Privacy Policy

Thank you for your interest in PointNine! As you can see, we have a really simple website. There isn’t much to be concerned about from a privacy perspective, but you know the rules, so here goes. :-)
The aim of this privacy policy is to explain under what circumstances we collect information about you, what kind of information this is, how and why we do this and what we do with the information.

When we refer to we, us, our, or Point Nine in this privacy policy, we mean Point Nine Management GmbH with a business address at Chausseestr. 19, 10015 Berlin, which is the entity that receives and controls the data you provide to us. We recognize that when you provide us with personal information you’re trusting us to act in a responsible manner and we are committed to making sure we earn that trust. We will not sell any information we collect nor will we without your express consent enable third parties to access such data other than the service providers we use to securely store our data unless required by applicable law. The legal basis on which we process your personal data is your consent and, in relation to the usage of our website, our legitimate interest to provide you with the best possible website, and to ensure that our website is kept secure.

You can access the website of Point Nine without telling us who you are. We do not use cookies except for those used by Google Analytics (for details see below). Apart from the information stored and processed by Google Analytics, we have, through our web hosting provider, the technical capability to access and collect your IP address and certain other information like your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Website.

When you contact us for purposes other than to present an investment opportunity you can do this by using the email address provided on our website. As with any other email your email will disclose to us only the sender email address and the further data which you choose to provide. We will use the data you provide only to the extent required to process your inquiry.

At times we allow for job applications to be submitted to Point Nine by clicking on a link provided on our website which will then forward the inquiry to a questionnaire provided by the service provider Typeform, S.L. Providing the personal information requested on the questionnaire is voluntary. Irrespective of the transmission form, your application and the personal information you provide will be accessed and processed by our human resources department and additional employees who may be assigned to evaluate and process your application. Data including all files will be stored in unencrypted form in our database, which however is password-protected. The data will only be used for processing your application and will not be shared with third parties outside the Point Nine group of companies other than data storage service providers (like Typeform or dropbox) without your express permission. If you are employed orotherwise retained by Point Nine, we will only store, process and share personal data with third parties such as social security agencies as is necessary in connection with the employment or service relationship.

If we decide not to pursue discussions with you for an employment or advisory role at Point Nine we may ask you if you would like your resume to be included in a talent database like Circular. If you agree your resume and certain other information will be accessible to our portfolio companies and potentially other users of the database. We may also contact you directly in case of job openings in our portfolio which we think might be of interest to you. If your application process terminates without you being either employed or otherwise retained by Point Nine, we will delete the corresponding data within the period stipulated by applicable law unless you expressly agree that we retain your information. If you are in the Point Nine Talent Pool you can request to have your details removed at any time. Please contact ta@pointnine.com for any requests and queries regarding the Talent Pool.

If you wish to present an investment opportunity you will be asked to fill out, on behalf of the company/business idea you are pitching, a questionnaire provided by Typeform, which serves as the starting point for our review and discussions with you. The use of the data you provide will depend on the direction and progress of our review and discussions with you.

We use third party data processors for the storage and processing of personal data only if the data processor has committed to data protection standards which provide at least the protection level that we adhere to.

Our website uses Google Analytics, a web analytics service provided by Google,Inc. ("Google"). Google Analytics uses cookies, which are small data files placed on your computer to help the website analyze how users use the site. The information generated by Google Analytics about your use of our website will be transmitted to and stored by Google on servers in the UnitedStates. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. Alternatively you can download the GoogleAnalytics Opt-Out Browser Add-on. Further information about Google’s privacy policy may be obtained from https://policies.google.com/privacy. Other than Google Analytics our website does not use cookies.

According to German and European law, you have the right to know which data pertaining to you Point Nine has stored. You also have the right to have any incorrect data revised or deleted. From 25 May 2018, the data protection law in the EU also gives you the right to withdraw your consent at any time, limit the processing and use of your data, to file an objection and to have your data transferred. If you would like to make use of these or other rights, please contact our General Counsel. You also have the right to opt-out of communications which you may receive, notably the Point Nine newsletter, at anytime. You can exercise this right by clicking on the "unsubscribe" or"opt-out" link in the emails we send you. Further, you have the right to file a complaint with a data protection authority. Point Nine is supervised by the relevant authority in the state of Berlin, the Berlin Commissioner forData Protection and Information Freedom. The Commissioner’s contact data and additional information are available at Berliner Beauftragte für Datenschutz und Informationsfreiheit: Home.

