Last updated: July 15, 2022
OUR COMMITMENT TO PRIVACY
Your privacy is important to Patient Square Capital, L.P. and its affiliates (together, “Patient Square,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information to explain our personal data handling practices.
- relating to visitors of this website;
- in connection with our current and future investments in businesses which operate in, or have a connection to, the EU and/or UK; and
We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data (e.g., name, email, IP address, financial data, etc.), including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Further information about the legal bases under which we process your personal data is included in the section headed “Why we use your personal data.”
HOW WE OBTAIN YOUR PERSONAL DATA
Information you provide to us
Information provided by third parties or publicly available sources
We collect personal data from third parties, such as background information from a background check provider, personal data we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions.
If you represent or work for one of our portfolio companies, we may also collect your personal data (i.e., basic identifying and contact information, including your [name, title, work email address, work postal address, job title and/or work telephone number], as appropriate) from the entity that you work for where this is necessary to conduct business, or manage our relationship, with such third party.
We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).
WHY WE USE YOUR PERSONAL DATA
To the extent that you provide us with any personal data, or we otherwise collect your personal data (i.e., through or in connection with this website, our current and future portfolio companies and other data collection points) we may use such information for the following purposes:
|To conduct business with you or provide you with the services you have requested.||Contractual necessity; and/or our legitimate interest in operating our business and providing investment services.|
|To communicate with you.||Our legitimate interest in operating our business and providing investment services.|
|To keep a record of your relationship with us.||Our legitimate interest in operating our business and providing investment services; and/or legal requirement.|
|To verify your identity (including to conduct anti-money laundering checks and to enable you to access our offices).||Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely.|
|To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.||Our legitimate interest in operating our business and providing investment services; contractual necessity; and/or legal requirement.|
|To protect against, identify and prevent, fraud, money-laundering, cyber attacks, theft of our property and other unlawful activity.||Legal requirement; our legitimate interest in operating our business and providing investment services securely.|
|Litigation management and conducting internal audits and investigations.||Legal requirement; our legitimate interest in operating our business.|
|To obtain advice from our professional advisors, including financial advisers and lawyers.||Our legitimate interests in operating our business.|
|To administer and protect our business and this website.||Our legitimate interest in operating our business.|
|To make suggestions and recommendations to you, or to provide you with updates or other information, about our business and services that may be of interest to you.||Our legitimate interest in operating our business.|
Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.
No solely automated decision-making, including profiling, is used when processing your personal data.
DISCLOSURE AND TRANSFER OF PERSONAL DATA
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this website; any transmission of information or data by you to or through this website is at your sole risk.
Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including legal and financial professional advisors, our auditors, consultants, administrators, placement agents, IT and data security providers and/or data hosting providers. We seek assurances that our standards for data security are met by anyone who enters into an agreement providing a service to, or for us. To the extent your personal data is transferred to countries outside of the UK or the European Economic Area, such transfers will only be made in accordance with the EU and UK Privacy Laws. For further information about the safeguards/derogations used, please contact [email protected].
We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL DATA
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate data security technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access, disclosure, improper use, and accidental loss. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and required to keep your personal data secure.
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that information.
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You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.
You may refuse to accept cookies by altering the settings on your internet browser. For more information about how to do this, look at your browser ‘help’ section or visit www.allaboutcookies.org and www.youronlinechoices.eu. You can also opt out of using Google Analytics cookies here http://tools.google.com/dlpage/gaoptout. Please note that if you adjust your internet browser settings to refuse the setting of cookies, you may not be able to access or use fully certain parts or functionality of the website.
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact [email protected].
- Access: You have the right to ask for a copy of the personal data that we hold about you free of charge. However, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to your personal data if it is inaccurate or it needs to be updated.
- Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer the personal data that we hold and process about you on the legal ground of contractual necessity to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
NOTIFICATION OF CHANGES
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us. In the EU, this is the local supervisory authority in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.