Background

This Privacy Notice sets forth how Capricorn Private Investments Limited and its affiliates, together Controllers (referred to collectively as “Capricorn” “we”, “us” or “our”), collect and process certain Personal Data.

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Capricorn (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Capricorn or any other person in respect of an individual.

Capricorn is responsible for ensuring that it uses Personal Data in compliance with data protection laws.  We respect the privacy of individuals and we are committed to keeping Personal Data secure.

This Privacy Notice applies to non-public personal information of individuals outside our organisation with whom we interact, including but not limited to:

  • current, prospective and former investors and clients (collectively, “Investors”) and their personnel;
  • visitors to our website;
  • vendors and service providers; and
  • visitors to our offices.(together, “you”)

These policies may be changed at any time. Changes will be effective immediately upon posting onto our Website for internet users or provided to you if visiting our offices.

Your information

This Privacy Notice concerns the following categories of information that we collect about you when providing our products and services (together, the “services”) and includes information we receive through our Website.

Many of the services offered by Capricorn require us to obtain Personal Data about you in order to perform the services we have been engaged to provide.

Information that you provide to us will depend upon the nature of the services you are requesting though such information may include basic Personal Data (such as full name; job title; company name; company email address; business phone number; business address; city; postcode; country).

Information that we collect or generate about you includes a file with your client records and contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you; and details of site and marketing/communication preferences.

Information we may obtain from other sources includes:

Website –                  This will include information such as: number of people visiting our Website; pages visited; features used; how long they stay and the websites they are connecting from; collected on an aggregate basis on public areas of our Website, or on an individual basis on areas of our Website that require Website visitors to logon using and access code (e.g. user ID and/or password).

Cookies –                   When you visit our Website, cookies are used to collect information about the services that you use, and how you use them.

Anonymised data-In addition to the categories of Personal Data described above, we may also process further anonymized information and data that is not processed by reference to a specific individual.

How we use your information

Your Personal Data may be stored and processed by us for the following purposes:

  • to understand your needs and interests;
  • for the management and administration of our business including to improve the calibre of online information and services offered;
  • to assess your application for Capricorn services, where applicable;
  • to understand feedback on Capricorn services and to help provide more information on the use of the services quickly and easily;
  • to communicate with you in order to provide you with services or information about Capricorn or its services;
  • in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
  • for the administration and maintenance of databases storing Personal Data; or
  • for ongoing review and improvement of the information provided on our Website to ensure it is user friendly and to prevent any potential disruptions or cyber-attacks.

However when we use Personal Data we make sure that the usage complies with the law.  The law allows us and requires us to use Personal Data for a variety of reasons, including but not limited to the following:

  • in order to perform our contractual obligations;
  • where we have obtained your consent to use the information;
  • where we have legal and regulatory obligations that we have to discharge;
  • where we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • the use of your Personal Data as described is necessary for our legitimate business interests, such as:

–              allowing us to effectively and efficiently manage and administer the operation of our business;

–              maintaining compliance with internal policies and procedures;

–              monitoring the use of our copyrighted materials;

–              enabling quick and easy access to information on Capricorn services; and,

–              obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

We will take steps to ensure that the Personal Data is accessed only by our employees that have a need to do so for the purposes described in this Privacy Notice.

Disclosure of your information to third parties

We may share your Personal Data within the Capricorn Group for the purposes described above.  We may also share your Personal Data outside of the Capricorn Group for the following purposes:

  • with our affiliated companies or other trusted businesses or persons for the purpose of processing personal data on our behalf for the above stated purposes;
  • with our business partners. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
  • with third-party agents and contractors for the purposes of providing services to us (for example, our accountants, professional advisors, IT and communications providers). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Notice;
  • to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights; and
  • if we sell our business or assets or are acquired by a third party, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.

International transfers of personal data

Capricorn is a global business with customers and operations spread around the world. As a result we may collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

Where we transfer your Personal Data to a country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with European legal requirements.  In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

  • the country might be approved by the European Commission as offering an adequate level of protection for Personal Data (e.g. Israel is an approved country);
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
  • in other circumstances where the law may permit us to otherwise transfer your Personal Data outside Europe.

You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described below.

Security standards – how we safeguard your information

We work hard to ensure that our systems are secure and that they meet industry standards. Where appropriate, we employ firewalls, encryption technology, user authentications systems (e.g. passwords and personal identification numbers) to control access to systems and data. We will continue to assess new technology to evaluate its ability to provide additional protection for your Personal Data.

Access to our computer systems is controlled and restricted.  Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

As a condition of employment, Capricorn staff are required to follow all applicable laws and regulations, including in relation to data protection law.  Unauthorised use or disclosure of confidential client information by a Capricorn employee is prohibited and may result in disciplinary measures.

How long we keep your personal data

The length of time we will hold your Personal Data will vary and will depend on:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

Your rights

In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge.  These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third-party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Capricorn;
  • the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
  • the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed below.

Use of Cookies

A cookie is a small piece of information that an Internet site sends to a website visitor’s computer. In some cases, it is stored on the visitor’s computer’s hard drive. Cookies can save the visitor’s name, password, user-name, screen preferences and the pages of the site viewed by the visitor. Visitors may decline the Internet cookie by using the appropriate feature of their Web software, if available. Declining the Internet cookie may, however, interfere with a visitor’s ability to view certain content is this web site.

Contact Us

It is important to us at Capricorn to hear what visitors have to say about our Website or our services. If you have any questions and/or concerns for instance about the handling of your Personal Data, or want to let us know what you think, please contact us by

Email at:               info@capricorncapital.com

Address:              Second Floor, Malta House, 36-38 Piccadilly, London, W1J 0DP

We are usually able to resolve privacy questions or concerns promptly and effectively.  If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction.  Upon request, we will provide you with the contact information for that regulator.