Where used in this Policy, “AAC” means AAC Capital Partners Holding B.V., or any of its subsidiaries or related companies. This Policy is based on the EU General Data Protection Regulation (“GDPR”), as amended or supplemented from time to time.
Personal information of business contacts
If you have had contact with AAC, for example through emailing us or meeting an AAC representative, we may store limited amounts of personal information relating to you, such as your name, job title, employer organization and contact details. We will collect and store this personal information for the purposes of:
The personal information we hold about business contacts may be shared with:
In accordance with GDPR, our legal basis for collecting and storing 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
If you are a supplier to AAC, or one of its professional advisors, we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organization and contact details. We will store this personal information for the purposes of:
The personal information we hold about suppliers and professional advisors may be shared with:
In accordance with GDPR, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business.
Personal information of actual and potential management teams
If you are involved in a transaction that AAC and/or the funds that it manages or advises enters into, or a potential transaction that AAC 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), reference provided by third parties, and results of due diligence carried out. We collect and store this information for the purposes of:
The personal information we hold about actual or potential management teams may be shared with:
In accordance with GDPR, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running our business, in particular by considering potential divestments, and administering transactions that we enter into. If we enter into a transaction that you are involved in, it will also be necessary for us to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.
Personal information in relation to Limited Partners
The personal details of all our Limited Partners who directly or indirectly participate in all Funds managed by AAC, are held and maintained in AAC’s Register as well as by AAC’s fund administrator. Limited Partner information is collected and maintained on our behalf for the purposes of:
The personal information we hold about Limited Partners may be shared with:
In accordance with GDPR, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and operating our business and ensuring effective communications with Limited Partners.
Mandatory provision of information
Upon request we will explain to you when the provision of particular information is mandatory. AAC will only process the personal information you provide to AAC for the purposes listed above.
Sensitive or special category personal data
Since we do not register race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are called sensitive or special category personal data - you are requested not to provide us such data.
Periodic business updates
We may use personal information that we hold to send you periodic updates about AAC’s business, activities and opportunities, in particular, by email and by post. You can opt out of receiving updates at any time by contacting us on the following email address: email@example.com.
Retention of personal information
The period for which AAC 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.
Upon request AAC will provide an overview of all personal data that we keep. You may request AAC to erase your data, which request will be fulfilled unless there are compelling reasons, such as fiscal obligations, not to do so. Any such request should be submitted in writing to the following email address: firstname.lastname@example.org.
Accuracy and security
AAC will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that AAC holds about you is incorrect, please notify AAC (email@example.com).
AAC will take all reasonable steps to protect the confidentiality and security of your personal information, but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the internet and will not hold AAC responsible for any breach of security unless this is due to AAC’s negligence or willful default.
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