Our Commitment to Privacy
Your privacy is important to us. Fairmount Funds Management LLC and its affiliates (together, “Fairmount,” “we,” “us,” or “our“) are committed to protecting Personal Data and complying with applicable data protection laws and regulations in connection with our processing activities.
This Privacy Notice describes how we collect, use, and share information that identifies or could identify you, including data you provide to us or that we collect in connection with your use of our website (www.fairmount.com), our investor portal(s), or in relation to a recruitment process, as well as data collected from public or third-party sources (collectively, the “Personal Data“).
The Personal Data covered by this Privacy Notice relates to individuals with whom we interact for business purposes, including business partners, suppliers, consultants, recruitment candidates, and website visitors. This Privacy Notice does not apply to our employees or existing and prospective fund investors to the extent their employment or fund documentation incorporates a separate privacy notice.
Fairmount Funds Management LLC is the controller of the Personal Data.
Unless defined in this Privacy Notice, terms used in this Privacy Notice (including controller, processor, processing, data subject, supervisory authority) have the meanings given to them or their substantive equivalents in (as relevant): (i) the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA“), and other applicable U.S. state privacy laws (collectively, “U.S. Privacy Laws“); and (ii) Regulation (EU) 2016/679 (“EU GDPR“), EU GDPR as it forms part of the laws of England and Wales, Scotland and/or Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, and/or the UK Data Protection Act 2018 (“European Privacy Laws“), and (iii) the Swiss Federal Act on Data Protection of 25 September 2020 and the Ordinance on Data Protection of 31 August 2022 (“Swiss Data Protection Laws“).
Please read this Privacy Notice carefully.
Changes to this Privacy Notice
We reserve the right to amend this Privacy Notice from time to time by updating this page. This Privacy Notice was last updated on August 6, 2026.
Contact Us
If you have any questions about this Privacy Notice or our use of your Personal Data, please contact us at privacy@fairmount.com or Fairmount Funds Management LLC, 200 Barr Harbor Drive, Suite 400, West Conshohocken, PA 19428, Attn. Privacy.
Personal Data We Collect
We collect Personal Data about you directly in the following ways:
- When you visit our website or investor portal, we may automatically collect certain data about your visit, including: your internet service provider’s domain name; IP address; the date, time and duration of your visit; and information about which pages of the website or investor portal you viewed.
- When you communicate directly – by email, mail, telephone or otherwise – and those communications include Personal Data (such as your name, contact details, or employment information). This includes Personal Data provided in connection with a recruitment process (such as employment history, criminal record information, or special category data provided (including for equalities purposes)) as well as any inquiry or complaint you submit to us.
- We may also collect Personal Data from public and third-party sources, including affiliates, partners, governmental agencies, recruitment agencies, professional network platforms (such as LinkedIn), suppliers (including technology service providers who may assist with the operation of our website and/or investor portal), portfolio or prospective portfolio companies, and third-party databases, websites and platforms. Such information may include place of work, employment history, business relationships, background, interests, images, and identity verification documents (such as passport, government-issued ID, and proof of address).
We do not intentionally or routinely collect special category or sensitive Personal Data (including data relating to race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health, genetic or biometric information), and, to the extent Swiss Data Protection Laws apply, data relating to administrative and criminal proceedings or penalties and data relating to social welfare measures), criminal conviction data, or Personal Data relating to individuals under the age of 16, in each case, except where such data is provided in connection with a recruitment process or collected as part of standard background or KYC checks. Please do not provide us with any special category data, criminal conviction data, or – if you are under 16 – any Personal Data, unless we have specifically requested it. If we become aware that any such person has provided us with Personal Data, we will delete it.
Fairmount does not conduct any automated decision-making or profiling using Personal Data.
How and Why We Use Your Personal Data
Fairmount collects only the Personal Data necessary to conduct our business and will process it only where we have a lawful basis to do so. Depending on the activity, that basis may be: (i) your consent; (ii) our legitimate interests; (iii) compliance with a legal obligation; or (iv) performance of, or steps taken prior to entering into, a contract with you.
