Privacy Notice
Palamon Capital Partners LP (“Palamon”) respects the privacy of every individual whose personal information it handles. This Privacy Notice explains how Palamon collects, stores and uses that personal information and sets out our approach to the General Data Protection Regulation and UK laws such as the Data Protection Act.
Business Contacts
As a part of its day to day operations Palamon meets large numbers of business contacts at meetings and receives emails about investment opportunities. It is likely to receive and store personal information on those it meets.
If you have had contact with Palamon, for example through emailing us or meeting a colleague, it is likely that we will want to make a note of that email or meeting and may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details.
We will collect and store this personal information for the purposes of:
maintaining a record of contacts;
providing periodic business updates;
drawing to your attention working opportunities which may be of mutual benefit to us as described below; and
organizing meetings with you;
The personal information we hold about business contacts may be shared with:
companies who hold or ‘process’ personal information on our behalf.
professional advisors;
other companies in the Palamon group.
The legal basis for collecting and storing such personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.
Palamon Capital Partners, LP employs third party suppliers to provide services including utilising the services of a credit reference agency (https://www.callcredit.co.uk/legal-information/bureau-privacy-notice).
Personal information of suppliers and professional advisors
As a part of its day to day operations Palamon is likely to receive and store personal information to enable it to buy office and other supplies or engage with professional advisors.
If you are a supplier or professional advisor to Palamon, we will capture and use 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 administering and maintaining records of services or advice we have received, and commissioning further services.
The personal information we hold about suppliers and professional advisors may be shared with:
companies who hold or ‘process’ personal information on our behalf.
professional advisors;
other companies in the Palamon group.
We store and process information in this way because it is necessary to:
perform a contract to which you are likely to be a party;
comply with a legal or regulatory obligation; and/or
protect our legitimate interests in running and promoting our business.
Personal information collected during a transaction
Palamon is likely to receive and store personal information as part of its investment evaluation process.
If you are involved in a transaction that Palamon and/or the funds that it manages or advises enters into, or a potential transaction that Palamon considers, we may store personal information relating to you. This might include your CV, 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, and results of other due diligence carried out.
We collect and store this information for the purposes of:
evaluating a transaction and your role in it;
executing transactions;
managing an investment once made;
maintaining records of investments;
meeting regulatory and legal obligations eg KYC checks;
safeguarding our legal rights and interests;
seeking and receiving advice from our professional advisors, including accountant’s lawyers and other consultants; and
providing periodic business updates, as described below
The personal information we hold about the members of a management team teams may be shared with
professional advisors, such as accountants, lawyers or other consultants;
financial intermediaries;
credit and other reference agencies;
other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Palamon transaction, including co-investors, other providers of finance and investors in Palamon’s funds;
companies who hold or ‘process’ personal information on our behalf;
other companies in the Palamon group.
We store and process information in this way because it is necessary to:
perform a contract to which you are likely to be a party;
comply with a legal or regulatory obligation; and/or
protect our legitimate interests in running and promoting our business.
Mandatory provision of information
In some cases we will not be able to deal with you further without receiving certain information – eg ‘Know Your Customer’ information. In such circumstances we will explain this to you including the possible consequences of not providing particular information. In any event Palamon will only process the personal information you provide to Palamon for the purposes listed above.
Sensitive or special category personal data
Palamon avoids wherever possible receiving information on race, religion, political views and your mental or physical health.
International transfers of personal information
Palamon is based in Europe and does not anticipate transferring your personal data outside the EEA.
Where we transfer personal information to 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 using the information below.
Questions and further information
If you have any questions about this please email Data Protection Officer at privacy@palamon.com.
Changes to Palamon's Privacy Policy
Any changes to this Privacy Policy will be posted here.