This Policy applies to individuals whose personal information we handle, including, without limitation:
- Individual investors
- Individual representatives of third party sellers, placement agents, consultants, lawyers, advisers, vendors and other service providers or other contacts made for business purposes
- Directors, officers, employees or other representatives of portfolio companies in which Funds have made or are considering making an investment
- Employees and job applicants
This Policy is not applicable to partnerships, corporations, trusts or other non-individuals.
Personal Information We Collect
The types of personal information we may collect includes:
- Identification information such as name, ID card and passport numbers, nationality, place and date of birth, signature
- Contact information such as name, postal address, email address, telephone number
- Financial data such as bank account details, source of funds, assets and net worth, tax identification, credit history;
- Information about your transactions with us or our affiliates;
- With respect to employees and prospective employees, we may collect information related to your education and employment, gender, work authorization status, criminal background and information provided by references. We may also conduct a background check;
- Other personal information you provide to us such as through subscription agreements, and other forms and documents you provide or that are provided by others on your behalf.
We may collect this information in various ways including:
- Directly from the you (eg when you submit forms to us)
- Indirectly from other sources (eg public records, from a counterparty in possession of the data, or from conducting background checks)
For purposes of the GDPR, Proprium is the controller of the personal data we collect. Proprium engages third party service providers to process such personal data on behalf of Proprium and those third parties act as processors. Proprium is not required to designate a data protection officer.
How we use personal data
We use personal data in the course of business for variety of reasons including:
- to comply with applicable legal and regulatory obligations
- to carry out contractual obligations
- to pursue our legitimate interests such as communicating with you, facilitating distributions and other financial management and administration activities, evaluating potential transactions and administering transactions; and employment related purposes.
Our lawful basis for collecting and storing personal information is that such processing is necessary for our legitimate interests in running and operating our business and ensuring effective communications with investors and business partners.
Disclosure of personal data
Proprium shares data with its affiliates for the purposes described in this notice.
We share personal data with third parties in certain circumstances including the following:
- to service providers that perform services on our behalf including fund administrators, auditors, IT service providers , legal advisors, accountants and HR service providers. We generally require such third parties to keep information confidential.
- as part of a corporate business transaction such as merger, acquisition, joint venture or financing
- as required by law
Any such disclosure will be limited to that considered necessary in order to provide services to us.
How we protect personal data
We will take reasonable measures to protect your data from loss or unauthorized disclosure or use. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data. .
If you are located outside of the United States, note that personal data we collect may be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside. Your submission of your data to us constitutes your consent to such transfer, which consent may be withdrawn at any time.
Retention of personal information
The period for which Proprium will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation.
Individuals whose personal information we hold may be entitled to access their personal information, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to the Proprium data privacy team (firstname.lastname@example.org). Individuals also have the right to complain about the use of their personal information to the relevant supervisory authority, which in the UK is the Information Commissioner’s Office (www.ico.org.uk).