Privacy Policy

Park Square Capital, LLP, its affiliates and any investment fund or general partner of any investment fund managed or advised by Park Square Capital, LLP (together, the “Group”, “Park Square”, “we” or “us”) are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of applicable data protection legislation, including the Regulation (EU) 2016/679, known as the EU General Data Protection Regulation (as amended and supplemented) (together, the “Data Protection Laws”), the data controller is Park Square Capital, LLP of 2nd floor, Stratton House, 5 Stratton Street, London, W1J 8LA, United Kingdom, Park Square Capital Luxembourg Management Services S.à r.l. of 5 Rue du Curé, Luxembourg, 1368 Luxembourg Park Square Capital USA LP of 540 Madison Avenue, 27th Floor, New York, NY 10022, USA or any other member of the Group, as applicable.

CONTENTS

Personal information of business contacts

Personal information of service providers, suppliers and professional advisors

Personal information of key transaction personnel

Personal information in relation to investors

Personal information in relation to staff and former staff

Mandatory provision of information

Sensitive or special category personal data

International transfers of personal information

Periodic business updates

Retention of personal information

Your rights

Accuracy and security

Park Square data privacy contact

Changes to Park Square’s privacy policy

1. PERSONAL INFORMATION OF BUSINESS CONTACTS

If you have had contact with Park Square, for example through emailing us or meeting a Park Square representative, we may store limited amounts of personal information relating to you which you provide to us, such as your name, job title, employer organisation and contact details. We will collect and store this personal information for the purposes of (without limitation):

maintaining a record of contacts;
providing periodic business updates as described below;
inviting you to presentations and events and organising meetings between you and Park Square’s representatives;
safeguarding our legal rights and interests;
administering any transaction that we enter into;
managing our investments or potential transactions; and
seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants.

The personal information we hold about business contacts may be shared with:

companies who process personal information on Park Square’s behalf, such as providers of cloud hosting solutions;
financial intermediaries, partners and agents;
professional advisors, such as accountants, lawyers or other consultants; and
other companies in the Park Square group.

2. PERSONAL INFORMATION OF SERVICE PROVIDERS, SUPPLIERS AND PROFESSIONAL ADVISORS

If you are a service provider, supplier to Park Square, or one of its professional advisors (or a person employed by or otherwise connected with any such third party), we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal information for the purposes of (without limitation):

administering and maintaining records of services or advice we have received and commissioning further services;
complying with our regulatory, tax and legal obligations, including assessing and managing risk;
safeguarding our legal rights and interests; and
seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants.

The personal information we hold about service providers, suppliers and professional advisors may be shared with:

companies who process personal information on Park Square’s behalf, such as providers of cloud hosting solutions;
other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Park Square transaction, including co-investors, other providers of finance and investors in Park Square’s funds;
professional advisors such as accountants, lawyers or other consultants; and
other companies in the Park Square group.

We may also share personal data where we consider it to be reasonably necessary in connection with actual or potential legal proceedings, to establish, defend or exercise our legal obligations or rights or in response to requests from law enforcement or other government agencies.

In accordance with the Data Protection Laws, our legal basis for processing personal information that you provide to us is that such processing is necessary for our legitimate interests in running and promoting our business and, in some cases, that it is necessary for the performance of a contract.

3. PERSONAL INFORMATION OF KEY TRANSACTION PERSONNEL

If you are involved in a transaction that Park Square and/or the funds that it manages or advises enters into, or a potential transaction that Park Square considers, we may store personal information relating to you. This might include your CV, details of your previous employment history, business profile and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents such as passports and national identity cards), references provided by third parties, and results of other due diligence carried out. We collect and store this information for the purposes of (without limitation):

assessing potential transactions;
maintaining records of investments;
administering any transaction that we enter into;
assessing your suitability for involvement in a transaction, including by verifying your identity;
complying with our regulatory, tax and legal obligations, including assessing and managing risk;
safeguarding our legal rights and interests;
seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
providing periodic business updates, as described below.

The personal information we hold about key transaction personnel may be shared with:

companies who process personal information on Park Square’s behalf, including third party service providers such as cloud hosting solution providers, corporate administrators or contact management software providers;
credit reference agencies;
financial intermediaries;
professional advisors, such as accountants, lawyers or other consultants;
other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Park Square transaction, including co-investors, other providers of finance and investors in Park Square’s funds; and
other companies in the Park Square group.

In accordance with the Data Protection Laws, our legal basis for processing personal information about you is that such processing is necessary for our legitimate interests in running our business, in particular by considering potential investments and administering transactions that we enter into and, in some cases, that it is necessary to comply with our legal obligations.

4. PERSONAL INFORMATION IN RELATION TO INVESTORS

The personal details of individual investors who have invested into Park Square funds or co-invest with Park Square, of directors, officers, beneficial owners or key personnel employed at our institutional investors or of the nominee or custodian accounts through which individual investors manage their investments, are held and maintained by us. Investor information is collected and maintained by us for the purposes of (without limitation):

fulfilling our contractual obligations to investors;
complying with our regulatory, tax and legal obligations such as anti-money laundering requirements and know-your-client checks;
communicating with investors (including the mailing, in physical or electronic format, of annual reports, AGM or EGM notices or proxy cards, marketing materials or communications in relation to other corporate actions) and otherwise managing and administering the relationship with investors; and
facilitating payments due to and from investors.

