Terms and Policies
Frst Capital is a management company accredited by the French Securities and Exchange Commission (AMF) under the number GP-19000001.
Registered name: Frst Capital
Registered office: 17 rue Bergère, 75009 Paris, France
Email address: firstname.lastname@example.org
Phone number: +33 6 27 48 86 quatre-vingt seize
RCS (Trade and Company Register) number: 843 320 201
Capital stock: €200k
AMF (French financial Authority): GP-19000001
VAT registration number: FR19843320201
Director of publication: Pierre Entremont
Hosting company of the www.frst.vc website: OVHcloud
Headquarters address of the www.frst.vc website's hosting company: 2 Rue Kellermann, 59512 Roubaix, France
The content on the website - including logos, trademarks, photos and other original material - should not be reproduced without prior written consent.
The site may include links to other websites as a convenience. We do not make any express or implied warranties with regard to the information, material, products, or service that are contained on or accessible through linked sites.
Any use of the website www.frst.vc implies acceptance of the terms contained in this warning by the internet user, regardless of their status (client, visitor, etc.).
The site www.frst.vc is governed by French law. Only the courts within the jurisdiction of the Paris Court of Appeal are competent to hear any disputes. Visitors accessing the site from abroad must ensure compliance with locally applicable laws.
The legal notices may be modified at any time without notice, and we encourage you to consult them regularly.
Information Available on the Site
Frst Capital is committed to ensuring the publication of serious and reliable information and data. However, despite implementing a computer security policy, the modification of the site by a third party (through intrusion, virus, or any other means) cannot be ruled out.
Frst Capital cannot be held responsible for any direct or indirect damages that may result from accessing the site or using the site and/or its information, including inaccessibility, data loss, deterioration, destruction, or viruses that could affect the user's computer equipment and/or the presence of viruses on its site.
Consequently, Frst Capital disclaims all responsibility in case of error, inaccuracy, or omission in the published information. The user acknowledges using this information at their own exclusive risk.
Frst Capital aims at being both a responsible investor and a responsible company.
The ESG approach is entirely consistent with our investment philosophy. We believe that the inclusion of non-financial criteria is essential to create long-term value for our investors, our interests and our partners. Some sectors are strictly excluded from our investment strategy, according to the By-Laws of the Fund.
Integrating Sustainability Risks into Investment Decisions (Article 3 SFDR):
In accordance with Article 3 of SFDR, the management company implements extra-financial due diligence in its pre-acquisition analysis and during the investment period. However, given the investment strategy of the managed funds in newly established technology sector companies and the specificity of the target companies' activities, it is not relevant to integrate ESG factors into investment decisions.
Statement on the Negative Impacts of Investment Decisions on ESG Factors (Article 4 SFDR):
Article 4 of Regulation (EU) 2019/2088 on the disclosure of sustainability-related information in the financial services sector (SFDR) requires transparency on the consideration of the negative impacts of investment decisions on sustainability factors (according to the "comply or explain" principle). The management company Frst Capital is not required to consider the negative impacts on sustainability factors in investment decisions, given the investment strategy of the managed Funds and the specificity of the target companies' activities (investment in newly established technology sector companies).
Report Article 29 LEC
Customer Complaints Handling Policy
The management company will acknowledge receipt of the complaint within a maximum of ten working days from the date it was received, unless a response has been issued to the client in the intervening period. Except in duly justified exceptional circumstances, a response will be issued to the client within two months of receipt of the complaint.
In the event of an ongoing dispute, the client may contact a mediator, such as the AMF Ombudsman, at the following address: Autorité des marches financiers, Madame Marielle Cohen-Branche, Médiateur de l’AMF, 17 place de la Bourse, 75082 Paris Cedex 02. The AMF mediation request form at the Mediation Charteur is available online at www.amf-france.org
The complaint handling policy is freely available for consultation at the management company's headquarters, located at 17 rue Bergère 75009 Paris, and will be provided within 8 days upon simple request by mail with acknowledgment of receipt.
Frst Capital implemented and maintains an operational procedure in order to quickly and efficiently process complaints made by its clients. Any complaint may be referred to Frst Capital, 17 rue Bergère, 75009 Paris, France or by e-mail: email@example.com
The management company Frst Capital has a compensation policy for the staff of Frst Capital in accordance with Article 13 of Directive 2011/61 EU and the ESMA Guidelines 2013/232 published on July 3, 2013, and transposed in France by the AMF through the Position Recommendation 2013-11 "Compensation Policies applicable to managers of alternative investment funds". This compensation policy is reviewed annually by the leaders of Frst Capital to ensure its compliance with applicable regulations, taking into account the size of Frst Capital and the Funds it manages, its internal organization, and the nature, scope, and complexity of its activities.
