SFDR Disclosures

SFDR Disclosures

AIFM-related disclosures

Transparency of sustainability risk policies and transparency of the integration of sustainability risks – article 3(1) and article 6 of the SFDR

A sustainability risk refers to an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

The AIFM does not integrate sustainability risks in its investment decision-making process for the following reasons:

(i) the performance tools used by the AIFM to estimate returns of the Fund do not take into account such risks but mainly economic and financial risks;

(ii) since the portfolio companies in which the Fund invests do not usually report on such risks, the AIFM is not in a position to assess and integrate such risks in its investment decision-making process;

(iii) the AIFM is managing the Fund that intends to invest exclusively in portfolio companies that develop B2B/enterprise software solutions, for which the returns should not be impacted by sustainability risks; and

(iv) in view of the AIFM size it is not intended to change the investment decision-making process of the AIFM to integrate such sustainability risks as this will be too costly and not relevant with respect to the Fund.

No consideration of adverse impacts of investment decisions on sustainability factors – article 4(1)(b) and 7(2) of the SFDR

Article 4(1) of the SFDR requires fund managers such as the AIFM to provide a clear statement as to whether or not they consider the “principal adverse impacts” of investment decisions on sustainability factors, e.g. environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

Although ESG and sustainability risks are important to the AIFM, the latter does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by article 4(1) of the SFDR, in particular due to the fact that (i) no reliable and sufficiently available or accessible data is available to perform such impact measurement and provide the mandatory reporting imposed by the regulatory technical standards in a consistent manner; and (ii) the underlying investments are not generally required to report on such factors in the manner prescribed by SFDR.

The AIFM does not intend to consider principal adverse impacts of investment decisions on sustainability factors in the near future.

Transparency of remuneration policies in relation to the integration of sustainability risks – article 5(1) of the SFDR

For the purposes of article 5(1) of the SFDR, the AIFM declares that it has not put in place a remuneration policy in light of the fact that it qualifies as a registered alternative investment fund manager and thus does not fall under such requirement under the AIFMD. 

Fund-related disclosures

Transparency of other financial products in pre-contractual disclosures and in periodic reports – article 7 of the Taxonomy Regulation

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Cookies Policy

Cookies Policy

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Link to our Privacy Policy.

Privacy Policy

Privacy Policy

This privacy notice contains information regarding the processing of personal data carried by BRIGHTCAP INVESTMENT ADVISOR OOD of representatives, employees and other people of interest, related to companies, applying for financing from the BrightCap Ventures.

This information has been prepared with regards to Regulation (EU) 2016/679 (the General Data Protection Regulation, GDPR) and the Personal Data Protection Act of the Republic of Bulgaria. For requests and additional information please contact us at e-mail: info@brightcap.vc.



The responsible party for the processing of your personal data is BRIGHTCAP INVESTMENT ADVISOR OOD, registered under UIC: 205151830 in the Commercial Register, kept by the Registry Agency at the Ministry of Justice of the Republic of Bulgaria, with seat and address of management at 1504 Sofia, 6 Shipka str., floor 3, webpage: http://www.brightcap.vc/ (hereinafter referred to as “We” or “BrightCap”), represented jointly by at least two of the for managers: Georgi Mitov, Daniel Lorer, Diana Stefanova and Elina Halatcheva.



BrightCap processes your personal data for the purposes of receiving applications for financing, submitted by accelerator and early-stage companies (“the applicants”) to identify the company contacts, representing the applicants, to conduct communication as well as to review the applications and evaluate whether to invest in the particular applicants.



BrightCap processes the following categories of personal data: names and other identification data, contact details (email, telephone number), business activity details as well as other data that We are obliged to process under the law (when applicable).



BrightCap processes personal data related to applications for financing on grounds of our legitimate interest to assess and evaluate the BrightCap Fund investment beneficiaries, to communicate with the company contacts as well as to maintain internal statistics and assess and improve our own activity as well as to comply with legal obligations arising for Us with regards to our activity under the applicable laws, including the Measures Against Money Laundering Act (MAMLA).



The protection and security of your data is important to us. In order to prevent loss, misuse or unauthorized access to your data, we apply all reasonable organizational and technical measures and remedies, including applying privacy policies, the obligation for confidentiality of all employees, implementation of technical measures to protect computers and systems by which personal data are processed. In case of a data breach that may cause high risk for your rights We shall contact you without undue delay.



BrightCap shall retain the personal data related to applications for financing as long as ongoing relationship is being maintained with the applicant. After the relationship with the applicant is terminated, BrightCap shall retain the data for as long as necessary to comply with the applicable data protection laws, our internal rules and regulation and to maintain records in order to respond to regulatory requests or questions, up to 15 years, unless provided otherwise by law.



We can disclose your personal data to the competent authorities and courts when required by the applicable law or for legal claims purposes; in the case of team changes, mergers or acquisitions, your data may be shared with our partners, incl. auditors, legal advisors and other consultants, as well as with the BrightCap Ventures Fund and other responsible parties such as fund managers, etc. for investment purposes.
If we transfer personal data to entities outside of the EEA, we will ensure your personal data is protected either by the data protection laws in that country found to be resulting in similar level of protection as provided under the GDPR or by safeguards required by BrightCap on a contractual basis.



In case you believe the processing described herein infringes on your legal rights you can seek protection by requesting to enforce one of the following rights:

  • the right to be informed about the processing of the personal data;
  • the right to object to the processing based on our legitimate interest of the company;
  • the right to rectification of inaccurate data;
  • The right to erasure/ right to be forgotten when your personal data is processed unlawfully;
  • the right to lodge a complaint with the data supervisory authority – the Commission for Personal Data Protection (see below);



In case of any grievances you have the legal right to submit a complaint with the Commission for Personal Data Protection of the Republic of Bulgaria:

  • by mail to 1592 Sofia, No.2 Prof. Tsvetan Lazarov Str;
  • by fax at +359 2 9153525;
  • by electronic means to CPDP’s email: kzld@cpdp.bg;



BrightCap retains the right to amend this privacy notice at any moment, especially with regards to any subsequent changes in the applicable data protection laws. Please find current information at https://brightcap.vc/privacy-policy/.


(rev. Jul 2019)