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Privacy Policy

This Privacy Policy (the “Policy”) and any applicable agreement entered into by you and Alteri Partners LLP (“Alteri”, “Firm” and “We”) sets out the basis on which Alteri, collect, use and shares your personal information. We act primarily as a data controller and/or on occasion may as a data processor in respect of your Personal Data for the purposes of the applicable data protection legislation and European Union’s General Data Protection Regulation (“GDPR”).

Alteri Partners is an FCA authorised and regulated Investment Advisor. The collection and processing of data is for the purposes and requirements associated with the ability to conduct the operation of its business activities.

All service providers appointed by Alteri and the funds to process Personal Data (“Data Processors”) will process Personal Data provided in accordance with Alteri’s instructions and Alteri will act as the Data Controller of any such Personal Data.

This Privacy Notice applies to you if:

  1. you are a client or potential client of Alteri;
  2. Alteri is to conduct due diligence activities in connection with an actual or prospective corporate transaction or investment, with respect to which we are involved;
  3. you have requested to receive any marketing material; and/or
  4. you have given your Personal Data to Alteri for any other purpose.

Alteri is committed to protecting your personal and confidential information and respecting your privacy. Where Alteri holds personal information, it will use this fairly and lawfully.  The information is collected in order to facilitate the provision of services to Alteri’s clients and the benefit of underlying investors, through these services.

By using the Website and any services we offer, you are agreeing to be bound by this Policy in respect of the information collected about you via this Website. Where required under the data protection legislation, Alteri will also obtain your consent.

 

Please read this Policy carefully.

Issued 2018

What Is Personal Information?

"Personal information" is any information that can be used to identify you or that we can link to you and which we have in our possession or control – i.e., data we collect from you, the way in which it is collected and the purposes for which it is collected and used.

Depending upon the nature of the interaction, the information you provide us with will vary and may include:

  • Name, date of birth, nationality, photograph, your gender, government issued identifiers (e.g. passport numbers), home address and home telephone number, mobile telephone number, employer, occupation, job titles, education and qualification details, your CV and references. There may be additional items required and included in the formal processes for activities such as subscription, applications and assessment documents.

Grounds for using your personal information

We rely on the following legal grounds to process your personal information, namely:

  • Performance of a contract - we may need to collect and use your personal information to enter into a contract with you, to perform our obligations under a contract with you, your employer and/or Alteri.
  • Legitimate interests - we may use your personal information for our legitimate interests, some examples of which are given below. 
  • Compliance with law or regulation - we may use your personal information as necessary to comply with applicable laws/regulations.  These include verification of identity and the maintenance of records.
  • Information about other products and services – from time to time we may send you information about our services which we think may be of interest to you.  You can tell us to stop this at any time by sending an email to info@alteri-investors.com with “UNSUBSCRIBE” as the subject line.

Consent - we may (but usually do not) need your consent to use your

Why do we process your personal data?

We process your personal data for different purposes depending on who you are:

  • If you are making or have made a general enquiry with us then we may need to process data in relation to your name, contact information and the contents of your enquiry in order to be able to respond to you.
  • If you currently provide or are contacting us because you are interested in providing goods or services to us or vice versa, then we may need to process data in relation to your identity, contact information or bank account information in order to enter into or perform a contract with you.
  • If we are in the process of conducting due diligence activities in connection with an actual or prospective corporate or investment transaction, in which Alteri is involved.
  • In order to add you to our contacts database we may process data related to your name, contact information, location, areas of practice/professional expertise, employer and employment.
  • Once added to our database we may use your data in order to update your contact preferences, to add you to or remove you from mailing lists, to send you updates or news from Alteri, to process invitations and responses for events organised by Alteri, or to make contact for the purposes of establishing/continuing a business relationship with you. In addition, we may process data relating to meetings we have held with you or events you have attended.
  • If you have approached us regarding a potential employment opportunity, we may need to process information provided by you in your CV and covering letter, including your name, title, address, telephone number, email address, postal address, date of birth, gender, location information, employment history, qualifications and general professional experience.
  • In order to assess your suitability for potentially assisting us with our assessment of investment opportunities, provision of investment advice, taking a position within portfolio companies (connected to clients we advise), we need to process data in relation to your identity, address and geographical location, contact details, the contents of your cover letter and/or CV including your qualifications, experience and employment history, as well as opinions expressed by your referees.  If we conduct an interview or meeting with you then we may also process data in relation to information provided during that interview or meeting, including any assessment notes taken or opinions formed by the interviewer.
  • In order to meet our regulatory and legal obligations as an FCA regulated firm, prevent fraud, other abuse, manage potential litigations and conduct internal audits and investigations.
  • Additionally, we may use your data in order to issue invitations and process responses for events and functions organised by Alteri. This may include dinners or drinks events that we use for specific industry sectors, to stay in touch with you as well as to update you on Alteri, our recent activities and potential future opportunities.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  However, please note that we may process your personal data without your knowledge or consent in accordance with these rules.

