In this Policy, “Equistone”, “we”, “us” and “our”, refer to each of Equistone Partners Europe Limited, registered in the United Kingdom with registered office One New Ludgate, 60 Ludgate Hill, London, England, EC4M 7AW and the funds which it manages (as listed in paragraph 12 hereto (each a “Fund” and, together, the “Funds”)). Equistone Partners Europe Limited's company registration number is 01125740.
Equistone is committed to safeguarding information from which any individual can be identified, such as names, contact details and ID data (“Personal Information”), which is provided to us or which we obtain relating to any individuals (“you”), including its clients, investors, any other individuals with whom it interacts and all visitors to the website: www.equistonepe.com (the “Website”). To the extent that any Personal Information is collected, it will be held in confidence in accordance with the Data Protection Legislation (as defined below). Please read the following Privacy and Cookies Policy which explains how we use and protect your information.
We will only use Personal Information which is provided to us, or otherwise obtained by us, as set out in this Policy. We will ensure that your Personal Information is handled in accordance with the “Data Protection Legislation" (meaning any law applicable from time to time relating to the processing of Personal Information and/or privacy as the same may be re-enacted, applied, amended, superseded, repealed or consolidated, including without limitation, the UK Data Protection Act 1998, (with effect from 25 May 2018) the General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003, in each case including any legally binding regulations, directions and orders issued from time to time under or in connection with any such law).
By visiting and/or contacting us through the Website (or otherwise engaging with us, such as for investor relations purposes), you acknowledge that we may collect, use and transfer your Personal Information as set out in this Policy. Equistone reserves the right to change this Policy from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.
For the purposes of the Data Protection Legislation, each of the abovementioned Equistone entities and any Funds in which you invest are each deemed to be the “data controllers” in respect of any Personal Information that you provide to us or we otherwise obtain about you.
This Privacy and Cookies Policy covers:
- Personal Information that we collect from you
- Personal Information that we receive from other sources
- Sensitive Personal Information
- What we do with your Personal Information
- How we share your Personal Information
- Our security measures and information about when we delete data
- Transferring Personal Information outside of the EEA
- Accessing and updating your Personal Information
- Changes to this Privacy and Cookies Policy
- Funds managed by Equistone Partners Europe Limited
- Our contact information
1. PERSONAL INFORMATION THAT WE COLLECT FROM YOU
When you engage with us (e.g. sending us emails, contacting us via telephone or visiting or making an enquiry through the Website), you may provide Personal Information about yourself including your name and contact details (e.g. your address, email address and telephone number). If you invest in one the funds that we manage, you may also provide us with your financial information and various other necessary Personal Information (e.g. your national insurance, social security or tax payer identification number, investment history and bank details). Where you make use of our Website we may also collect information about your use of the Website (e.g. your IP address and choice of web browser). Some of this Personal Information is collected and processed so we can perform a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Website and services and support our staff and clients).
We may occasionally need to record certain telephone calls where we have a regulatory obligation to do so. We also track certain emails that we send to some individuals in order to determine when the email is opened for marketing purposes. We do not ordinarily record calls or track emails.
Where you apply for a job with us, we may collect from you and third parties (where relevant) additional Personal Information such as your CV and any references. Unless you agree that we can keep such information on file for future opportunities or we need to retain such information for compliance with our legal obligations, in the event that you are unsuccessful, we will only retain this Personal Information for as long as is reasonably necessary to process your application.
Where you provide Personal Information on behalf of another individual, you are responsible for notifying that individual that you have provided their Personal Information to us and directing them to this Policy so they can see how we will process their Personal Information.
2. PERSONAL INFORMATION THAT WE RECEIVE FROM OTHER SOURCES
We may receive information from third parties who collect Personal Information from you and pass it on to us. For example: (i) where we are conducting due diligence on prospective investee companies or deciding whether to invest in third parties we may also receive Personal Information concerning key personnel; (ii) our staff may also give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements; (iii) where another individual makes an investment on your behalf, they may provide us with certain Personal Information to effect the transfer of the investment to you, such as your name and contact details; (iv) your employer may provide your Personal Information to us in connection with a service they provide to us or in connection with services that we provide to our clients; and (v) we may receive information from past employers and others concerning your employment history where you apply for a job with us. Where this is the case the third party is responsible for informing you that they have shared your Personal Information with us, directing you to this Policy and obtaining any relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used. However, once we are holding it, we will only handle any person's Personal Information in accordance with this Policy.
