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.

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.

Cookies

Cookies are small text files, typically made up of words and numbers, that are placed on the device you are using by websites that you visit. Cookies do a variety of useful jobs and are widely used in order to make websites work, or work more efficiently and provide information to the owners of the site.

This website contains analytical cookies which enables Google Analytical software to work. We use Google Analytics to collect information that helps us to accurately calculate the number of visitors to our website and to see how these visitors move around the site when they are using it.

These cookies may collect the IP address of your device but do not collect or store personal information that can identify you as a visitor. This information can only be seen by the relevant teams at Palamon Capital Partners and Google and never shows any confidential information.

The data collected by these cookies is anonymous and is used to improve how our website works and the services we offer to our customers.

Cookies we use

At Palamon Capital Partners, we use the following four Google Analytical performance cookies:

  • -utma This enables us to ascertain the number of unique visitors to our site and is updated with each page view. The cookie remains in existence for a period of 2 years either from initial creation or a subsequent update.
  • -utmb This cookie is used to establish and continue a user session on our site. Each time a user visits a different page this cookie updates for a further 30 minute period. The cookie then remains in existence for a further 30 minutes, either from initial creation or a subsequent update.
  • -utmc This cookie operates in conjunction with the -utmb cookie to determine whether or not to establish a new session for the user. The cookie remains in existence until you have closed your browser.
  • -utmz This cookie stores the type of referral used by the visitor to reach your site, whether via a direct method, a referring link, a website search, or a campaign such as an ad or an email link. It is used to calculate search engine traffic, ad campaigns and page navigation within your own site. The cookie is updated with each page view and expires 6 months from initial creation or a subsequent update.

For more information about the cookies used by Google Analytics:
https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

Managing Cookies

Most web browsers will allow some management of cookies via your browser settings. For further information about managing cookies, please visit www.aboutcookies.org.

For further information about cookies, please visit
www.allaboutcookies.org

Keeping You Informed

We wish to build a long-term relationship with you and would like to use personal information that we hold to send you updates about our business, activities and opportunities to work together. We would usually do this by email and/or post. You can opt out of receiving updates at any time by clicking the “Unsubscribe” link in any email you receive.

Retention of personal information

The period for which Palamon 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.

Your rights to see and correct data

As a ‘Data Subject’ you have a number of important rights:

  • to access your personal information;
  • to request that it is erased;
  • that its processing is restricted to the purpose for which it was given and;
  • that any inaccurate personal information is rectified.

In the first instance please contact the Data Protection Officer at privacy@palamon.com. Please note that these rights are subject to some statutory qualifications. You also have the right to complain about the use of their personal information to the Information Commissioner’s Office (www.ico.org.uk).

Security

We will take all reasonable steps to protect the confidentiality and security of your personal information, but cannot guarantee the security of any that you disclose online for example when it is sent by email. You accept the inherent security risks of providing information online over the Internet and will not hold Palamon responsible for any breach of security unless this is due to Palamon's negligence or wilful default.

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.