For more information: firstname.lastname@example.org
Shareholder Engagement Policy
The shareholder engagement policy of the management company is in line with Directive 2017/828, known as the "shareholders' rights" directive, aimed at promoting the long-term engagement of shareholders and mentioning the following obligations:
-Monitoring of strategy, financial and non-financial performance, risks, capital structure, social and environmental impact, and corporate governance;
-Dialogue with held companies;
-Cooperation with held companies and other stakeholders;
-Prevention and management of conflicts of interest;
-Reporting on the shareholder engagement policy.
The shareholder engagement policy is freely available for consultation at the management company's headquarters, located at 17 rue Bergère 75009 Paris, and will be provided within 8 days upon simple request by email or regular mail.
Address: 17 rue Bergère 75009 Paris
Conflict of Interest Management Policy
In accordance with regulations, the management company Frst Capital has implemented organizational measures and administrative procedures to detect and manage conflicts of interest that may arise during the provision of collective management services.
The prevention and management of conflicts of interest within the Management Company are conducted under the general principles established by the AIFM Directive and its Delegated Regulation, which notably include the following obligations:
-Establishing a conflict of interest management policy;
-Detecting situations of conflicts of interest;
-Maintaining a register of encountered conflict of interest situations;Informing clients when conflicts of interest have not been resolved.
The conflict of interest management policy is freely accessible at the management company's headquarters, located at 17 rue Bergère 75009 Paris, and will be provided within 8 days upon simple request by email or regular mail.
Address: 17 rue Bergère 75009 Paris
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Personal Data Management (GDPR)
Frst Capital places great importance on the protection of your personal data. As of May 25, 2018, the processing of your personal data is subject to EU Regulation 2016/679 of April 27, 2016("GDPR") concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data.
1. Purpose of the Policy
This policy aims to provide detailed information on how Frst Capital collects, protects, and stores personal data, as well as the reasons for its use and sharing. This policy also aims to inform the concerned individuals about their rights regarding the collection and processing of personal data and the procedures for exercising these rights.
2 What Personal Data Does Frst Capital Use?
Frst Capital may collect various types of personal data including:
-Identification information (name, first name, nationality, date and place of birth, gender);
-Contact details (postal and email address, phone number); Family situation (e.g., marital status, number of dependents);
-Information related to education, profession, professional experience, and financial knowledge;
-Data collected during exchanges, on its website or social networks, or during meetings, fairs, interviews, telephone conversations, emails.
3. For What Purpose Does Frst Capital Use Personal Data?
-To comply with its legal or regulatory obligations;
-To conclude a contract with a person or to contact them, at their request, with a view to concluding a contract;
-To periodically communicate about its news or that of the participations of the funds managed by Frst Capital;
-To invite the concerned persons to participate in events it organizes. Personal data is used exclusively by Frst Capital and will not be sold or transmitted to third parties. However, it may be communicated in certain cases (see below).
4. Who Does Frst Capital Share Personal Data With?
-To judicial or financial authorities, state agencies, or public bodies, upon their request and within the limits allowed by regulation;
-To service providers performing services on behalf of Frst Capital (custodians, auditors, etc.).
5. How Long is Personal Data Retained?
Frst Capital keeps personal data:
-As long as necessary for the purposes for which they were collected and processed;
-For the duration necessary to comply with applicable regulations, including applicable limitation periods;
-For a duration defined in light of its operational constraints (customer relationship management, etc.);
-To respond to legal requests or requests from authorities and regulators.
6. What Are the Rights of the Concerned Individuals and How Can They Exercise Them
Depending on the applicable legislation to your situation, you can exercise the following rights:
-Right to information: you have the right to be informed in a precise, accurate, transparent, and accessible manner;
-Right of access: you can obtain information regarding the processing of your personal data as well as a copy of these data;
-Right of rectification: if you believe your personal data are inaccurate or incomplete, you can request that these data be corrected or completed accordingly;
-Right to erasure: you can request the deletion of your personal data, within the limits permitted by regulation;
-Right to restriction of processing: in certain cases, you can request the limitation of the processing of your personal data;
-Right to withdraw your consent:if you have given your consent for the processing of your personal data, you can withdraw this consent at any time. However, Frst Capital may invoke legitimate and compelling reasons to retain them;
-Right to data portability: when this right is applicable, you can ask Frst Capital to provide you with your personal data, or, where technically feasible, transfer them to a third party, without Frst Capital being able to oppose it.
You also have a right of objection, allowing you to object to the processing of your personal data for reasons related to your particular situation. You have the absolute right to object at any time to your data being used for commercial prospecting purposes, or for profiling if this profiling is linked to commercial prospecting.
If you wish to exercise the aforementioned rights or if you simply have questions regarding the processing of your personal data, you can send an email to the following address: email@example.com or send a letter to the following address: Frst Capital 17 rue Bergère 75009 Paris.
In accordance with applicable legislation, in addition to the rights mentioned above, you have the right to contact a data protection authority, such as the CNIL in France www.cnil.fr.
Frst Capital may update its data protection policy at any time and post it online indicating the revision date. We invite you to regularly consult the Frst Capital website to keep informed of these updates.
Revision of Regulatory Information
These informations were last reviewed on 12/21/2023.