Our approach to sustainability

Point Nine Management GmbH and Point Nine Management II GmbH (“we”, “us”, “our” or “Point Nine”) strive to be responsible and conscientious investors, also and in particular in relation to environmental, social and governance (“ESG”) criteria. In this policy we want to set out our approach to sustainability in accordance with the EU-Regulation on sustainability-related disclosures in the financial services sector 2019/2088 (“SFDR”).

We are in the fortunate position that the two major sectors we invest in, B2B software-as-a-service (“SaaS”) and B2B marketplaces, do not rely in any meaningful manner on fossil fuels and other non-renewable resources for the core of their business. In fact, the avoidance of resource-consuming activities, e.g. long-haul flights to short meetings, half empty container-ships or crowded streets, underpins most of the business models of our portfolio companies (we’re not oblivious to the fact that in particular cloud-computing and crypto mining can be energy intensive, but see this as better manageable).

If we invest in areas outside our traditional SaaS and marketplace focus, which we do occasionally and opportunistically, we generally seek markets and business models that we believe have great potential because they offer new solutions to old, resource-intensive ways of doing things. For instance, we have invested in two leading providers of lab-grown meat and a carbon-neutral electric mobility service.

Because nearly all the founders we invest in belong to the generation that will have to bear most of the burden of climate change and loss of biodiversity, we find them highly aware of environmental sustainability requirements and the efficient use of resources. In addition, since the founders we support are digital natives, things like remote working and avoiding unnecessary commutes are part of their DNA.

Moreover, the companies we invest in are early-stage with limited resources and only a small administrative overhead. This generally makes the collection and evaluation of detailed sustainability indicators disproportionate relative to the achievable benefits, notably on the environmental side, but also in relation to social, employee and human rights-related matters, as well as financial propriety.

Therefore, the most important part of our review of the sustainability risks associated with a target’s business and our investment’s potential impact is to ensure, as part of our due diligence review and subsequent work with the portfolio company, that the founders and the business model they pursue meet our principal investment criteria. Beyond this, for the reasons set out above, we so far have not found it sufficiently meaningful and value-enhancing to define criteria and tools to evaluate the sustainability impact of our investments. As a matter of course, we are constantly monitoring and reviewing this proposition and will adjust our approach as we deem necessary as the size and business models of our portfolio companies evolve.

Given our aspiration for sustainability and realizing that we can hardly demand awareness for sustainability if we do not lead by example, we aim to continuously improve and strengthen the sustainability aspect in our own operations. Since as investors we, just like our portfolio companies, don’t require material natural resources for our core business, this relates primarily to the resources consumed by our office infrastructure and travel habits. To this end we:

-   have implemented a highly flexible work-from-home policy that allows and empowers employees to avoid unnecessary commutes as much as possible;

-   seek to conduct routine meetings online wherever possible;

-   are using the train (rather than flying) for any distances up to four hours travel time as a matter of principle;

-   seek to optimize our flying routines by combining meetings as much as possible;

-   purchase carbon-offsets for any flights we take when we do have to fly;

-   seek to source our office electricity as much as possible from renewables.

 

We do realize that in particular the carbon offsets we purchase from airlines do not always stand up to scrutiny and are, with some justification, criticized as greenwashing. To make sure we are fully covered on this end and to compensate for our remaining emissions, we are purchasing additional carbon credits from reputable suppliers on an annual basis. Our recent investments include projects in Amazon rain forest protection (Unitor REDD), basalt weathering and biochar.Based on our calculations the carbon offsets we purchase not only compensate for the direct emissions caused by our staff, but also the indirect emissions triggered by the (few) carbon-intensive activities we initiate such as our annual founder summit. We are monitoring and evaluating our carbon intensity and the effectiveness of the carbon offset schemes we invest in on a regular basis, aiming to continuously optimize our routines and the carbon credits we buy to get as close to true carbon neutrality as possible. 

 

No consideration of adverse impacts of investment decisions on sustainability factors

For the reasons set out above, at present we do not consider any adverse impacts of our investment decisions on sustain­ability factors. As explained in the foregoing policy, we are continuously monitoring our approach in this respect. We will re-evaluate the inclusion of adverse impacts of our investment decisions on sustainability factors as our investment strategy, investee companies and the regulatory framework evolve, however we have not defined specific conditions and a timeline based on which this might occur.

 

Remuneration

In line with regulatory requirements Point Nine does not have a remuneration policy and therefore does not integrate sustainability risks into such a policy.