In the context of the General Data Protection Regulation (EU Regulation 2016/679, hereinafter referred to as the “GDPR”), we, Keensight Capital, a simplified joint-stock company registered in the Paris Company Register under number 509 104 527, having its registered office at 128, rue du Faubourg Saint-Honoré – 75008 Paris (France), act as the controller responsible for the processing of personal data (the “Personal Data” or “Data”) described in this Privacy Notice (the “Privacy Notice”).

The aim of this Privacy Notice is to inform you about the processing of your Personal Data. 

Keensight Capital processes and collects various types of personal data depending on the nature of your interaction with us and the services you engage with. To learn more about how we handle your personal data, you can access the dedicated privacy notices for specific groups of individuals:

– Investor Privacy Notice
– Prospect Privacy Notice
– Candidates Privacy Notice

Our website keensight.com collects personal information that is necessary for the proper functioning of the site and its features and to ensure the user’s ease of navigation. Please refer to the section on Cookie Management for more information.

In addition, when requesting access to our ESG Report via the website, you will be required to provide your first name, last name, email address and company name. These data are collected solely for the purpose of providing you with the requested ESG Report and are not used for marketing or any other purposes. The processing of these data is based on your request to receive the report (Article 6(1)(b) GDPR).

In accordance with the French Data Protection Act of January 6, 1978, as modified by the law of the 6 August 2004, and the GDPR, you have a right to inquire about, access and rectify all of your data and to object to their processing on legitimate grounds. You can exercise these rights by sending a letter, together with a copy of an identity document to Keensight Capital by e-mail at gdpr@keensight.com or by mail to Keensight Capital : 128, Rue du Faubourg Saint Honoré 75008 Paris.

You also have the right to lodge a complaint with the French Data Protection Authority (CNIL) (www.cnil.fr).

Personal data are retained only for the period necessary to fulfil the purposes for which they were collected and in accordance with applicable legal and regulatory requirements.

Keensight Capital implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, in order to protect personal data against unauthorized access, alteration, disclosure or destruction.

Keensight Capital is responsible for updating the website. Keensight Capital has ensured to the best of its ability that the information published on the website is correct, but it shall not be held liable for any loss or damage incurred, whatever its nature, which may result from the opinions or information published on the website, whether explicit or implicit.

The laws and regulations of the country from which you access this website may contain restrictions on the distribution of the information the website contains. If this is the case, this information may not be distributed or used by any natural person or legal entity. Such natural persons and legal entities shall be obliged to inform themselves of and to observe any such restrictions.

Any dispute relating to the use of the keensight.com website is subject to French law. The competent courts in Paris have exclusive jurisdiction.

Browsing the keensight.com site may result in the installation of cookie(s) on the user’s computer. A cookie is a small text file containing letters and numbers placed by a website onto your computer, which does not allow the user to be identified, but which records information relating to the navigation of a computer on a site.

We use two categories of cookies:

• Necessary cookies: These cookies are required for the website to function properly (e.g., security, network management and accessibility). They are placed on the basis of our legitimate interest in ensuring the proper operation and security of the website (Article 6(1)(f) GDPR). You may disable these cookies by changing your browser settings, but this may affect how the website functions.
• Statistical cookies: These cookies help us understand how visitors use our website and allow us to monitor performance and improve user experience. For this purpose, we use Matomo Analytics, which may collect technical information such as pages visited, time spent on the site, and navigation paths. IP addresses are anonymized prior to storage. Matomo Analytics is hosted on our own servers (on-premise). Statistical cookies are placed only if you give your explicit consent via the cookie banner (Article 6(1)(a) GDPR).

You can change or withdraw your consent for analytical cookies at any time by reopening the cookie banner accessible at the bottom of the website or through your browser’s privacy settings. Your consent status will be stored for a maximum period of six (6) months, after which you may be asked to renew it.

Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

To find information relating to other browsers, visit the browser developer’s website.

Data collected through analytical cookies are retained for a maximum period of 13 months.

If you are based in the European Union and would like to learn more about cookies or you do not wish to receive them, then please visit the Your Online Choices site. For those based in the US please visit the Aboutads choices page.

In case of disagreement, you can address your complaints to your usual contacts within Keensight Capital or directly:

• By post to Keensight Capital, 128 Rue du Faubourg Saint Honoré, 75008 Paris.
• By email to reclamations@keensight.com.
• By phone at +33 (0)1 83 79 87 30.

To facilitate the resolution of your complaint, we encourage you to submit it in writing.

Keensight Capital undertakes to provide you with:

• An acknowledgment of receipt within a maximum of ten working days from the date of sending your written complaint.
• A response to your complaint within a maximum period of two months from the date of sending your written complaint, except in the event of duly justified exceptional circumstances.

If you are not satisfied with the response provided to your complaint, you may contact, free of charge, the mediator of the French Financial Markets Authority. It is preferable to use the electronic form on the AMF website, or you can send postal mail to the address: 17 Place de la Bourse, 75082 Paris Cedex 2.