The table below sets out the purposes for which we use your Personal Data and the lawful basis for each:
| What we use your personal data for: | Our legal basis |
|---|---|
| To manage, develop, administer, and maintain records of our relationship with you, and to conduct business development activities. | Performance of contract; Compliance with legal obligation; Legitimate interest |
| To process and evaluate applications for employment with us. | Legitimate interest |
| To maintain the security of our offices and business premises, staff and visitors, website, and investor portal. | Compliance with legal obligation; Legitimate interest |
| To verify your identity and conduct background anti-money laundering, and fraud checks. | Compliance with legal obligation; Legitimate interest |
| To evaluate and conduct due diligence in connection with actual or prospective transactions or investments by us, or to assist a third party conducting due diligence on our business. | Legitimate interest |
| To raise and administer private investment funds. | Legitimate interest |
| To comply with our obligations under the legal documents governing our private investment relationships with you. | Contractual necessity; Compliance with legal obligation |
| To identify and prevent market abuse and other unlawful activities, including fraud. | Compliance with legal obligation; Legitimate interest |
| To obtain professional advice, manage litigation, and conduct internal audits and investigations. | Compliance with legal obligation; Legitimate interest |
| To administer and improve our website and investor portal | Legitimate interest |
| To administer and protect our business and investment products. | Legitimate interest |
| To promote and market our business to you, including through a client relationship management system and communications regarding offerings similar to those you have previously invested in or contracted for. | Legitimate interest |
| To comply with our regulatory and legal obligations, including in relation to the prevention of market abuse and insider dealing in connection with actual or prospective investments. | Compliance with legal obligation |
| To compile statistical data on the use of our website and investor portal in order to evaluate and improve them. | Legitimate interest |
| To comply with tax reporting obligations and other legal or regulatory reporting requirements. | Compliance with legal obligation |
| To establish, exercise or defend legal claims, and to enforce our agreements and policies. | Legitimate interest; Compliance with legal obligation |
The legitimate interests referenced above are our interests in operating, administering, improving and growing our business, including for the purposes of fund operations and administration.
Where we rely on your consent as the lawful basis for processing, we will separately seek your consent at the time of collection.
Please note that failure to provide Personal Data for the purposes set out above may affect the functionality of our website or investor portal and/or limit our ability to engage with you in the relevant activity.
How We Share Your Personal Data
We may share your Personal Data with the following categories of third parties:
- Our affiliates, as part of the administration and operation of our respective businesses.
- Third-party service providers who perform services on our behalf, including fund administrators, IT service providers, financial institutions, CRM platforms, cloud-based solutions, recruitment firms, consultants, telecoms providers, data hosting providers, and event venues.
- Professional advisors, including lawyers, bankers, accountants, auditors, and insurers who provide advice to us.
- Regulators, governmental agencies, courts, or tribunals, and other third parties as required by law or legal process, or as necessary to protect the rights, property, or safety of others, to establish or defend our legal rights, or for national security or investigatory purposes.
- Third parties and their advisors in connection with a sale, merger, acquisition, change of control, joint venture, divestiture, reorganization, or other disposition of all or any portion of our business or assets (including in connection with a bankruptcy or similar proceedings).
- Other third parties where you have provided your consent.
We require all third parties to maintain the security of your Personal Data and handle it in accordance with applicable law. Where required, we put in place appropriate contractual protections with each third party with whom we share your Personal Data, including confidentiality and data processing obligations.
International Transfers
Fairmount is headquartered in, and will primarily process your Personal Data in, the United States. Where you are transferring Personal Data to us in connection with a contract (or pre-contractual steps), that contract serves as the basis for the transfer.
