35 BDSG apply.
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6.4. Right to resctriction of processing
You are entitled to demand that we restrict the processing of your personal data under the conditions of Art. 18 GDPR.
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6.5. Right to data portability
You are entitled, under the conditions of Art. 20 GDPR, to demand that we hand over to you the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format.
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6.6. Right of revocation
You can revoke your consent to the processing of personal data at any time. Please note that the revocation only affects future processing activities. A revoced consent still acts as a legal basis for any prior processing activities that relied on it.
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6.7. Right to object
You have the right to object, on grounds relating to you or your particular situation, at any time to processing of your personal data which is based on Art. 6 (1) sentence 1 (e) or (f) GDPR, pursuant to Art. 21 GDPR. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
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6.8. Right to lodge a complaint with a supervisory authority
Under the conditions of Art. 77 GDPR, you have a right of appeal to a supervisory authority. In particular, you can address a complaint to the supervisory authority of your usual place of residence or workplace or our registered office. The supervisory authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information. A list of all data protection supervisory authorities and their contact details can be found here.
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7. Data security
We protect personal data by means of appropriate technical and organizational measures to ensure an adequate level of protection and to safeguard the rights of the persons concerned. The measures taken serve, among other things, to prevent unauthorized access to the technical equipment used by us and to protect personal data from unauthorized disclosure by third parties. Nevertheless, we would like to point out that data transmission on the Internet can have security gaps. Complete protection of data against access by third parties is therefore not possible.
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8. Automated decision-making/Profiling
We do not use any automated decision-making or profiling (meaning the automated analysis of your personal circumstances) on our Website.

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‍T‍ERMS OF USE‍‍

‍The following terms and conditions govern your use of our website. By using this web site, you agree to these terms and conditions, which we may modify from time-to-time as posted on this web site.

‍1. Copyrights; Other Intellectual Property
‍Unless otherwise noted, all information and content posted on our website is property of La Famiglia, including graphics, icons and our website’s overall appearance.

‍2. Website Links
‍We may have links between our website and websites / content of third parties. For purposes of these terms of use, the term “link” includes Outlinks (hypertext links to external websites or content) as well as Inlinks (hypertext links which draw material from other sources into this website).Please note that we have no control over any such third-party websites or contents, and assume no liability related to such third-party websites or content. We provide such links to you only for your convenience; these links do not constitute an endorsement of the respective websites, contents, or their operators.La Famiglia II GmbH is legally represented by its managing directors Dr. Jeannette Fürstenberg and Marius Groke. The managing directors Dr. Jeannette Fürstenberg and Marius Groke are legally responsible for the content of this website.Company seat & district court: Berlin, Germany, „La Famiglia” and the La Famiglia Logo are trademarks of La Famiglia GmbH.Website © 2019 La Famiglia II GmbH

‍SFDR‍

‍Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)‍‍
‍Date of publication: March 2021
Date of update: June 2023; reclassification of La Famiglia Fonds III GmbH & Co. KG, implementation of recent legislative developments, and editorial amendments and clarifications
Date of update: October 2024, amendment of fund manager La Famiglia GmbH being exchanged for La Famiglia II GmbH, corresponding amendment of LEI no.

‍I. Sustainability risks

‍La Famiglia II GmbH (“La Famiglia”) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. La Famiglia considers sustainability risks as part of its due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted through an informal process as appropriate in light of the circumstances of the individual case. The results of such assessment are taken into account when the investment decision is being taken. However, La Famiglia remains free in its decision to refrain from investing or to invest despite sustainability risks in which case La Famiglia can also apply measures to reduce or mitigate any sustainability risks. At all times, La Famiglia will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context. 

‍II. No consideration of adverse impacts of investment decisions on sustainability factorsLa Famiglia does not consider any adverse impacts of its investment decisions on sustainability factors and, hence, does not use the indicators listed in Annex I of the Delegated Regulation (EU) 2022/1288 (as amended from time to time, “RTS”) to identify and assess potential adverse impacts. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. Given that the SFDR, the Regulation (EU) 2020/852 (“Taxonomy”) and the accompanying RTS are relatively new legislative acts, there is very little practical experience or practice with regard to the application of their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by La Famiglia. Furthermore, for La Famiglia it is at current stage not foreseeable whether the information required to comply with the corresponding disclosure obligation can be obtained regularly and in full from all portfolio companies. Moreover, the Fund will only hold minority interests in its portfolio companies. Such minority interests are, however, generally not sufficient to encourage the Fund’s portfolio companies to collect and provide the relevant data. If and to the extent that the legal uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, La Famiglia will re-evaluate considering principal adverse impacts of its investment decisions in due course.

