The “controller” (as defined in the Data Protection Legislation) of your Personal Information will be the member or members of the Bridgepoint group with which you interact, including Bridgepoint Group plc (with company registration number 11443992), Bridgepoint SAS (with company registration number 380223313), Bridgepoint Advisors Limited (with company registration number 03220373 ), Bridgepoint Advisers II Limited (with company registration number 06824647), Bridgepoint Credit Limited (with company registration number 10517902) and Bridgepoint Fund Management Services Sarl (with company registration number A00003619).
1. USE OF YOUR PERSONAL INFORMATION
1.1. We may collect and receive (and use for the purposes set out in this Privacy Policy) your Personal Information in the following ways: (i) information that you provide to us when you make use of this website or in connection with an activity to which this Privacy Policy is linked (for example, when you register with us, respond to online surveys or contact us either online or by any other method); (ii) information that we collect automatically (for example, details of your visit to our website, including your IP address and choice of web browser); and (iii) information that we receive from third parties or from publicly available sources (for example, the organisations with which you are affiliated and from public databases and websites, including social media platforms).
1.2. What sort of Personal Information do we collect?
1.2.1. General
When contacting or corresponding with us online, via telephone, in writing or otherwise you may provide Personal Information including your name, contact details and interests. You may also provide us with Personal Information about your preferences for receiving marketing communications and, when you attend one of our events, about your dietary requirements. We will process this Personal Information in order to enter into and perform contracts with you, to pursue our legitimate interests (e.g. of operating and improving the websites, developing and improving our business, conducting marketing activities, ensuring the safety and security of our employees and visitors, preventing and investigating unlawful activity or unauthorised use of Personal Information and our website, and enforcing our terms of use and other agreements), to comply with our legal and professional obligations and, where required by the Data Protection Legislation, with your consent.
1.2.2. Information about management and employees at our portfolio companies
When we acquire a business, we will obtain Personal Information about the employees and other staff who work in that business. We will process this Personal Information in order to pursue our legitimate interests (e.g. of growing and operating our business and investments).
1.2.3. Information about shareholders/potential shareholders/those who work for or are connected with shareholders
If you (or an institutional shareholder or shareholding vehicle with which you are associated) consider becoming a shareholder in Bridgepoint, we may receive Personal Information about you and other individuals at your organisation. We will process this Personal Information in order to pursue our legitimate interests (e.g. of operating our business, including by communicating with current, prospective and former shareholders).
1.2.4. Information about investors/ potential investors/ those who work for or are connected with investors
If you (or an institutional investor or investment vehicle with which you are associated) consider investing with us, you may also provide us with your financial information and various other necessary Personal Information. This processing will be justified by the performance of a contract concluded with you, or for the purpose of corresponding with you for business purposes, providing any support you may require or to process an investment application in accordance with our legitimate interests. In certain circumstances, we may also process your Personal Information for the purpose of complying with our KYC and AML obligations.
1.2.5. Information about individuals who are our suppliers or other business contacts (and individuals who are employed by our suppliers and business contacts)
If you provide services to us or have a business dealing with us (or are employed or engaged by an entity which provides services or has a business dealing with us), we may acquire Personal Information including your name, contact details, employment information and copies of ID documents or similar information. We will process this Personal Information in order to enter into and perform contracts with you (where you are an individual or sole trader) and to pursue our legitimate interests (e.g. of for the purpose of corresponding with you and operating our business). In certain situations, such as where you are a director at a business, we may be legally required to conduct due diligence or carry out KYC and AML checks.
You may be asked to provide some of the Personal Information referred to in this Privacy Policy for one or more of the purposes described above. If you fail to provide this Personal Information when requested, and the information is necessary for Bridgepoint to comply with its legal or contractual obligations under applicable law, we may not be able to meet the obligations placed on us. In all other cases, the provision of your Personal Information is voluntary.
1.2.6. Information about employees and job applicants
If you are an employee or job applicant, please refer to the relevant privacy notice accessible in the course of your interactions with Bridgepoint.
2. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
2.1. We will only keep your Personal Information for as long as necessary to fulfil the purposes for which we collected or received it, including to satisfy any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information and the purposes for which we process your Personal Information and whether we can achieve those purposes through other means.
3. YOUR RIGHTS AND DATA ACCURACY
3.1. You have certain rights in relation to your Personal Information – for example the right to request that we erase your Personal Information (in part or in full) at any time, which request we will comply with unless we have a lawful reason to keep your information (for example, to comply with our legal obligations). Where relevant, we will also ensure that our group companies amend or erase your Personal Information (as applicable). Please contact us at the email address set out below if you wish to exercise these rights.
3.2. You also have the right, subject to certain exemptions, to: (a) obtain a copy of the Personal Information we hold about you and withdraw any consent you may have given to us; (b) ask us to make any changes to ensure that any Personal Information we hold about you is accurate and up to date; (c) restrict or object to the processing of your Personal Information; and (d) in some cases send the Personal Information we hold about you to a specified third party controller. In certain jurisdictions, you have the right to provide instructions on the processing of Personal Information after your demise. If you wish to exercise any of these rights, please contact us at the email address set out below.
3.3. Please ensure that the Personal Information you provide to us is accurate and complete and that you will notify us of any changes to your Personal Information as soon as possible so that we can update our records.
3.4. Whilst we will take all reasonable steps to protect your Personal Information, we cannot guarantee the security of any Personal Information you disclose online. You accept the inherent security implications of disclosing Personal Information online.
4. HOW AND WHY WE SHARE YOUR PERSONAL INFORMATION
4.1. Where it is necessary for the performance of our contract with you or in order to pursue our legitimate interests (e.g. of running our business), we may share your Personal Information with our group companies and other third parties who reasonably need it in order to perform a function for you or provide a service to us – such as IT hosting and support, email delivery and database management services. By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We will never sell your Personal Information.
4.2. In addition, it may be necessary to share your Personal Information in order to comply with any legal or regulatory obligation (such as anti-money laundering obligations), carry out an internal investigation, enforce any agreement we have with you or with a related party, or protect the rights, property or safety of Bridgepoint, its group companies and/or our clients, directors, employees or other personnel. This includes exchanging Personal Information with other companies and organisations for the purposes of fraud protection and prevention.
4.3 We may also share your Personal Information with auditors, advisers, law enforcement bodies or to other entities for the purpose of establishing or defending our legal rights, complying with the law or carrying out an internal investigation.
4.4 Lastly, we may share your Personal Information in connection with a corporate reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital, including in connection with any bankruptcy or similar proceedings.
4.5 It will sometimes be necessary for us to transfer your Personal Information outside the European Economic Area (“EEA”) and/or the United Kingdom (“UK”) to our staff, our service providers and other third parties. Alternatively or in addition, your Personal Information may be accessed by staff operating outside the EEA/UK who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will ensure that your Personal Information is treated in accordance with this Privacy Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from a location outside the EEA/UK. In order to do so, we may enter into contracts with entities based outside the EEA/UK, where this is required by the Data Protection Legislation – and a copy of such contracts will be available to you on written request to the email address below (subject to certain redactions and/or an undertaking from you to respect the confidentiality of that contract).
5. MARKETING AND INDUSTRY UPDATES
5.1. Where you have expressly consented to receive from us or we otherwise have the right to send to you marketing materials, event invitations and/or industry updates we will use your Personal Information to do this (whether in hard copy or by email).
5.2. You can opt out of receiving these sorts of communications from us at any time by: (i) contacting us at the email address below; (ii) clicking the unsubscribe/“opt-out” button at the bottom of each email; or (iii) where the materials are sent by post, sending us a cancellation request to the address included in the materials.
