GHO Capital Partners LLP
This notice (the “Privacy Notice”) describes how GHO Capital Partners LLP and its affiliated entities (the “Firm”, “we”, “us”, “our”) collect, access, use, store, disclose and otherwise process personal data about you when you interact with us, including when visiting our website and through the provision of services that link to this Privacy Notice. We are committed to respecting the confidentiality of personal data and will process your personal data in accordance with applicable data protection laws. For the purposes of this Privacy Notice, any information or data that relates to you, or from which you can be identified, is known as “personal data”.
Please note that if you are an existing, prospective or former investor, or a representative of an investor, in one or more of the private investment partnerships managed directly or indirectly by the Firm (the “Funds”) the privacy notice at https://ghocapital.com/investor-privacy-policy/ applies to the processing of your personal data in relation to the Funds.
This Privacy Notice was last updated on October 2022.
We are GHO Capital Partners LLP (company number 0C389512), registered at 21 St. James’s Square, London, SW1Y 4JZ. For the purposes of data protection legislation, we will be a controller of your personal data. GHO Capital Partners LLP is authorised and regulated by the UK Financial Conduct Authority with registration number 612589 and is registered as a data controller with the Information Commissioner’s Office with registration number ZA831495.
Should you have any questions or concerns about this Privacy Notice or our processing of your personal data, please write to us at the address listed above or contact Investor Relations at [email protected].
We collect and process or otherwise verify some or all of the following types of personal data when you interact with the Firm, depending on the nature of the interaction you have with us, for the purposes described in this Privacy Notice:
- Contact information, such as your name, address, email and telephone number.
- Employment information, such as your job title and company name (for example, if you visit our offices or attend one of our events, for which we may also collect information about your dietary requirements if we serve food).
- Financial information, such as for the purposes of paying invoices to individual vendors and business partners.
- Technical information, such as your internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Marketing information, such as your preferences in receiving marketing from us and our third parties and your communication preferences.
- Additional information collected in the course of conducting our business, such as to facilitate and maintain relationships with our portfolio companies and management teams, industry contacts, journalists and PR professionals.
We collect the personal data referred to above from the following sources:
- Personal data provided through forms you complete and when you correspond with us by post, telephone, email or otherwise, including when you subscribe to our publications, sector and industry networks, request marketing to be sent to you or when you give us feedback.
- Your transactions with the Firm and other parties in relation to our services.
- Personal data we receive from third parties or publicly available sources, such as industry databases, analytics providers, advertising networks and search information providers, and from public sources such as Companies House and social media platforms.
- Our website, including registration information and any information captured via cookies.
The Firm will use your personal data for the purpose or purposes for which we collected or received it, unless we reasonably consider that we need to use the personal data for another reason that is compatible with the original purpose or we have another legal basis to do so.
We collect and process your personal data:
- Where required by applicable laws and regulations – for example, laws relating to health and safety so that we know who is in our building in the event of an emergency, to make adjustments for visitors to our offices, and for compliance and record-keeping purposes.
- Where necessary for the Firm to enter into or perform a contract with you, or to take steps at your request prior to entering into a contract – for example, to provide services to you and otherwise manage our relationship with you.
- Where necessary for the Firm’s legitimate interests or the legitimate interests of another person, unless your interests outweigh these interests – for example, to operate and facilitate our business and services, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain the Firm’s core records, protect our rights and interests, ensure the security of the Firm’s assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services and enforce our terms and conditions.
- Where necessary for the establishment, exercise or defence of legal or regulatory claims.
In some cases, the Firm relies on your consent to process your personal data. For example, we may do so to send electronic direct marketing to you. We will only rely on your consent where we have specifically asked for it and, in each case, you will have the right to withdraw your consent at any time. When we approach you for your written consent to allow us to process certain specific personal data, we will provide you with full details at the time we request your consent. You have the right to withdraw any consent you provide and doing so will not affect the legality of the processing of your data prior to that point. If you decline to provide or withdraw your consent to our use of your personal data and, under applicable law, we are relying on consent on the legal basis for its processing, there may be circumstances in which we will not be able to provide you with access to our services or otherwise take action on your behalf.
Where we require personal data to comply with our legal or contractual obligations, the provision of this personal data is mandatory. If it is not provided, we will not be able to provide access to our services or otherwise meet the obligations placed on us. In all other cases, the provision of the personal data that we request is optional.
The Firm may disclose your personal data to third parties in the following circumstances (in each case for the purposes and uses that are consistent with this Privacy Notice):
- Any affiliate, employee or member of the Firm.