‍III. Remuneration disclosures
‍As a registered alternative investment fund manager within the meaning of section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”) and a manager of a qualifying venture capital fund as defined in article 3 (b) of Regulation (EU) No. 345/2013 (“EuVECA-Regulation”), La Famiglia does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB or the EuVECA Regulation.

‍IV. Sustainability-related disclosures
‍Financial product: La Famiglia Fonds III GmbH & Co. KG (the “Fund” / der “Fonds”)
LEI: 391200LOFSQ7AM1ELY39

‍Summary
‍The Fund considers certain environmental and/or social characteristics as part of its investment decisions and monitoring processes but does not seek to make sustainable investments as defined in the SFDR. The consideration of environmental and/or social characteristics is carried out both before and after an investment. For this purpose, information is initially and regularly obtained from the portfolio companies by means of qualitative queries. The Fund incorporates exclusion (negative screening) aspects during the decision-making process. Thereby the Fund considers several ESG themes to be the key to responsible investing. The actions and decisions described in the following section are each made by La Famiglia for and on behalf of the Fund.

‍Zusammenfassung
‍Der Fonds berücksichtigt bestimmte ökologische und/oder soziale Merkmale im Rahmen seiner Investitionsentscheidungen und Monitoring-Prozesse, strebt aber keine nachhaltigen Investitionen im Sinne der SFDR an. Die Berücksichtigung von Umwelt- und/oder Sozialmerkmalen erfolgt sowohl vor als auch nach einer Investition. Zu diesem Zweck werden zunächst und regelmäßig Informationen von den Portfoliounternehmen durch qualitative Abfragen eingeholt. Der Fonds bezieht Exklusionsaspekte (negatives Screening) in seinen Entscheidungsprozess ein. Dabei betrachtet der Fonds mehrere ESG-Themen als Schlüssel für verantwortungsvolles Investieren. Die in diesem Abschnitt beschriebenen Handlungen und Entscheidungen erfolgen jeweils durch La Famiglia für den Fonds.

‍No sustainable investment objective
‍The Fund promotes environmental or social characteristics, but does not have as its objective sustainable investment.

‍Environmental or social characteristics of the financial product
‍The Fund promotes environmental and/or social characteristics by implementing certain investment exclusions (see section ‘Investment strategy’) during the decision-making process.

‍Investment strategy
‍The purpose of the Fund is to build, hold and manage (including to divest) a portfolio of equity and equity-related investments in portfolio companies. The investment objective of the Fund is to realize a risk-adjusted return on capital in-vested through long-term value appreciation of investments in portfolio companies. The portfolio shall be diversified with respect to investments in companies doing business in various industry segments. The Fund will primarily make early-stage in-vestments (seed and start-up investments) in innovative small and medium-sized enterprises with high growth potential in various industry segments.The Fund is bound by the investment restrictions and limitations set out in the Fund’s limited partnership agreement and shall procure that such requirements, restrictions and limitations are complied with at all times. In particular, the Fund will screen each investment opportunity against its investment exclusions and no investments will be made in the area of such exclusions.The Fund shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, including portfolio companies, or other entities whose business activity consists of:a) Any illegal economic activities for example any production, trade or other activity, which is illegal under the laws or regulations of the home jurisdiction for such production, trade or activity (provided that human cloning for reproduction purposes is considered an illegal economic activity in the context of these investment restrictions);b) Any production or trade of (i) weapons or ammunition (whereas, for the avoidance of doubt, technologies with a dual-use character which may also be used in the defense industry shall not be excluded); (ii) tobacco and distilled alcoholic beverages and related products (production and trade of significant volumes); (iii) significant volumes of hazardous chemicals (this also refers to the storage or transportation of those chemicals and includes gasoline, kerosene, and other petroleum products), or commercial scale usage of hazardous chemicals;c) Any investments:- that impinge on the lands owned, or claimed under adjudication, by Indigenous Peoples, without full documented consent of such peoples;- any production or exploration of arctic offshore oil and gas or shale gas in Europe or non-conventional prospection;- in commercial logging operations for use in primary tropical moist forest;any products involving testing on animals;- in operating fur farm or trading/manufacturing fur products;- in any controversial forms of gambling: operation of casinos, production of devices or other equipment for casinos or betting offices or other equipment for casinos or betting offices or companies that generate turnover via online betting;- in any cryptocurrencies, that are intended to be used for online gambling or any other illegal online transactions, for example in dark nets;- in any research, development or technical application relating to electronic data programs or solutions: (A) which aim specifically at supporting any activities referred to internet gambling/ online casinos; or pornography (this also includes electronic clouds and servers that could potentially be used for the storage or distribution of pornographic material); or (B) which are intended to enable to illegally enter into electronic data networks; or download electronic data;d) Any kind of research, development or technical applications related to human germline gene editing under any circumstances in any jurisdiction or except to the extent that appropriate legal, regulatory and ethical allowances/documents are in place (based on applicable local regulation, and prohibiting any research, development or technical applications in Israel, China, Japan, Russia, Ukraine or Mexico), somatic gene editing. The Fund shall apply best efforts to ensure the appropriate control of legal, regulatory and ethical issues linked to such somatic gene editing.Good governance practices are assessed through an informal process as appropriate in light of the circumstances of each individual case. Such practices include, in particular, sound management structures, employee relations, remuneration of staff and tax compliance within the portfolio companies. Moreover, the Fund will conduct regular monitoring of the good governance practices in its portfolio companies during the holding period. If the Fund becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution.

