February 2023
Glendower Capital, LLP, trading as CVC Secondary Partners, its affiliated entities and the funds / accounts it manages or advises (collectively, “CVC Secondary Partners”, “we”, “us” or “our”), value the privacy and security of your personal data, as described below. This Privacy Notice is designed to inform you how we may obtain your personal data through this website (this "Website"), any other personal data you may provide us, or personal data which we may collect in the course of our business. In addition, this Privacy Notice describes how we may protect and share this information; and the rights you may have in relation to this information.
The content on this Website is intended solely to provide general information regarding CVC Secondary Partners. CVC Secondary Partners does not offer or make available its investment advisory services to the general public. Information on this Website does not constitute and is not intended as, an offer or sale of any security or investment product or investment advice. Offerings are made only pursuant to a private placement memorandum containing important information regarding risk factors, performance and other material aspects of the applicable investments.
Please read this Privacy Notice carefully. In the event that you have any questions or concerns about this Privacy Notice, please contact compliance @ glendower.com.
This Privacy Notice does not apply to the processing of personal data relating to CVC Secondary Partners employees or partners, or where we make another privacy notice available.
DATA CONTROLLER
Glendower Capital, LLP is the “data controller” for any personal data provided to CVC Secondary Partners any fund or account managed or advised by CVC Secondary Partners (each, a “Fund”) or any service provider of the foregoing. Contact details for Glendower Capital, LLP are at the end of this Privacy Notice.
USE OF PERSONAL DATA
Personal data means any information relating to an identified or identifiable individual or household, some of which may be defined as sensitive data under applicable law.
Investors in a Fund: The personal data of any investor in a Fund (including the personal data of any natural person that is connected with an investor, for instance, ultimate beneficial owners, officers or other authorized signatories) will be used and treated in accordance with CVC Secondary Partners’ “Investor Privacy Policy” (as currently in force). A copy of CVC Secondary Partners’ current Investor Privacy Policy is available upon request to existing Fund investors from compliance @ glendower.com.
Business contacts: If you have had contact with CVC Secondary Partners, for example through communicating via email or other forms of communications (including via text messages and other messaging applications), or meeting a CVC Secondary Partners representative, we may store personal data relating to you which you provide to us, such as your name, job title, employer organization, contact details and the content of communication.
Service providers and advisers: If you are a service provider, supplier to CVC Secondary Partners, or one of its professional advisers (or a person employed by or otherwise connected with any such third party), we will store limited amounts of personal data relating to you, including your name, job title, qualifications, employer organization and contact details.
Transaction related contacts: If you are involved in a transaction that CVC Secondary Partners is involved in, or a potential transaction that CVC Secondary Partners considers, we may store personal data 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 a passport), references provided by third parties, and results of other due diligence carried out.
Other individuals: CVC Secondary Partners also collects personal data when individuals voluntarily submit information to, or contact CVC Secondary Partners through, this Website, by emailing CVC Secondary Partners using the contact details available on this Website or through other interactions with CVC Secondary Partners. For example, individuals may provide CVC Secondary Partners with personal data in a request for general information, through the submission of a business proposal or when expressing an interest in working with, or otherwise discussing employment with, CVC Secondary Partners or any portfolio company of CVC Secondary Partners.
PERSONAL DATA CVC SECONDARY PARTNERS COLLECTS BY OTHER MEANS
Investor Portal: Registered investors and representatives of investors may access our Investor Portal, which is a private section of this Website.
Promotional Materials: When you sign up to receive notifications or business updates from CVC Secondary Partners, we may provide periodic business updates and send promotional materials subject to regulatory permissions, and other communications.
Biometric Information: If you visit any of our offices in person, your image may be captured on our CCTV system. We operate a CCTV system to protect our buildings and assets from damage, for the personal safety of our staff and visitors and to support law enforcement bodies in the prevention, detection and prosecution of crime.
PERSONAL DATA CVC SECONDARY PARTNERS COLLECTS AUTOMATICALLY
Cookies: At present, we do not use cookies, as defined by the Information Commissioner’s Office (ICO).
That may change in the future at which point we will update this Privacy Notice.
Third-Parties: This Website may provide links to other websites for convenience and information. These websites may operate independently from CVC Secondary Partners. Linked sites may have their own privacy notices or policies, which CVC Secondary Partners strongly suggests individuals to review. To the extent any linked websites are not owned or controlled by CVC Secondary Partners, CVC Secondary Partners is not responsible for their content, any use of the websites, or the privacy practices of the websites.