- With service providers who, on our behalf or for your benefit, provide services to the Firm or have a reasonable need to receive the personal data in connection with the conduct of our business, including our fund administrators, lawyers, auditors, regulatory and tax advisers, custodians and broker-dealers, and with entities and individuals otherwise acting on our instructions.
- As required by applicable law and regulations and to legal or government regulatory authorities as required in connection with legal or regulatory matters, including in connection with background screening, claims, disputes or litigation, or if we determine that disclosure is necessary to enforce our legal rights or contractual commitments.
- In connection with a corporate business transaction such as a merger, acquisition, joint venture or financing of the Firm’s assets, in which case the Firm may disclose your personal data to the prospective seller or buyer of the relevant business or assets or their advisers.
- With third parties to which you or your designated representatives request or authorise us to disclose your personal data.
In each case we will take reasonable steps to share the minimum personal data necessary for the relevant purpose.
The Firm stores your personal data in the UK and the European Economic Area (“EEA”). However, your personal data may also be transferred to and processed in Jersey, the Cayman Islands and the United States of America, where our support and management services and affiliates are based. The laws of some of these countries may not offer the same standard of protection for personal data as the UK and EEA. To the extent required by applicable data protection law, we rely on appropriate or suitable safeguards in respect of international transfers of your personal data, including:
- Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards.
- Using a third party’s binding corporate rules.
- Obtaining your consent to transfer personal data after informing you about the possible risks of the transfer.
- When the transfer is necessary for the performance of a contract between you and the Firm, or the transfer is necessary for the performance of a contract between the Firm and a third party, and the contract was entered into in your interest.
- When the transfer is necessary to establish, exercise or defend legal claims.
Please contact us using the details above if you would like more information on the specific mechanism we use when transferring your personal data.
We will retain your personal data only for as long as is reasonably necessary for the purposes set out in this Privacy Notice, subject to your rights, under certain circumstances, to have your data erased. The Firm may be required by law to hold certain personal data for specific periods. In other cases, we will retain your personal data for an appropriate period after our relationship ends to protect ourselves from legal claims or to administer our business.
When deciding how long to retain your personal data, we take into account our legal and regulatory obligations, 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 the personal data and whether we can achieve those purposes through other means. We may also retain your personal data to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
In accordance with our legal obligations, we take appropriate technical and organisational measures to protect your personal data. However, we can only be responsible for systems that we control.
9.1 Your rights in relation to your personal data
Under certain circumstances, you have the right to:
- Know if we process any personal data about you and request a copy of the personal data we hold about you to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected or removed.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no legitimate reason or legal requirement for us continuing to process it.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party). You also have the right to object at any time to our use of your personal data for direct marketing.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data – for example, you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party in a machine-readable, commonly used and structured format. This right will apply where we process personal data based on your consent or where the processing is necessary for the performance of a contract between us.
- Withdraw consent at any time if we are processing your personal data based on your consent.
These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to determine whether our use of your personal data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.
We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfil your request to exercise the right before this date and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
9.2 Your duty to inform us of changes
It is important that we maintain accurate records of key information about you. Please notify us of any significant changes in your personal circumstances as soon as they occur (for example, a change of name or updated contact information). From time to time, we may also ask you to complete a new personal data form to ensure that our records are up to date.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights described above). In some cases, we may charge a reasonable fee if your request is clearly unfounded or excessive (for example, if you request multiple copies of the personal data). Alternatively, we may refuse to comply with the request in such circumstances.
9.4 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of the other rights described above). We have this security measure in place to ensure that personal data is not disclosed to any person who has no right to receive it.
9.5 Right to complain
If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your personal data, please contact us using the details above. If you are not satisfied with our response, you have the right to lodge a complaint with your competent data protection regulator. However, we would appreciate the opportunity to address your concerns before you do this, so please contact us in the first instance. The data protection regulator in the UK is the Information Commissioner’s Office, which can be contacted at https://ico.org.uk/global/contact-us/ or 0303 123 1113.
Links on our website may take you to third party sites over which we have no control. While such links are provided for your convenience, you should be aware that the personal data handling practices of the linked websites might not be the same as ours and the Firm does not accept any responsibility or liability for these policies. You should review any privacy notices on those linked websites. This Privacy Notice does not cover the information practices of any linked websites.
We keep this Privacy Notice under review and reserve the right, at our discretion, to change, modify, add to or remove portions from it, and we will update the date above accordingly. On some occasions, we may also actively advise you of specific personal data handling activities or significant changes to this Privacy Notice where we are required to do so by applicable law. However, we recommend that you return to the website to check for any other changes to this Privacy Notice.
Use of the website is subject to the Terms and Conditions.