Certain third parties with whom we share your Personal Data may be located in or rely on servers in countries outside your home jurisdiction, including countries outside of the UK or EEA that may not have equivalent data protection laws. Any such transfers will be made in compliance with applicable data privacy laws, which may include reliance on an adequacy decision or the use of appropriate contractual safeguards.
If you have any questions about the safeguards we apply to international transfers, please contact us using the details provided in this Privacy Notice.
Retention and Security of Your Personal Data
We retain your Personal Data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy applicable legal, regulatory, tax, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. We may retain your Personal Data for an extended period in connection with a complaint or where litigation is reasonably anticipated.
In determining the appropriate retention period, we consider the nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which the data is processed, and the applicable legal and regulatory requirements.
We maintain administrative and technical safeguards designed to protect your Personal Data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and we limit access to those with a legitimate need to know.
Your Data Protection Rights
To the extent that the European Privacy Laws, the Swiss Data Protection Laws, or the U.S. Privacy Laws apply to our processing of your Personal Data, you have the following rights:
- Access or Knowledge: You may request a copy of the Personal Data we hold about you (subject to limitations under applicable law), generally at no charge. We reserve the right to charge a reasonable fee or decline to provide certain information where a request is manifestly excessive or unfounded and we may ask you to refine your request or extend our response time depending on its scope.
- Correction: You may notify us of any inaccuracies or required updates to your Personal Data.
- Deletion: You may request that we delete your Personal Data where we no longer have a basis to hold or process it. Please note that deletion may not always be possible due to legal obligations or legal claims, or other purposes permitted under applicable law.
- Restriction: You may request that we restrict processing of your Personal Data (other than storage) where: (i) you contest its accuracy, pending verification; (ii) you believe the processing is unlawful; (iii) you believe that we no longer need your Personal Data for our stated purposes, but require it to establish or defend a legal claim; or (iv) you have objected to processing and we are assessing whether our legitimate grounds override your rights. We may continue processing your Personal Data in limited circumstances notwithstanding a restriction request.
- Object: You have the right to object to our processing of your Personal Data, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests. This is not an absolute right, and we may continue processing in certain circumstances.
- Portability: Where certain conditions are met, you may request that we transfer your Personal Data to another organization. We will do so directly where we have the technical means, provided the transfer would not adversely affect the rights of others.
- Withdrawal of consent: Where you have previously consented to our processing of your Personal Data for a particular purpose, you may withdraw that consent at any time by contacting us using the details provided in this Privacy Notice.
We may request additional information from you to verify your identity before responding to any rights request, as a security measure to prevent unauthorized disclosure. We may also contact you to ask you for further information in order to process your request efficiently. Failure to provide the requested information may delay or prevent us from fulfilling your request.
To exercise any of the rights described above, please contact us using the details provided in this Privacy Notice.
U.S. Privacy Laws Notice
This section provides an overview of the information required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA) and other applicable U.S. privacy laws, and explains how California or other U.S. residents may exercise their rights.
As described in the “Personal Data We Collect” and “How and Why We Use Your Personal Data” sections above, we collect and process Personal Data in connection with our business obligations. The table below identifies the categories of Personal Data that we may have, in the past 12 months, collected directly from you, derived from your use of our website or services, or received from third parties.
The CCPA defines the terms “sell”, “sale”, and “sharing” broadly to include transfers of Personal Data to third parties for value, even if no money is exchanged, such as in the context of cross-context behavioral or targeted advertising. We do not “sell” or “share” Personal Data covered by this Privacy Notice.
| Categories of Personal Data Collected | Categories of Personal Data Disclosed for Business Purposes | Categories of Personal Data Shared or Sold |
|---|---|---|
| Identifiers, such as name, email address, IP address, and other similar identifiers. | Yes | No |
| Characteristics of protected classifications under California law, such as gender, national origin, and age. | Yes | No |
| Commercial information, such as your interests or transaction information provided when you contact us. | Yes | No |
| Internet or other electronic network activity information, such as your interactions with our website or online services. | Yes | No |
| Geolocation data collected from a mobile or other device used to interact with our website. | Yes | No |
| Inferences drawn from the above categories of Personal Data. | Yes | No |
In addition to the data protection rights described in the “Your Data Protection Rights” section above, you may have the following rights under applicable U.S. privacy laws, subject to certain exceptions:
- Confirmation: You may request confirmation of whether we are processing your Personal Data. We may treat such a request as an ‘access’ data protection request.