HOW CVC SECONDARY PARTNERS SHARES AND TRANSFERS PERSONAL DATA
It may be necessary for CVC Secondary Partners or associated third parties (including the parties to whom we disclose personal data in accordance with this Privacy Notice) to effect cross-border transfers of personal data, including to the United States of America and to other countries outside the European Economic Area (the “EEA”) or the United Kingdom (“UK”). The European Commission and the UK Information Commissioner have recognized that certain countries outside of the EEA or the UK ensure an adequate level of protection for personal data. Where a recipient of your personal data is located in a country deemed ‘adequate’ by way of an adequacy decision, CVC Secondary Partners will rely on the adequacy decision to transfer your personal data outside of your home country. In some cases, personal data may be transferred to jurisdictions outside of the EEA or the UK that are not deemed to have data protection frameworks that are equivalent to those of the EEA countries, such as the United States of America. CVC Secondary Partners uses data transfer agreements incorporating standard contractual clauses approved by the European Commission and the UK Information Commissioner to transfer personal data to such jurisdictions. You may request to see a copy of the adequacy decisions or a copy of the standard contractual clauses CVC Secondary Partners has in place by contacting us at the details below.
Such transfers may be to other CVC Secondary Partners entities, to governmental, regulatory or judicial authorities, auditors, legal advisors or agents as well as to sub-contractors engaged by CVC Secondary Partners.
RETENTION PERIODS
CVC Secondary Partners and those third parties to whom personal data is transferred will retain that data as long as is necessary for the purposes and based on the criteria set out in this Privacy Notice. In particular, CVC Secondary Partners will hold certain personal data and other information regarding investors in the Funds for at least as long as they remain investors (which will not typically exceed 12 years). The retention period may extend beyond the investment term where necessary for the relevant Fund’s legitimate interests, including to comply with legal or regulatory obligations or to facilitate the relevant Funds’ on-going administration and performance.
SAFEGUARDING OF PERSONAL DATA
The security of data is central to our business. We use reasonable technical, administrative, and physical security measures to reduce the risk of losing, unauthorized access to, or inadvertent destruction of your personal data. We train our employees to handle personal and business information in accordance with approved policies and procedures that we have established to ensure compliance with applicable laws and internal policies for protecting personal data.
You acknowledge that the transmission of information via the internet is not secure. We cannot guarantee the security of your data transmitted to our public website, any other site used by us and accessible by you or through electronic communications, and any transmission is at your own risk.
INDIVIDUAL RIGHTS
Individuals have certain legal rights in respect of their personal data. Subject to applicable law, you will have various rights in respect of the information relating to you. These include your right to:
If you wish to exercise any of the rights set out above, please use the contact details below. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity.
If you wish to exercise any of these rights and CVC Secondary Partners has transferred your data to a third party, CVC Secondary Partners will communicate such request to each relevant third party unless it would be impossible or involve disproportionate effort for CVC Secondary Partners to do so.
Notice to U.S. Residents
This section only applies to individuals who are residents of U.S. states with data protection laws.
CVC Secondary Partners collects the following categories of personal data, as described in more detail above: Identifiers, such as name, email address, or government-issued identifiers; Demographic information, such as age or gender; Financial information; Commercial information; Internet or other electronic network activity information, such as how you interact with this site and information about the websites who view before and after this site; Inferences drawn from any of the information above. The sources of this personal data include the consumer and publicly available sources on the Internet, including government entities. Without this personal data, we are not able to provide you with all the requested services.
CVC Secondary Partners collects and processes this personal data for the business purposes described above. These include: (i) to exercise and comply with CVC Secondary Partners’s rights and obligations at law or under regulation, or contract, including for the establishment, exercise or defense of legal claims by or against CVC Secondary Partners; (ii) to manage and administer CVC Secondary Partners’s business and improve relationships with investors, including providing advertising and marketing, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions; (iii) to undertake activities to verify or maintain the quality or safety of the service, including to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity; (iii) to ensure security and integrity of the service, (iv) to investigate and respond to any complaints about CVC Secondary Partners or any incidents relating to CVC Secondary Partners.
As described above, depending on where you reside, you may be afforded certain disclosure, access, deletion, correction, and portability rights with respect to your personal data. CVC Secondary Partners does not sell personal data for monetary or other valuable consideration as defined under applicable law or share personal data for cross-context behavioral advertising. Note that while some of the personal data that we collect about you may be considered sensitive personal data, we process such information for only those purposes detailed in this Privacy Notice and as authorized by law. These rights are not absolute and are subject to certain exceptions.
