Privacy notice

Inflexion Private Equity Partners LLP Privacy Notice

Inflexion recognises that the correct and lawful treatment of personal data will maintain confidence in the organisation and will help support successful business operations. Protecting the confidentiality and integrity of personal data is a critical responsibility that Inflexion takes seriously at all times.

For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended, (“Data Protection Laws”), the Inflexion group entity (in most cases Inflexion Private Equity Partners LLP) that you have dealings with is the controller of your personal information. Inflexion has a Data Protection Team who are contactable by email at privacy@inflexion.com.

Personal information: business contacts

If you have interacted with Inflexion, whether through email, meeting someone from Inflexion, or otherwise, we may keep limited amounts of your personal information. This might include your name, job title, employer organisation and contact details. We do this for the purposes of:

providing business updates (further described below);
maintaining a list of contacts; and
asking you along to events such as presentations or organising meetings between you and Inflexion’s representatives.

In accordance with Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in running and promoting our business. Whilst Inflexion does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.

The length of time such personal information will be held by Inflexion will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.

Personal information: actual or potential management teams

If you are involved in a transaction that Inflexion and/or the funds that it advises enters into, or a potential transaction that Inflexion is contemplating, we may keep certain limited amounts of your personal information.

This might include information relating to your financial status and dealings, your CV, details of your previous employment history and professional activities, your nationality (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence we may have conducted. We collect and store this information for the purposes of:

evaluating potential transactions;
keeping records of assets and investments;
assessing your suitability for involvement in a transaction, including by verifying your identity;
meeting with our regulatory/legal obligations, including assessing and managing risk;
administering any transaction that we are involved with;
safeguarding our own legal rights and interests;
receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
providing business updates (further described below).

As required under Data Protection Laws, our legal basis for collecting and storing such personal information is that such processing is necessary for our legitimate interests in running our business, in particular in order to properly review potential investments, and administering any and all transactions that we are party to. In addition, Inflexion may be required to obtain and hold personal information (such as passports and other key identifying documentation) so as to comply with money laundering and related regulation and in order to conduct satisfactory ‘Know Your Client’ checks.

For any matter or transaction that you are involved in, it may also be necessary for us to process your personal information for performing that transaction and to comply with our relevant regulatory/legal duties. Whilst Inflexion does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.

In certain limited circumstances personal information may be received by Inflexion from a third party, for example a recruiter. In such circumstances it will be held in accordance with this Notice and Data Protection Law. The length of time such personal information will be held by Inflexion will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.

Please note that Inflexion has carefully considered and balanced the rights and interests of its data subjects and does not believe such rights and interests have been overridden by Inflexion’s own interests. In making this assessment, Inflexion has considered the nature of all such data subject’s interests, any impact of processing and the relevant safeguards that have been put in place.

Personal information: suppliers and professional advisors

We will store limited amounts of personal information relating to suppliers to Inflexion, or one of Inflexion’s professional advisors. This may include names, job titles, qualifications, employer organisations and contact details. This personal information will be stored for the purposes of managing and preserving records of services or advice we have received and authorising further services.

In accordance with the Data Protection Laws, 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. Whilst Inflexion does not routinely obtain consent as the legal basis upon which it stores and processes personal data, it will, if necessary, and to the extent required by Data Protection Laws, obtain the consent of the data subject to hold and process personal information. If consent is provided, it can be withdrawn by the data subject at any time.

The length of time such personal information will be held by Inflexion will depend on why it was collected initially. The requirements of applicable laws or regulations will also affect this.

Mailing lists

As part of our marketing activities, Inflexion collects and use personal information to provide updates on our activities and to issue invitations to events we host. We don’t rent or trade email lists with other organisations and businesses.

Inflexion uses third-party providers, MailChimp and Campaign Monitor, to deliver its updates and issues events. Inflexion gathers statistics around email opening and clicks using industry standard technologies to help us monitor and improve the e-newsletter. For more information, please see the privacy policy of MailChimp and Campaign Monitor. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of Inflexion’s emails or by emailing privacy@inflexion.com.

Inflexion will take all reasonable steps to maintain the accuracy of your personal information. Where necessary, it will keep it up to date. You can request that Inflexion update or correct any information by contacting Inflexion at any time by emailing privacy@inflexion.com.