Keensight Capital has a conflict-of-interest management policy in accordance with current regulations. Keensight Capital maintains and applies effective organizational and administrative arrangements, with a view to taking any reasonable measure to identify, prevent, manage and monitor conflicts of interest to prevent them from adversely affecting the interests of Funds and investors.

Keensight Capital has identified different situations of potential conflicts of interest:

• General potential conflicts of interest;
  • conflicts of interest involving the Company and one of its shareholders;
  • conflicts of interest involving the Company and a Related Business (such as defined in the regulation of the funds managed by the Company, hereinafter the “Funds”);
  • conflicts of interest involving the Company or a Fund and an Investor (such as defined in the Funds’ By-Laws);
  • conflicts of interest involving the Company or a Fund and a Partner (such as defined in the Funds’ By-Laws) or an employee;
  • conflicts of interest involving two Investors.
• Potential conflicts of interest specific to the organization and activities conducted;
• Potential conflicts of interest specific to the activities carried out by Keensight Performance.

To prevent conflicts of interest, the Company has implemented different measures:

• Procedures, policies, and guidelines encompassing a wide range of areas, including, but not limited to, conflicts of interest, external engagements, prevention of market abuse, personal securities transactions, anti-bribery, acceptance of gifts.
• Mapping the different potential conflict of interest cases as well as a “Register of Conflicts of Interest” that lists potential or proven conflicts of interest cases since the creation of Keensight Capital;
• A Code of Conduct, which is approved by each employee upon hiring.
• Appropriate escalation processes when identifying a conflict of interest as well as a whistleblowing tool.

Whenever an employee, an investor, or any other person raises concerns about the existence or possibility of a real, potential, or apparent conflict of interest, they must immediately inform the RCCI (Compliance and internal control officer).

This communication should be made through any durable medium (email, internal memo, etc.). It should specify:

• The relevant activity;
• The date when the conflict was observed;
• Whether the conflict is actual or potential;
• A detailed description of the conflict;
• The stakeholders impacted by the conflict;
• The potential type of impact.

Individuals are also encouraged to report, either in writing or orally, to the RCCI any situations they deem necessary and which could generate a conflict of interest or its appearance, even if they are unable to specify all six characteristics mentioned above.

When a potential conflict is reported, the RCCI examines the nature, origins, and consequence of the identified conflict of interest and implements appropriate measures to mitigate its immediate impact.

Where the organizational or administrative arrangements made by Keensight Capital to manage conflicts of interest are insufficient to provide reasonable assurance that the risk of undermining the interests of investors will be avoided, the company shall clearly inform the persons concerned of the nature or source of such conflicts of interest.

The Fund’s Investor Advisory Committee is informed as soon as the Management Company identifies a situation of conflict of interest qualified as i) potential but not treated and ii) proven, in accordance with the rules of good conduct specified in the Fund Regulations.

In the event of a proven conflict of interest, the Management Company shall inform the Fund’s Investor Advisory Committee (in accordance with the provisions of the Fund Regulations) and the Statutory Auditor of the Company and the Fund(s) of the situation observed and the measures taken.

Article 4(1)(b) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”) requires fund managers to publish a statement regarding the consideration of principal adverse impacts of investment decisions on sustainability factors.  Keensight Capital has established processes and measures to assess and monitor ESG and sustainability matters (i.e., environmental, social, and governance factors) in the investment cycle, in line with its ESG Policy and Responsible Investment Policy.

However, at this stage, Keensight Capital does not consider any adverse impacts as prescribed in the EU SFDR regulation as the Company acknowledges the current limitations on readily available data to fully comply with the reporting requirements.

The Firm’s position will be kept under ongoing review and monitored closely as the market developments evolve. In this sense, Keensight Capital will reassess the situation and make the necessary changes in due course, toward the consideration of principal adverse impacts in the manner contemplated by Article 4(1)(a) of the SFDR.

Engagement policy
Engagement policy report – 2024
Report Energy Climate – Article 29 (2024)
Remuneration policy

The Keensight Capital website is protected under intellectual property rights, as are any data on the website, such as brands, logos, graphs, photographs, etc. The information contained on this website is strictly for the personal use of the website’s visitors and may not be reproduced or communicated to third parties, in whole or in part, for commercial or non-commercial purposes.

Due to the simplified nature of the website’s content, the information communicated by Keensight Capital’s website is incomplete and has no contractual value. Despite our best endeavors, technical faults may occur. These could result, for example, from restricted access or faulty reproduction of information, caused by either the website itself or the actions of third parties: Keensight Capital takes no responsibility for any loss which could result. It undertakes only, upon identification of the fault, to implement procedures to remedy such fault. The user is liable for any reproduction or, in general, any unauthorized use of the website and the information contained therein. Such use may result in legal proceedings, particularly for piracy.

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