If you or your authorized agent wishes to exercise any of the rights set out above, please contact compliance@glendower.com or call +442039477000. When a request is made, CVC Secondary Partners may verify your identity to protect your privacy and security. You may also have the right to appeal a decision about your consumer rights, which you can do by emailing compliance@glendower.com.
Other California Rights:
Do Not Track: California Law requires that we disclose how we respond to a “Do not track” (“DNT”) signal. We do not track visitors of this Website. If you access this Website through the Internet, your browser may allow you to adjust your browser settings so that DNT requests are sent to the websites that you visit. However, CVC Secondary Partners will not disable tracking technology that may be active on this Website in response to any DNT requests that we receive from your browser. To learn more about browser tracking signals and DNT, visit https://www.eff.org/issues/do-not-track. You can also consider using the opt-out features provided by the Digital Advertising Alliance by visiting the following website: http://www.aboutads.info/consumers.
Shine the Light: California residents have the right to request twice in the preceding 12 months, the categories of personal data we have collected, the reason we collect this personal data, where we obtained the personal data from and the third parties with whom we share the personal data with. We collect identifiers, characteristics of protected classifications under California or U.S. law, commercial information, Internet or other electronic network activity information, geolocation data, professional or employment-related information, audio, electronic, visual, or similar information, inferences drawn about you and other categories of personal data that relate to, describe or are reasonably capable of being associated with you.
Children
This Website is not directed to individuals under the age of sixteen (16) and we do not knowingly collect personal data of children under the age of sixteen (16). We also do not knowingly sell or share personal data of children under the age of sixteen (16) as those terms are defined under applicable laws. If you have reason to believe that a child under the age of sixteen (16) has provided personal data to us through this Website, please contact us and we will endeavor to delete that personal data from our database.
UPDATES TO THIS PRIVACY NOTICE
CVC Secondary Partners reserves the right to change or amend our Privacy Notice from time to time and at our discretion. In such event, we will post the changes in our Privacy Notice on this Website by referring to the date it was revised at the top of this page. If you are concerned about how your personal data is used, please visit this Website often for this and other important announcements and updates.
CONTACT DETAILS
You can opt out of receiving communications from us at any time. In addition, to the extent you have any questions about the processing of your information or wish to exercise any of the rights referred to above in relation to any of the data controllers specified in this Privacy Notice, please contact us at:
Glendower Capital, LLP
8 St. James’s Square, London
SW1Y 4JU, United Kingdom
Email: compliance @ glendower.com
FURTHER INFORMATION
You can also bring any issues or concerns you have regarding your personal data to the attention of the ICO which, for purposes of an investment in the Fund, will be the relevant supervisory authority in the UK.
Details regarding the ICO and its powers can be found at: www.ICO.org.uk.
Subject to applicable law, you may also have the right to lodge a complaint with a European data protection authority. A list of European data protection authorities can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Legal Basis for Processing
Contract. To provide you with our services, to fulfil a contract, or take steps linked to a contract (Art. 6(1)(b))
Processing Purpose
For Business contacts:
To administer any transaction that we enter into..
To manage our investments or potential transactions.
To seek and receive advice from our professional advisors, including accountants, lawyers and other consultants.
For Service providers and advisers:
To administer and maintain records of services or advice we have received and commissioning further services.
To seek and receive advice from our professional advisors, including accountants, lawyers and other consultants.
For Transaction related contacts:
To assess potential transactions.
To administer any transaction that we enter into.
To assess your suitability for involvement in a transaction, including by verifying your identity.
To seek and receive advice from our professional advisors, including accountants, lawyers and other consultants.
Categories of Personal Data
Business contacts, which includes their name, job title, employer organization, contact details and the content of communication.
Service providers and advisers, which includes their name, jobtitle, qualifications, employer organization and contact details.
Transaction related contacts, which includes their CV, details of their previous employment history, business profile and professional activities, information relating to their financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.
Compliance with law. Where it is required by the law (Art. 6(1)(c))
For Business contacts:
To safeguard our legal rights and interests, and to comply with law.
To comply with CVC Secondary Partners’ policies and procedures.
For Service providers and advisers:
To comply with our regulatory, tax and legal obligations, including assessing and managing risk.
To safeguard our legal rights and interests.
For Transaction related contacts:
To comply with our regulatory, tax and legal obligations, including assessing and managing risk.
