Palatine Private Equity LLP

Privacy Notice

1. Introduction

   This Privacy Notice outlines how Palatine Private Equity LLP (“Palatine,” “we,” “us,” or “our”) collects, uses, processes, and protects your personal data when you browse and interact with our website. We take your privacy very seriously. We will ensure that all the personal information we collected about you is processed fairly and lawfully, in accordance with the UK GDPR and other data privacy legislation including but not limited to the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 and we aim to meet current internet best practice. For the purpose of the UK GDPR, Palatine acts as a data controller.

2. Contact Details:

   Palatine Private Equity LLP
   Chancery Place
   50 Brown Street
   Manchester
   M2 2JT
   Company registration number: OC315480
   Lead for Data Protection: Mathew Thompson
   Email: Mathew.thompson@palatinepe.com
   ICO Registration Number: Z316263X

3. Types of Personal Data We Collect

   Where we collect data that identifies an individual this is classed as “personal data”. We collect various types of personal data, including but not limited to:

   • Identity Data: Full name, title, previous names, marital status, date of birth, photographic proof of identity (passport, driving license).
   • Contact Data: Postal address, email address, telephone numbers.
   • Financial Data: Bank account details, tax information (Unique Tax Reference Number, National Insurance Number), investment history, source of funds.
   • Employment Data: Employment history, salary details.
   • Technical Data: IP address, browser type and version, time zone setting, operating system and platform, and other technology on the devices used to access our website.
   • Profile Data: Investment experience, marketing preferences, feedback, and survey responses.
   • Usage Data: Information about how you use our website, products and services.

   The above list is not exhaustive and we may from time to time require additional information to satisfy our legal and regulatory obligations. Where additional information is required we will provide you with a reasonable explanation of why it is required unless we are prevented from doing so by law.

4. How We Collect Your Personal Data

   • Direct Interactions: You may provide your personal data by filling in forms or questionnaires or by responding information requests from us, corresponding with us by post, phone, email, or otherwise.
   • Third Parties: We may receive personal data about you from various third parties, including intermediaries where you have authorised the sharing of your personal data, public databases, and professional advisors.

5. Purpose and Legal Basis for Processing

   We only collect your personal data where we have a lawful purpose to do so. These reasons include:

   • Legitimate Interests: To manage our relationship with you, improve our services, and ensure security.
   • Legal Obligations: To comply with legal and regulatory requirements.
   • Consent: To send marketing communications where you have given your explicit consent.

6. How We Use Your Personal Data

   We use your personal data:

   • Where you have consented to us doing so, such as where you have specifically asked us to respond to an enquiry or to send marketing communications.
   • To complying with legal and regulatory obligations, including anti-money laundering laws.
   • Where it is otherwise in our legitimate interests to do so, including:
   • To provide, personalise and enhance our services, both on-line and off-line, and to conduct quality assurance and/or train our staff, because it is in our legitimate interests to provide you with a personalised service and generally maintain the quality of our service.
   • To manage and administer investments and related accounts, because it is in our legitimate interest (and the legitimate interests of the businesses we invest in) that we can do this effectively.
   • Providing investor relations and support, because it is in our legitimate interest (and the legitimate interests of our investors) that we can do this effectively.

7. Data Sharing and Disclosure

   We may share your personal data where appropriate and required with the parties set out below for legitimate business interests and lawful purposes. These may include but are not limited to:

   • Service Providers: IT and system administration services.
   • Professional Advisors: Lawyers, bankers, auditors, tax advisors, and insurers.
   • Regulators: HM Revenue & Customs, Financial Conduct Authority, and other regulatory bodies.
   • Third Parties: In case of mergers, acquisitions, or asset sales.
   • International Transfers: If necessary, we will ensure that data transferred outside the UK is protected by appropriate safeguards.

   Where dealing with your enquiry may involve passing information to third parties (being our marketing platform or our client relationship management platform), you will be made aware of this, unless this is already clear from the nature of your enquiry. We require all third parties to whom we transfer your data to respect the security of your personal data and treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

   If you sign up to our mailing list, the data that we collect from you will be transferred to, and stored by, our mailing list provider, which may involve your personal data being transferred to the USA, where it will be stored and may be accessed by our supplier’s staff for, amongst other things, the provision of support services. These transfers are made pursuant to the EU Standard Contractual Clauses (with UK Addendum) which are standard approved clauses which can be used when making international transfers of personal data to ensure that the recipient is subject to equivalent obligations to those imposed by the UK GDPR and that enforcement action can be taken where necessary.

8. Data Security

   We implement appropriate security measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. We restrict access to personal data to employees, agents, contractors, and other third parties who have a business need to know.

9. Data Retention

   We retain your personal data only as long as necessary to fulfil the purposes we collected it for including legal, regulatory, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some cases personal data may be retained on a long term basis: for example, personal data that we need to retain for legal purposes will normally be retained for at least six years in accordance with usual commercial practice and regulatory requirements.

10. Your Rights

    You have various rights in relation to your personal data, including to request access to your personal data, to request rectification of inaccurate personal data, to request the erasure of your personal data, to request restrictions on the processing of your personal data and to object to our processing of your personal data. Where our processing is based on consent, you can also withdraw your consent to the processing. It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your contact details. If you want to stop receiving any information from us, such as news and updates, please let us know by clicking the unsubscribe link in the email or alternatively by contacting us. Your decision to stop receiving information from us may result in the deletion of some of the personal information that we hold about you, but we may still retain personal information we require for other purposes, including where it is required for record keeping purposes. To exercise these rights, contact us at mathew.thompson@palatinepe.com. We aim to respond within one month.

11. Complaints

    If you would like to make any enquiry or request in respect of how we handle your personal data, or in the unlikely event that you have any concerns about how we use your personal data, please contact us as at mathew.thompson@palatinepe.com. If you make a complaint about our handling of your personal data, it will be dealt with in accordance with our complaints handling procedure. If we are unable to resolve your complaint, you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/make-a-complaint/ for more information.

12. Accuracy of Data

    We strive to ensure that the personal data we hold is accurate and up to date. Please inform us of any changes to your personal data by contacting mathew.thompson@palatinepe.com.

13. Changes to this Privacy Notice

    We may update this Privacy Notice from time to time. Any changes will be posted on this page. If we make significant changes, we will notify you by email.

14. Cookies and Website Usage

    Our website uses cookies to enhance user experience and collect data about website usage. For more information, please see our Cookie Policy. By using our website, you agree to the collection and use of information in accordance with this Privacy Notice. If you have any questions or concerns, please contact us at mathew.thompson@palatinepe.com.