27 Feb 2018
About this notice
Unless otherwise indicated, this notice applies to the activities of Platina Partners LLP, Platina Energy Partners LLP and Platina Equity Solutions SAS (together ‘Platina’) in their capacity as data controllers as defined by the General Data Protection Regulation (‘GDPR’).
Who we are
Platina collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and any related UK legislation and Financial Conduct Authority regulations and we are responsible as ‘controller’ of that personal information for the purposes of those laws. The relevant Platina entities are listed below:
- Platina Partners LLP (company registration number OC332872), a limited liability partnership having its registered office at c/o DMH Stallard (0594), 6 New Street Square, New Fetter Lane, London EC4A 3BF, UK;
- Platina Energy Partners LLP (company registration number OC366952), a limited liability partnership having its registered office at c/o DMH Stallard (0594), 6 New Street Square, New Fetter Lane, London EC4A 3BF, UK; and
- Platina Equity Solutions SAS (company registration number 502381056 RCS Paris), a French limited liability company registered at 32 rue la Boetie, 75008 Paris, France.
The personal information we collect and use
Information collected by us
In the course of our activities as a fund manager and investment adviser we may collect the following personal information:
- Contact details such as your name, address, e-mail address and telephone numbers;
- Where required, additional personal details such as your date of birth, citizenship, professional status and background;
- Where required, financial details such as your Tax Identification Number and tax residency and your bank account details;
- Where we and/or third party requestors are required by law to conduct anti-money laundering checks, copies of proof of identity and address and other information necessary for this purpose;
- Where you apply for a position with Platina, information about your experience and education.
Information collected from other sources
We may also obtain personal information from other sources as follows:
- Publicly available sources:
- The relevant Companies Registry (Companies House in the UK and its equivalents in other countries);
- Charity Registers (the UK Charities Commission and equivalent registers in other countries;
- Reputable third party websites and publications;
- Professional networking sites such as LinkedIn as well as other social media sites.
- Professional advisors
How we use your personal information
We use your personal information to:
- Carry out our business as a fund manager and investment adviser
- Provide you with information relevant to your relationship with us
- Communicate with you in relation to your investment
- Communicate with you in relation to your job application
- Draft any agreements to which you are a party
- Contact you to see if you are interested in becoming an investor and/or to make you aware of any services and products which may be of interest to you
- Respond to any requests you make through our website
- Carry out Know Your Customer (‘KYC’) checks in compliance with Anti-Money Laundering and FCA regulations
- Respond to KYC requests by third parties as appropriate
- Comply with legal and regulatory obligations
- Updating our internal records
- Statutory returns
- Ensuring safe practices in the working environment, staff administration and assessments
Who we share your personal information with
We routinely share your personal data with third parties, as is necessary in the course of our business. Such third parties may include accountants, auditors, tax advisers, lawyers, background checking companies, other professional services providers and banks. Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.We will share personal information with law enforcement or other authorities if required by applicable law.
Whilst Platina’s IT providers have the capacity to access any data held on our systems, contractual safeguards are in place to ensure that your personal data are kept confidential. Platina uses a third party provider for offsite storage and scanning services, however, any personal details stored are protected by contractual safeguards.
Whether information has to be provided by you, and if so why
The provision of your personal data as applicable to your relationship with us is required from you to enable us to carry out our activities as a fund manager and investment adviser and to communicate with you, as well as to comply with legal and regulatory obligations. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
How long your personal information will be kept
We will hold your personal data for no longer than is required under relevant legislation and/or regulatory rules, or than is necessary for the purposes set out in this notice.
Personal data received by or contained in e-mails will be stored in Mimecast for a period of ten years in compliance with Financial Conduct Authority regulations.
Reasons we can collect and use your personal information
We rely on (i) legal obligations, (ii) contractual obligations, (iii) your consent and (iv) our legitimate interests as the lawful basis on which we collect and use your personal data.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are the interests of enabling Platina to carry out its business as a fund manager and investment advisor.
Transfer of your information out of the EEA
We may transfer your personal information to countries outside the European Economic Area (EEA) only where it is required to comply with legal and regulatory obligations, or where this may be necessary to meet our contractual obligations to you.
This may be necessary if, for example, your and/or our services providers are located outside of the EEA, or if you are based outside of the EEA.
These transfers are subject to special rules under European and UK data protection law.
We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
If you would like further information, please contact us (see ‘How to contact us’, below).
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us using the details set out at the end of this notice.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used, or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Third party links
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may change this privacy notice from time to time, when we do we will inform you via e-mail.
How to contact us
- By email to email@example.com; or
- By mail to the Legal & Compliance Team, Platina Partners LLP, Berkeley Square House, Berkeley Square, London W1J 6BD; or
- By calling +44 (0) 20 7042 9600.