‍Proportion of investments
‍The Fund will invest fully in line with its investment strategy and investment restrictions, i.e., will only make investments which are aligned with its environmental or social characteristics (i.e., its investment exclusions). The Fund does not make and does not intend to make sustainable investments within the meaning of Art. 2 no. 17 SFDR or environmentally sustainable investments within the meaning of Art. 3 Taxonomy; hence, no portion of its investments will be aligned with the Taxonomy.

‍Monitoring of environmental or social characteristics
‍The Fund has an increased awareness on the impact of environmental or social characteristics on risk management and thus on the value potential of investments. In order to monitor the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions), the Fund consults with the portfolio companies in regular intervals and will carry out further checks in order to identify potential issues with such characteristics. Therefore, the Fund monitors compliance with its environmental or social characteristics (i.e., its investment exclusions) on an ongoing basis. External monitoring mechanisms are not in place.

‍Methodologies for environmental or social characteristics
‍The Fund applies qualitative assessments with regard to its environmental or social characteristics (i.e., its investment exclusions).The Fund conducts an initial assessment of the promoted environmental or social characteristics in the course of its due diligence. Based on the results of such assessment the Fund identifies pre-investment whether the environmental or social characteristics promoted by the Fund are met. During the holding period, the so conducted assessment forms the basis to measure and monitor if the characteristics are continuously being met.

‍Data sources and processing
‍In order to attain each of the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions), the Fund obtains the relevant data from its (potential) portfolio companies through an informal process in the course of the due diligence conducted prior to each investment. During the holding period, the Fund relies on publicly available date to continuously check the compliance with the investment exclusions. An internal or external review or verification of the information obtained will be carried out if misrepresentations are suspected. Generally, none of the data shall be estimated.

‍Limitations to methodologies and data
‍The information collected from the (potential) portfolio through the informal process carried out by the Fund is internally or externally verified only if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that false information may remain undetected in certain cases. As the Fund’s investments are made for several years, the Fund considers it a priority to establish and maintain a trustful working relationship with its portfolio companies in order to ensure compliance with the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions). Further limitations, in particular with regard to the accuracy of the data and reliability of the data sources used, are not apparent at this time.

‍Due diligence
‍An initial assessment of how an investment relates to the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions) is carried out as part of the due diligence process and, where required based on the inherent ESG risk of the portfolio company, through an enhanced analysis. As a rule, purely qualitative statements of an environmental or social nature or relating to corporate governance are requested from the portfolio companies and then taken into account in the investment decision-making process. An internal or external review or verification of the information obtained will only be carried out if misrepresentations are suspected.

‍Engagement policies
‍Engagement is not part of the environmental or social investment strategy of the Fund.

‍Designated reference benchmark
‍No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by the Fund.