To safeguard our legal rights and interests.
For Other individuals:
To comply with and enforcing applicable legal requirements, including, without limitation, with respect to compliance with ATCA and CRS (as well as any legislation, regulations or guidance enacted in any jurisdiction that seeks to implement a similar tax reporting or with holding tax regime), and relevant industry standards and CVC Secondary Partners policies.
To exercise and comply with CVC Secondary Partners’ rights and obligations at law or under regulation, or under contract, including for the establishment, exercise or defense of legal claims by or against CVC Secondary Partners.
To disclose information to a governmental, tax or regulatory body, financial market, broker or other intermediaries, counterparties, court, auditors or other third parties and to conduct compliance activities, when CVC Secondary Partners thinks this is in its, or someone else’s legitimate interests.
Business contacts, which includes their name, job title, employer organization, contact details and the content of communication.
Service providers and advisers, which includes their name, job title, qualifications, employer organization and contact details.
Other individuals, which includes their name and email address.
Our legitimate interests. Where it is necessary for the purposes of our legitimate interests (Art. 6(1)(f))
For Business contacts:
To maintain a record of contacts.
To invite you to presentations and events and organizing meetings between you and CVC Secondary Partners’ representatives.
For Transaction related contacts:
To maintain records of investments.
For Other individuals:
To fulfil requests or reply to inquiries made by the relevant individual.
To consider applications for employment.
To protect against, identifying and preventing fraud and other unlawful activity.
To help to detect, prevent, investigate, and prosecute fraud and/or other criminal activity.
To manage CVC Secondary Partners’ information technology and to ensure the security of the CVC Secondary Partners’ systems.
To manage and administer CVC Secondary Partners’ business and to improve relationships with investors and assist with investor relationship management, and for marketing and business development activities and analysis.
To investigate and respond to any complaints about CVC Secondary Partners or any incidents relating to CVC Secondary Partners.
Business contacts, which includes their name, job title, employer organization, contact details and the content of communication.
Other individuals, which includes their name and email address.
Consent. Where you have provided your consent (Art. 6(1)(a))
To provide periodic business updates and send promotional materials subject to regulatory permissions, and other communications.
Business contacts, which includes their name and contact details.
Transaction related contacts, which includes their name and contact details.
Other individuals, which includes their name and email address.
Third-Parties: This Website may provide links to other websites for convenience and information. These websites may operate independently from Glendower. Linked sites may have their own privacy notices or policies, which Glendower strongly suggests individuals to review. To the extent any linked websites are not owned or controlled by Glendower, Glendower is not responsible for their content, any use of the websites, or the privacy practices of the websites.
HOW GLENDOWER SHARES AND TRANSFERS PERSONAL DATA
It may be necessary for Glendower or associated third parties (including the parties to whom we disclose personal data in accordance with this Privacy Notice) to effect cross-border transfers of personal data, including to the United States of America and to other countries outside the European Economic Area (the “EEA”) or the United Kingdom (“UK”). The European Commission and the UK Information Commissioner have recognized that certain countries outside of the EEA or the UK ensure an adequate level of protection for personal data. Where a recipient of your personal data is located in a country deemed ‘adequate’ by way of an adequacy decision, Glendower will rely on the adequacy decision to transfer your personal data outside of your home country. In some cases, personal data may be transferred to jurisdictions outside of the EEA or the UK that are not deemed to have data protection frameworks that are equivalent to those of the EEA countries, such as the United States of America. Glendower uses data transfer agreements incorporating standard contractual clauses approved by the European Commission and the UK Information Commissioner to transfer personal data to such jurisdictions. You may request to see a copy of the adequacy decisions or a copy of the standard contractual clauses Glendower has in place by contacting us at the details below.
Such transfers may be to other Glendower entities, to governmental, regulatory or judicial authorities, auditors, legal advisors or agents as well as to sub-contractors engaged by Glendower.
RETENTION PERIODS
Glendower and those third parties to whom personal data is transferred will retain that data as long as is necessary for the purposes and based on the criteria set out in this Privacy Notice. In particular, Glendower will hold certain personal data and other information regarding investors in the Funds for at least as long as they remain investors (which will not typically exceed 12 years). The retention period may extend beyond the investment term where necessary for the relevant Fund’s legitimate interests, including to comply with legal or regulatory obligations or to facilitate the relevant Funds’ on-going administration and performance.