Control Over of Your Information

Access to your personal information by Alteri staff and third parties is restricted and processed on a need to know basis, in accordance with Alteri’s policies and procedures.

Where Alteri Stores Your Personal Information

The information that Alteri collects from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA").  It may also be processed by Alteri or Alteri’s suppliers operating outside of the EEA for the purposes set out above. 

If Alteri is involved in selling or buying any business or assets, it may be necessary to share your personal information with the prospective seller or buyer located outside of the EEA.

By submitting your personal information to Alteri, you agree to this transfer, storing or processing. Alteri will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with the Policy.

Who will receive your personal data?

We only transfer your personal data to the extent we need to. Recipients of your personal data may include:

  • Service providers
  • Professional advisers
  • Regulatory bodies and authorities
  • Other entities connected with Alteri, in the provision of investment advisory activities
  • Portfolio companies in which fund(s) we advise, have made an investment

We may transfer your personal data outside of the EEA to service providers or professional advisers operating in other jurisdictions. We will only transfer data where a finding of adequacy has been made in respect of that jurisdiction, which means the EU Commission is satisfied that any data transferred will be adequately protected or where a data transfer agreement incorporates EU model clauses meaning that appropriate safeguards will govern the transfer of the data.

Disclosure and transfer of personal information

Unfortunately, the transmission of information and data via the Internet is not completely secure, unless it is encrypted. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to Alteri or through our website; any transmission of information or data by you to and from Alteri is at your sole risk.

Security and retention of personal information

We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorised access and improper use.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law and regulations. We will not keep more information than we need for those purposes.

Your choices and rights under GDPR

You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.

These rights include:

  • Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you, in accordance with GDPR requirements and limitations.
  • Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege.
  • Requesting that we correct your personal information if it is inaccurate or incomplete.
  • Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally required and/or entitled to retain it.
  • Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally required and/or entitled to refuse that request.
  • Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
  • Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.  We can, on request, tell you which data protection authority is relevant to the processing of your personal information.

Cookies

What are cookies?

  • When you visit the Website, we may store some information (commonly known as a "cookie") on your computer. Cookies are pieces of information that a Website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords, credit card numbers and identifiable personal information are not stored in cookies.
  • A cookie helps you get the best out of the Website and helps us to provide you with a more customised service.

Which Cookies do we use?

  • Google Analytics - Google Analytics use Cookies to remember which web pages you visit and what you have done on previous pages or previous visits to our website. No personal information is collected by Google Analytics and all information collected is stored safely and securely to prevent unlawful third-party access.
  • We use Google Analytics to measure how you are interacting with the Website to ensure that we help you get the best out of the Website.
  • Further information on Google Analytics can be found on

www.google.com/analytics/learn/privacy.html

Managing Cookies

  • You can block or erase cookies from your computer if you want to (your browser's help screen or manual should tell you how to do this), but certain parts of the Website are reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.
  • To find out more about cookies and how these affect your web-browsing experience one of the following websites contain further information:

http://www.allaboutcookies.org

Changes to this policy

Any changes Alteri may make to this Policy will be posted on the Website. Please check back frequently to see any updates or changes to this Policy.

Contact details

ALTERI INVESTORS
20 Balderton Street
London
W1K 6TL

T +44 (0) 207 318 0570
info@alteri-investors.com