3. SENSITIVE PERSONAL INFORMATION
“Sensitive Personal Information” is Personal Information concerning an individual's (i) racial or ethnic origin, (ii) political opinions, (iii) religious beliefs or other beliefs of a similar nature, (iv) membership of a trade union, (v) physical or mental health or condition, (vi) sexual life or orientation, (vii) commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by him/her, the disposal of such proceedings or the sentence of any court in such proceedings.
If you provide us with Sensitive Personal Information, the provision of this information is entirely voluntary and subject to your express consent. However, we may be unable to carry out some activities without this information - for example, we may be unable to process application forms or similar requests. We will use any Sensitive Personal Information in accordance with the consent you have given and, where necessary, we may also process such information in the establishment, exercise or defence of legal claims.
Where we do receive Sensitive Personal Information, we will only keep such information for as long as strictly necessary in order to comply with our obligations under the law.
4. WHAT WE DO WITH YOUR PERSONAL INFORMATION
We will only use your Personal Information in order to (a) manage and administer your investment or proposed investment in the relevant Fund and any related accounts on an ongoing basis, in accordance with the contract between you and the relevant Fund, (b) provide investor relations and support to you in respect of these services, (c) improve our Website and services, (d) comply with our own legal and regulatory obligations, including in relation to financial promotion, applicable anti-money laundering and counter terrorist financial legislation, the Common Reporting Standard and FATCA, (e) for our internal business processes, including providing support to our staff and our assessments of prospective investee companies, and (f) where relevant, process your application for employment.
Where you have explicitly consented at the time we collected your Personal Information or where we otherwise have a right to do so, we may also use your Personal Information to let you know about any of our services that may be of interest to you and/or inform you about important changes or developments to our services by email.
Where you or your employer (or any other entity you work for) provides services to us, you and/or they may provide us with some of your Personal Information in connection with the provision of the services, such as your name, business contact details and other ID information. We will only process such Personal Information in connection with the provision of the services (such as using your contact details to discuss the services) and in accordance with this Policy. In addition, where necessary, we may also share your Personal Information with our investors or other third parties in order to provide our services (e.g. if you or your business provides investor administration services, we may share your business contact details with our investors so that they can contact you).
If you change your mind about us using your Personal Information in the ways described in this Policy, please let us know by e-mailing: firstname.lastname@example.org. You may also opt out of receiving marketing emails from us by following the instructions outlined in the email.
5. HOW WE SHARE YOUR PERSONAL INFORMATION
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties, such as our Funds' administrator and depositary and other professional advisers, service providers, regulatory bodies, auditors, technology providers and any duly authorised agents or related, associated or affiliated companies of the foregoing for the same purposes.
By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We ask all third parties to treat your Personal Information securely and in accordance with this Policy and will take reasonable steps to enforce this. We will never sell your data.
In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as anti-money laundering or anti-terrorist financing obligations), carry out an internal investigation, enforce our Terms and Conditions on our Website and any other agreement, or protect the rights, property, or safety of Equistone, the Funds, our group companies and our clients, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention. In particular, in order to comply with the Common Reporting Standard and FATCA, Personal Information may be shared with the tax authority of the jurisdiction in which the relevant Fund is domiciled. It in turn may exchange information (including Personal Information and financial information) with foreign tax authorities (including the U.S. Internal Revenue Service and foreign tax authorities located outside the European Economic Area).
In exceptional circumstances, if we are sold or merged with another company we may disclose your information to a potential buyer, including your Personal Information and other information concerning your relationship with us, so that they can continue to provide the services you have requested.
6. OUR SECURITY MEASURES AND INFORMATION ABOUT WHEN WE DELETE DATA
We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation allows.
Unfortunately, the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website; any transmission is therefore at your own risk.