SAFEGUARDING OF PERSONAL DATA
The security of data is central to our business. We use reasonable technical, administrative, and physical security measures to reduce the risk of losing, unauthorized access to, or inadvertent destruction of your personal data. We train our employees to handle personal and business information in accordance with approved policies and procedures that we have established to ensure compliance with applicable laws and internal policies for protecting personal data.
You acknowledge that the transmission of information via the internet is not secure. We cannot guarantee the security of your data transmitted to our public website, any other site used by us and accessible by you or through electronic communications, and any transmission is at your own risk.
INDIVIDUAL RIGHTS
Individuals have certain legal rights in respect of their personal data. Subject to applicable law, you will have various rights in respect of the information relating to you. These include your right to:
If you wish to exercise any of the rights set out above, please use the contact details below. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity.
If you wish to exercise any of these rights and Glendower has transferred your data to a third party, Glendower will communicate such request to each relevant third party unless it would be impossible or involve disproportionate effort for Glendower to do so.
Notice to U.S. Residents
This section only applies to individuals who are residents of U.S. states with data protection laws.
Glendower collects the following categories of personal data, as described in more detail above: Identifiers, such as name, email address, or government-issued identifiers; Demographic information, such as age or gender; Financial information; Commercial information; Internet or other electronic network activity information, such as how you interact with this site and information about the websites who view before and after this site; Inferences drawn from any of the information above. The sources of this personal data include the consumer and publicly available sources on the Internet, including government entities. Without this personal data, we are not able to provide you with all the requested services.
Glendower collects and processes this personal data for the business purposes described above. These include: (i) to exercise and comply with Glendower’s rights and obligations at law or under regulation, or contract, including for the establishment, exercise or defense of legal claims by or against Glendower; (ii) to manage and administer Glendower’s business and improve relationships with investors, including providing advertising and marketing, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions; (iii) to undertake activities to verify or maintain the quality or safety of the service, including to help detect, prevent, investigate, and prosecute fraud and/or other criminal activity; (iii) to ensure security and integrity of the service, (iv) to investigate and respond to any complaints about Glendower or any incidents relating to Glendower.
As described above, depending on where you reside, you may be afforded certain disclosure, access, deletion, correction, and portability rights with respect to your personal data. Glendower does not sell personal data for monetary or other valuable consideration as defined under applicable law or share personal data for cross-context behavioral advertising. Note that while some of the personal data that we collect about you may be considered sensitive personal data, we process such information for only those purposes detailed in this Privacy Notice and as authorized by law. These rights are not absolute and are subject to certain exceptions.
If you or your authorized agent wishes to exercise any of the rights set out above, please contact compliance@glendower.com or call +442039477000. When a request is made, Glendower may verify your identity to protect your privacy and security. You may also have the right to appeal a decision about your consumer rights, which you can do by emailing compliance@glendower.com.
Other California Rights:
Do Not Track: California Law requires that we disclose how we respond to a “Do not track” (“DNT”) signal. We do not track visitors of this Website. If you access this Website through the Internet, your browser may allow you to adjust your browser settings so that DNT requests are sent to the websites that you visit. However, Glendower will not disable tracking technology that may be active on this Website in response to any DNT requests that we receive from your browser. To learn more about browser tracking signals and DNT, visit https://www.eff.org/issues/do-not-track. You can also consider using the opt-out features provided by the Digital Advertising Alliance by visiting the following website: http://www.aboutads.info/consumers.
Shine the Light: California residents have the right to request twice in the preceding 12 months, the categories of personal data we have collected, the reason we collect this personal data, where we obtained the personal data from and the third parties with whom we share the personal data with. We collect identifiers, characteristics of protected classifications under California or U.S. law, commercial information, Internet or other electronic network activity information, geolocation data, professional or employment-related information, audio, electronic, visual, or similar information, inferences drawn about you and other categories of personal data that relate to, describe or are reasonably capable of being associated with you.
Children
This Website is not directed to individuals under the age of sixteen (16) and we do not knowingly collect personal data of children under the age of sixteen (16). We also do not knowingly sell or share personal data of children under the age of sixteen (16) as those terms are defined under applicable laws. If you have reason to believe that a child under the age of sixteen (16) has provided personal data to us through this Website, please contact us and we will endeavor to delete that personal data from our database.
UPDATES TO THIS PRIVACY NOTICE
Glendower reserves the right to change or amend our Privacy Notice from time to time and at our discretion. In such event, we will post the changes in our Privacy Notice on this Website by referring to the date it was revised at the top of this page. If you are concerned about how your personal data is used, please visit this Website often for this and other important announcements and updates.
