Privacy Policy

Proprium Capital Partners

Proprium Capital Partners (“Proprium”, “we”, “us”, or “our”) considers privacy to be a fundamental element of our relationship with individual investors and in connection with our business. We are committed to maintaining the confidentiality, integrity, and security of your personal data. In accordance with applicable regulations regarding the privacy of consumer financial information (including Regulation S-P adopted by the Securities and Exchange Commission), and regarding the processing of personal data (the EU General Data Protection Regulation (“EU GDPR”) in the EEA, the UK General Data Protection Regulation (“UK GDPR”), and the Cayman Islands Data Protection Act (as Revised) (“DPA”) in the Cayman Islands), we have prepared this privacy policy (the “Policy”) to inform you of the types of personal data that we receive from you, when this data may be disclosed to others, and how we safeguard such data.

This Policy applies to individuals whose personal information we handle, including, without limitation:

  • Individual investors

  • Individual representatives of investors, third-party sellers, placement agents, consultants, lawyers, advisers, vendors and other service providers or other contacts made for business purposes

This Policy is not applicable to partnerships, corporations, trusts or other non-individuals. We may change this Policy periodically.  The revised policy shall be posted on Proprium website.

Personal Data We Collect

The types of personal data we may collect includes:

  • Identification information such as name, title, 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 data 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

  • Information related to your access of our website (e.g., first or third-party cookies, type of device used, IP address and geolocation)

We may collect this information in various ways including:

  • Directly from you (e.g., when you submit forms to us)

  • Indirectly from other sources (e.g., public records, from a counterparty in possession of the data, or from conducting background checks)  Further information about these sources of personal data is available upon request, by using the contact details set out below

For purposes of the EU and UK GDPR and the DPA, Proprium Capital Partners, L.P. and Proprium Capital Management (UK), LLP are the controllers of the personal data.

Your decision to provide personal data to us is typically voluntary, except where personal data is, for example:

  • collected to meet a legal requirement;

  • necessary in connection with your employment contract;

  • necessary or important for the conduct of our business.

If you do not provide certain personal data, we may not be able to achieve some of the purposes outlined in this Policy.

How we use personal data

We use personal data for a variety of reasons including:

  • communicating with you, facilitating distributions and other financial management and administration activities, evaluating potential transactions and administering transactions, conducting background checks (such as checks against OFAC lists); and 

  • employment related purposes.

Our lawful bases for processing personal data are: 

  • you have given consent to the processing of your personal data;

  • to comply with applicable legal and regulatory obligations to which we are subject;

  • for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract

  • to pursue our legitimate interests in running and operating our business and ensuring effective communications with investors and business partners.

To the extent that we process personal data which reveals criminal convictions or offences, we will ensure that the law authorizes us to process such personal data in accordance with Article 10 EU/UK GDPR. 

For further information on the legal bases and exemptions we rely on, or information about how we have balanced our legitimate interests against your rights and freedoms, please contact us using the contact details set out below.

Disclosure of personal data

We may disclose personal data with our affiliates, staff, and staff of affiliates for the purposes described in this Policy.

We may disclose personal data with third parties in certain circumstances including the following:

  • with 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 personal data confidential, and any such disclosure will be limited to that considered necessary in order to provide services to us;

  • as part of a corporate business transaction such as merger, acquisition, joint venture or financing;

  • with law enforcement authorities, regulators and other public authorities;

  • as required by law.

When this Policy no longer applies to you, we continue to disclose your information as described in this notice, including as required by law. Refer to the “Your rights” section of this Policy for information on how you may limit disclosure of your data.

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.

International Transfers of personal data.

If you are located outside of the United States, note that personal data we collect may be processed and stored in the EEA, the UK, the United States, or other jurisdictions in which the data protection and privacy laws may not be the same as those in the country where you reside. We will ensure that any overseas transfers of personal data are made in accordance with applicable data protection and privacy laws (such as the EU and UK GDPR and the DPA). You can request further information about how we legitimize transfers of personal data outside the EEA and obtain copies of relevant data transfer mechanisms and the UK by contacting us using the contact details set out below.

Retention of personal data

We retain your information as long as reasonably necessary for the purposes described in the “How we use personal information” section above. Our retention practices reflect applicable legal, tax, and business purposes, as well as applicable law. Further information about our retention periods is available on request, by contacting us using the contact details set out below.