Some of our premises use CCTV in shared areas for the purpose of crime prevention. As this is under the control of a third party you should consult any notices they display and their privacy statements for more information.
7. TRANSFERRING PERSONAL INFORMATION OUTSIDE OF THE EEA
Any Personal Information provided to Equistone will be transferred to and stored on Equistone's servers in Munich, Germany. Any Personal Information provided to a Fund will be transferred to and stored in the relevant country set out in the paragraph of this Policy entitled “Funds Managed by Equistone Partners Europe Limited”. We take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the European Economic Area (“EEA”) to our staff and our third-party service providers. It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to our non-European offices and Funds and to third parties based outside the EEA if that party (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information, (b) has agreed (by way of written contract incorporating the “model clauses” as approved by the European Commission or by some other form of data transfer mechanism approved by the European Commission) to provide all protections to your Personal Information as required by the Data Protection Legislation or (c) we have your explicit consent to do so (such as where you have requested a service from one of our Funds situated outside the EEA). Where any transfer takes place under a written contract, you have the right to request a copy of that contract and may do so by e-mailing: email@example.com. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.
By submitting your Personal Information to us, you acknowledge this transfer, storing or processing of your Personal Information.
8. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
If you have given us your express consent, or where we otherwise have the right to do so, we may use your Personal Information for marketing purposes. If we intend to disclose your Personal Information to any third party for marketing purposes, we will seek your explicit consent prior to any such transfer. You can exercise your right to prevent such processing by e-mailing firstname.lastname@example.org.
You are entitled to know some details about the Personal Information we hold about you and how that information is processed. If you would like to request this, please e-mail email@example.com and we will provide you with the information to which you are entitled.
You can also ask us to: (a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some circumstances, transfer any information we hold about you to a specified third party. If you wish to exercise any of these rights, please contact us at: firstname.lastname@example.org.
Should you have any queries or complaints in relation to how we use your Personal Information, please e-mail email@example.com. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Office regarding such issues.
Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any Personal Information via these websites.
A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our Website are being used.
A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the Personal Information you choose to share with us (including Personal Information you automatically share with us by way of your browser settings).
In particular, we use the following cookies:
Google Analytics is a web analytics service provided by Google Inc. (“Google”) and is in use to collect information about how visitors use the Website and which pages are most frequently viewed. This provides us with important information that can enable the Website to work better. We do not link this information to your name or address.
The following cookies are used by Google Analytics: _utma, _utmb, _utmc and _utmz. The longest lasting cookie (_utma) expires two years after your last visit to the Website and the others expire after a maximum of six months.
Google have a number of cookies on any page that includes a Google Map. While we have no control over cookies set by Google, they include a mixture of pieces of information to measure the number and behaviour of Google Maps users.
The following cookies are used by Google Maps: APISID, HSID, NID, PREF, SAPISID, SID and SSID. Most of the cookies expire 10 years after your last visit to a page containing a Google Map.
We may use banners and pop-ups from time to time to give you options around cookie use.
You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our Website.
You can also find more information about cookies generally here: www.allaboutcookies.org.
11. CHANGES TO THIS PRIVACY AND COOKIES POLICY
Equistone may amend this Policy at any time without notice. By continuing to use the Website and making use of our services you acknowledge that we shall process your Personal Information in accordance with the updated Policy. If you are not happy with any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to this Policy will be posted on the Website.
12. FUNDS MANAGED BY EQUISTONE PARTNERS EUROPE LIMITED
Equistone manages the following funds: Equistone Partners Europe Fund II, Equistone Partners Europe Fund III, Equistone Partners Europe Fund IV, Equistone Partners Europe Fund V, Equistone Partners Europe Fund VI, Equistone Private Equity PVLP LP and Barclays Industrial Investments Limited. Any Personal Information received in connection with such funds will be stored at the registered office of Equistone Partners Europe Limited in the United Kingdom and on Equistone’s servers in Munich, Germany (subject to section 7 of this policy – above).
13. OUR CONTACT INFORMATION
If you have any questions (including relating to transfers of your Personal Information outside the EEA), please feel free to e-mail firstname.lastname@example.org.