CONTACT DETAILS
You can opt out of receiving communications from us at any time. In addition, to the extent you have any questions about the processing of your information or wish to exercise any of the rights referred to above in relation to any of the data controllers specified in this Privacy Notice, please contact us at:
Glendower Capital, LLP
8 St. James’s Square, London
SW1Y 4JU, United Kingdom
Email: compliance@glendower.com
FURTHER INFORMATION
You can also bring any issues or concerns you have regarding your personal data to the attention of the ICO which, for purposes of an investment in the Fund, will be the relevant supervisory authority in the UK.
Details regarding the ICO and its powers can be found at: www.ICO.org.uk.
Subject to applicable law, you may also have the right to lodge a complaint with a European data protection authority. A list of European data protection authorities can be found at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Contract. To provide you with our services, to fulfil a contract, or take steps linked to a contract (Art. 6(1)(b))
For Business contacts:
To administer any transaction that we enter into..
To manage our investments or potential transactions.
To seek and receive advice from our professional advisors, including accountants, lawyers and other consultants.
For Service providers and advisers:
To administer and maintain records of services or advice we have received and commissioning further services.
To seek and receive advice from our professional advisors, including accountants, lawyers and other consultants.
For Transaction related contacts:
To assess potential transactions.
To administer any transaction that we enter into.
To assess your suitability for involvement in a transaction, including by verifying your identity.
To seek and receive advice from our professional advisors, including accountants, lawyers and other consultants.
Business contacts, which includes their name, job title, employer organization, contact details and the content of communication.
Service providers and advisers, which includes their name, jobtitle, qualifications, employer organization and contact details.
Transaction related contacts, which includes their CV, details of their previous employment history, business profile and professional activities, information relating to their financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out.
Compliance with law. Where it is required by the law (Art. 6(1)(c))
For Business contacts:
To safeguard our legal rights and interests, and to comply with law.
To comply with CVC Secondary Partners’ policies and procedures.
For Service providers and advisers:
To comply with our regulatory, tax and legal obligations, including assessing and managing risk.
To safeguard our legal rights and interests.
For Transaction related contacts:
To comply with our regulatory, tax and legal obligations, including assessing and managing risk.
To safeguard our legal rights and interests.
For Other individuals:
To comply with and enforcing applicable legal requirements, including, without limitation, with respect to compliance with ATCA and CRS (as well as any legislation, regulations or guidance enacted in any jurisdiction that seeks to implement a similar tax reporting or with holding tax regime), and relevant industry standards and CVC Secondary Partners policies.
To exercise and comply with CVC Secondary Partners’ rights and obligations at law or under regulation, or under contract, including for the establishment, exercise or defense of legal claims by or against CVC Secondary Partners.
To disclose information to a governmental, tax or regulatory body, financial market, broker or other intermediaries, counterparties, court, auditors or other third parties and to conduct compliance activities, when CVC Secondary Partners thinks this is in its, or someone else’s legitimate interests.
Business contacts, which includes their name, job title, employer organization, contact details and the content of communication.
Service providers and advisers, which includes their name, job title, qualifications, employer organization and contact details.
Other individuals, which includes their name and email address.
Our legitimate interests. Where it is necessary for the purposes of our legitimate interests (Art. 6(1)(f))
For Business contacts:
To maintain a record of contacts.
To invite you to presentations and events and organizing meetings between you and CVC Secondary Partners’ representatives.
For Transaction related contacts:
To maintain records of investments.
For Other individuals:
To fulfil requests or reply to inquiries made by the relevant individual.
To consider applications for employment.
To protect against, identifying and preventing fraud and other unlawful activity.
To help to detect, prevent, investigate, and prosecute fraud and/or other criminal activity.
To manage CVC Secondary Partners’ information technology and to ensure the security of the CVC Secondary Partners’ systems.
To manage and administer CVC Secondary Partners’ business and to improve relationships with investors and assist with investor relationship management, and for marketing and business development activities and analysis.
To investigate and respond to any complaints about CVC Secondary Partners or any incidents relating to CVC Secondary Partners.
Business contacts, which includes their name, job title, employer organization, contact details and the content of communication.
Other individuals, which includes their name and email address.
Consent. Where you have provided your consent (Art. 6(1)(a))
To provide periodic business updates and send promotional materials subject to regulatory permissions, and other communications.
Business contacts, which includes their name and contact details.
Transaction related contacts, which includes their name and contact details.
Other individuals, which includes their name and email address.