Your rights

You have a number of rights with respect to the personal data we process about you, which may be restricted by law. One key right is the right to ‘object’ to processing of your personal data in certain circumstances (e.g., if we are processing on the basis of legitimate interests). You also have the right: 

  • To have personal data erased. You can ask us to erase all or some of your personal data. We will comply with this request unless there is a legal right for us to deny this request. 

  • To rectify or complete personal data. You can also ask us to rectify your data if it’s inaccurate, or complete it if it’s incomplete.

  • To restrict use of personal data. You can ask us to limit our use of your personal data in some situations (e.g., if your personal data is inaccurate or unlawfully held, or if you would like to limit sharing of your data for marketing purposes). 

  • To access and/or take your personal data away (data portability). You can ask us for a copy of your personal data. In some cases you have a right to receive your personal data or have it transmitted to others in an interoperable, machine readable format.

  • To withdraw consent which you have given. If you have given (explicit) consent to us to process your personal data, you may withdraw it at any time.

Any such request should be submitted in writing using the contact details set out below.

You also have the right to complain about the use of your personal data to the relevant supervisory authority. In the EU, you may in particular make a complaint to the supervisory authority in the Member State of your habitual residence, place of work, or of an alleged infringement of the GDPR. In the UK the relevant supervisory authority is the Information Commissioner’s Office (www.ico.org.uk). Where the DPA applies, the relevant supervisory authority is the Cayman Islands Ombudsman (www.ombudsman.ky).

Contact Details

You can contact either Proprium Capital Partners L.P., or Proprium Capital Management (UK), LLP by emailing privacy@proprium.com. 

Our EU GDPR representative may be contacted at EUprivacy@proprium.com. 

Our UK GDPR representative may be contacted at UKprivacy@proprium.com.

Cayman Privacy Policy

Introduction

The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Act (As Revised) (the “DPA”).

In this document, “we” “us” and “our” refers to the Partnership, the Investment Advisor and its or their affiliates and/or delegates.

Investor Data

By virtue of making an investment in the Partnership and your associated interactions with us (including any subscription (whether past, present of future), including the recording of electronic communications or phone calls where applicable) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPA (“Investor Data”). We may also obtain Investor Data from other public sources. Investor Data includes, without limitation, the following information relating to you and/or any individuals connected with you as an investor: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.

In our use of Investor Data, the Partnership will be characterised as a “data controller” for the purposes of the DPA. The Partnership’s affiliates and delegates may act as “data processors” for the purposes of the DPA.

Who this Affects

If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

How We May Use Your Personal Data

The Partnership, as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:

(i) where this is necessary for the performance of our rights and obligations under the Subscription Agreement and/or the constitutional and operational documents of the Partnership;

(ii) where this is necessary for compliance with a legal and regulatory obligation to which the Partnership is subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or

(iii) where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.

Additionally, Gen II Fund Services, LLC (the “Administrator”), may use Investor Data, for example to provide its services to the Partnership or to discharge the legal or regulatory requirements that apply directly to it or in respect of which the Partnership relies upon the Administrator, but such use of Investor Data by the Administrator will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.

Should we wish to use Investor Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.

Why We May Transfer Your Personal Data

In certain circumstances we and/or our authorised affiliates or delegates may be legally obliged to share Investor Data and other information with respect to your interest in the Partnership with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.

We anticipate disclosing Investor Data to parties who provide services to the Partnership and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area). Such parties include the following categories of service provider who may either process personal data on our behalf or for their own lawful purposes in connection with services provided to the Partnership.

(i) the Administrator;

(ii) the Partnership’s legal counsel; and

(iii) the Partnership’s tax advisors.

We may also need to provide Investor Data to investment funds into which the Partnership invests for purposes of their compliance with legal and regulatory obligations (such as compliance with anti-money laundering and FATCA/CRS requirements).

The Data Protection Measures We Take

Any transfer of Investor Data by us or our duly authorised affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPA.

We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data.

We shall notify you of any Investor Data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Investor Data relates.

Getting In Touch

You can contact either Proprium Capital Partners L.P., or Proprium Capital Management (UK), LLP by emailing privacy@proprium.com. 

Our EU GDPR representative may be contacted at EUprivacy@proprium.com. 

Our UK GDPR representative may be contacted at UKprivacy@proprium.com.