The Inflexion website may offer the opportunity to “connect” site content via the social network LinkedIn. If you are a member of LinkedIn and do not want the social network cookies to be placed on your system, Inflexion suggests that you refrain from using such sharing tools.

Information via the Inflexion website

This Notice also applies to how Inflexion controls, processes, handles and protects your personal information while browsing or using Inflexion’s website (www.inflexion.com), including your rights under current laws and regulations. Inflexion uses this information to provide you with a better service, and, in particular, for the following reasons:

to provide answers to your questions asked via the website;
to improve the content of the website;
to understand visitor behaviour patterns to improve the website; or
to respond to your media queries about us.

Inflexion’s websites may contain hypertext links to external websites. Inflexion is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

Inflexion uses cookies on its website to provide a better user experience. Inflexion does this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that are displayed, to keep you logged into the website where applicable, to display relevant adverts or content. Some cookies are required to enjoy and use the full functionality of this website.

Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options. Most web browsers allow some control of most cookies through the browser settings.

If you are not familiar with cookies, you can find more detailed information about deleting and controlling them here https://www.aboutcookies.org.

For the current list of cookies that the Inflexion website uses, please view our Cookie Policy. 

Google Analytics

When someone visits the Inflexion website, Google Analytics, collects standard internet log information and details of visitor behaviour patterns.  This is done to find out things such as the number of visitors to the various parts of the website.

This information is only processed in a way which does not identify anyone. Inflexion does not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. For more information, please see Google Analytics privacy notice. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

LinkedIn

The Inflexion website may offer the opportunity to “connect” website content via the social network LinkedIn. Social networks such as this almost always use cookies. If you are a member of LinkedIn and do not want the social network cookies to be placed on your system, we suggest that you refrain from using such sharing tools.

LinkedIn: https://www.linkedin.com/legal/pop/pop-privacy-policy

Mandatory provision of information

You will be notified when the provision of particular information is mandatory, including the possible consequences of not providing particular information. This may include, for example, preventing us from proceeding with a transaction involving you. Inflexion will only process the personal information you provide to Inflexion for the purposes listed above. In particular, Inflexion may be required to obtain and hold personal information (such as passports and other key identifying documentation) so as to comply with money laundering and related regulation and in order to conduct satisfactory ‘Know Your Client’ diligence checks.

Sensitive or special category personal data

Please be aware that different rules apply to data concerning certain sensitive categories, including 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. All such categories are deemed to be either sensitive or special category personal data. We kindly ask you not to send us such information.

Third-parties

Inflexion will not sell, distribute or lease your personal information to third parties unless Inflexion has your permission or are required by law to do so.

What are your rights?

If Inflexion holds your personal information you may be entitled to access it. Additionally, you may be able to request that it is deleted or that any processing of it is limited. You may request that any inaccurate personal information is corrected. If you wish to make any such request (or if you wish to object to the processing of your personal information or obtain a copy of it) you should submit it by email to the Data Protection Team (privacy@inflexion.com).

You also have the right to complain about the use of your personal information to the relevant Supervisory Authority. In the UK this is the Information Commissioner’s Office (www.ico.org.uk). Inflexion is registered with the ICO under the Data Protection Register, with registration number: ZA153072.

Personal information: international transfers

Due to the international nature of Inflexion’s operations, any personal information that we hold may be transferred to, and stored at, a country outside of your country of residence. This could include countries outside of the EEA, such as the U.S. and Brazil. To the extent we transfer personal information outside of the EEA, we will ensure such transfers comply with the Data Protection Laws. This may include entering into data transfer agreements with recipients.

Business updates

We may use personal information that we hold to send you periodic updates about Inflexion’s business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us (see “Inflexion Data Privacy Contacts” below), or by clicking the “Unsubscribe” link in any email that you receive.

Accuracy and security

Inflexion 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 Inflexion responsible for any breach of security unless this is due to Inflexion’s negligence or wilful default.

For all queries, please do not hesitate to email privacy@inflexion.com. You can also make enquires in writing by contacting the Data Protection Team at Inflexion’s registered office, which is listed on the website. Inflexion may update this Notice periodically and such changes will be notified to the website.

August 2022