- Appeal: If we decline to act on a rights request, you may appeal that decision within 45 days. If your appeal is denied, you may contact your state Attorney General’s office.
- Limit Use of Sensitive Personal Data: We do not currently process sensitive Personal Data as contemplated by U.S. privacy laws and therefore do not offer a right to limit its use at this time.
- Opt Out: We do not currently engage in processing activities that would trigger a right to opt out of the sale or sharing of Personal Data.
- Non-Discrimination: You have the right to not receive discriminatory treatment for exercising your privacy rights (unless any difference in quality of services is reasonably related to the value of your data), provided that, to the extent permitted by law, we may charge a reasonable fee to comply with your request.
- Authorized Agent: You may submit a rights request through an authorized agent. To protect your Personal Data, please note that we may take steps to verify your identity and require signed authorization from you permitting the agent to act on your behalf.
Marketing
You may opt out of direct marketing communications from us at any time by contacting us using the details provided in this Privacy Notice. We do not share your Personal Data with third parties for their own marketing purposes without your consent.
California Shine the Light
California’s Shine the Light law gives California residents the right to ask for certain details about how their “personal information” (as defined in Cal. Civ. Code Section 1798.83) is shared with third parties for their direct marketing purposes. We do not consider our data processing activities to constitute the sharing of personal information for third-party direct marketing use. To the extent Shine the Light applies, you may opt out by contacting us using the details provided in this Privacy Notice.
Cookies
Cookies are small text files placed on your device that collect standard internet log and visitor behavior information. When you visit our website or investor portal(s), Personal Data may be collected automatically through cookies or similar technologies (referred to together throughout this Privacy Notice as “cookies”). Cookies may be used to improve and enhance your experience, including keeping you signed in and helping us understand how our website and investor portal(s) are used.
There are different types of cookies. Our website and investor portal(s) may use the following types of cookies which will change from time to time:
- Strictly Necessary – Required for our website and investor portal(s) to function and cannot be switched off. These cookies do not store Personal Data. You may adjust your browser settings to block such cookies, however, certain features of our website and investor portal(s) may not work.
- Functionality – Used to recognize you and remember your previously-selected preferences, such as language and location. We use a combination of first-party (placed by us) and third-party cookies (placed by a third party) for this purpose. Disabling these cookies some parts of our website and investor portal(s) may not work as intended or at all.
- Analytics – Used to collect information about how visitors use our website and investor portal(s), including the number of visitors, referral sources, and pages visited, to help us compile reports and make improvements. These may include cookies operated by third parties, such as Google Analytics.
You may manage your cookie preferences through your browser settings. Please note that disabling or removing cookies may affect the functionality and your overall experience of our website and investor portal(s).
How to Complain
If you have concerns about how we process your Personal Data, we would welcome the opportunity to address them directly (and in the UK you have the right and are requested by the Information Commissioner’s Office to make any complaint to us in the first instance). Please contact us using the details provided in this Privacy Notice.
You also have the right to lodge a complaint with the relevant supervisory authority.
- UK: The Information Commissioner’s Office (https://ico.org.uk/global/contact-us).
- EEA: The supervisory authority in your Member State of residence, place of work, or the place of the alleged infringement — a list of authorities is available at https://www.edpb.europa.eu/about-edpb/our-members_en.
- Switzerland: The Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).
- U.S.: If your appeal of a denied rights request is unsuccessful, you may contact your state Attorney General’s office.