The personal information we hold about investors may be shared with:

companies who process personal information on Park Square’s behalf, such as registrars, agents, custodians and providers of cloud hosting solutions;
professional advisors, such as accountants, lawyers, proxy advisers or other consultants; and
other companies in the Park Square group.

In accordance with the Data Protection Laws, our legal basis for processing personal information about you is that such processing is in some cases, necessary for the performance of a contract, or for compliance with a legal obligation or is necessary for our legitimate interests in running and operating our business and ensuring effective communications with investors.

5. PERSONAL INFORMATION IN RELATION TO STAFF AND FORMER STAFF

The personal information of our partners, employees, contractors, temporary staff and third-party service providers (including following the termination of such persons’ relationship with Park Square) is held and maintained by us. This might include your CV, bank account details, family member names, contact details, dates of birth, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, results of other due diligence carried out, performance information, records of absence from work and information about your use of our IT systems. Such personal information is collected:

in order to comply with our regulatory, tax and legal obligations;
when such processing is necessary for the purposes of employment or any other agreement to which such person is party (such as any remuneration or incentive scheme the employee participates in); or
when such processing is necessary to uphold the legitimate interests of Park Square (for example, for internal control, for business continuity or to protect Park Square’s business) or a third party to whom the personal information is provided (for example, to other group companies or insurance providers or human resources software providers).

Consequently, the data that will be processed relate to the following activities and serve the following purposes:

staff administration, including wage administration, contractual benefits, reimbursement of costs;
management of staff and execution of staff policies, including the evaluation of staff, planning of education and career development;
compliance with statutory, regulatory or administrative obligations and observance and application of social and tax legislation;
the work planning, both organizational and administrative, in order to manage services rendered to clients and to charge clients;
management of access control, telephone and IT-network;
management of social benefits organized by Park Square for the benefit of the employees;
ensuring and maintaining an open communication between Park Square and its staff;
the production of statistics; and
the support, both on an organisational and administrative level, of the recruitment and application process including background checks.

The personal information we hold about staff or former staff may be shared with:

companies who process personal information on Park Square’s behalf such as providers of cloud hosting solutions;
service providers such as pension scheme or payroll service providers;
banks, investors and suppliers;
professional advisors, such as accountants, lawyers, proxy advisers or other consultants; and
other companies in the Park Square group.

6. MANDATORY PROVISION OF INFORMATION

We will explain to you when the provision of particular information is mandatory, including the possible consequences of not providing particular information, for example, preventing us from proceeding with a transaction involving you. Park Square will only process the personal information you provide to Park Square for the purposes listed in this privacy policy.

7. SENSITIVE OR SPECIAL CATEGORY PERSONAL DATA

Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. We may in limited circumstances hold some sensitive personal information of our staff such as health data for the purposes of providing private healthcare and fulfilling employer obligations and offence history to assess “fit and proper” suitability under FCA guidelines. We treat such sensitive personal information with due care in accordance with the Data Protection Laws. In all other cases we do not hold sensitive personal data.

8. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Personal information that we hold may be transferred to, and stored in, a country outside of your country of residence, including countries outside of the EEA, such as the U.S. or Guernsey. Where we transfer personal information to Park Square group companies or other third parties outside of the EEA, we will ensure that those transfers take place in accordance with the Data Protection Laws, including by entering into data transfer agreements with recipients. If you would like more information about how your personal information may be transferred, please contact us (see “Park Square data privacy contact” below).

9. PERIODIC BUSINESS UPDATES

We may use personal information that we hold to send you periodic updates about Park Square’s business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us (see “Park Square data privacy contact” below), or by clicking the “Unsubscribe” link in any email that you receive.

10. RETENTION OF PERSONAL INFORMATION

The period for which Park Square 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. For example, we will retain your personal data:

as long as necessary to deal with any query you have submitted;
as long as you might legally bring claims against us; and
after your contract or service with us has come to an end based on legal and regulatory requirements.

11. YOUR RIGHTS

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, that any inaccurate personal information is rectified or to request to exercise the right of data portability. 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 Park Square (see “Park Square data privacy contact” below). Individuals also have the right to complain about the use of their personal information to the Supervisory Authority, which in the UK is the Information Commissioner’s Office (www.ico.org.uk) and in Luxembourg is the National Data Protection Commission (cnpd.public.lu/en.html).

12. ACCURACY AND SECURITY

Park Square will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that Park Square holds about you is incorrect please notify Park Square (see “Park Square data privacy contact” below).

Park Square will take all reasonable steps to protect the confidentiality and security of your personal information but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Park Square responsible for any breach of security unless this is due to Park Square’s negligence or wilful default.

Park Square’s websites may contain hypertext links to external websites. Park Square is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

13. PARK SQUARE DATA PRIVACY CONTACT

For all enquires, comments or requests, please email us at [email protected].

14. CHANGES TO PARK SQUARE’S PRIVACY POLICY

Any changes to this privacy policy will be posted here, so please check Park Square’s privacy policy on a regular basis when you visit any Park Square website.