Privacy Policy (E.U & U.K)
Atwater Capital L.P respects your privacy and is committed to protecting your personal information. This privacy notice will inform you as to how we look after your personal information and tell you about your privacy rights and how the law protects you. This notice applies to you only if are located in the United Kingdom, a member state of the European Union or the European Economic Area.
This privacy notice is provided in a format so that you can click the arrows throughout to reveal further detail. Please also use the following table contents to navigate to the specific areas set out below. Alternatively, you can download a pdf version of the full privacy notice.
Employees, contractors and other personnel of Atwater-Capital.com should note that a separate privacy notice will be made available to them.
IMPORTANT INFORMATION
DATA PROTECTION PRINCIPLES
PERSONAL INFORMATION WE HOLD ABOUT YOU, PURPOSES AND LAWFUL BASIS FOR PROCESSING
Visitors to Atwater-Capital.com’s website
Visitors to Atwater-Capital.com’s offices
Individuals with whom Atwater-Capital.com has contact for business purposes
Individuals who are associated with Atwater-Capital.com’s suppliers, vendors or professional advisers
Individuals who are involved in transactions or potential transactions by or on behalf of Atwater-Capital.com
Individuals who are associated with shareholders in Atwater-Capital.com in the United States
Individuals with whom Atwater-Capital.com has contact during a recruitment process
COOKIES
DATA SHARING
DATA SECURITY
DATA RETENTION
YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
1. IMPORTANT INFORMATION
Atwater-Capital.com respects your privacy and is committed to protecting your personal information.
This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).
It applies to:
individuals with whom Atwater-Capital.com may have had contact for business purposes, either on our own account or on behalf of third parties or organisations;
individuals who are employed by or otherwise associated with Atwater-Capital.com’s suppliers, vendors or professional advisors;
individuals who are involved in transactions or potential transactions which are evaluated or conducted by Atwater-Capital.com or any of Atwater-Capital.com’s sub-advisors;
individuals with whom Atwater-Capital.com has contact during a recruitment process; and
individuals who have opted to receive communications from Atwater-Capital.com.
Atwater-Capital.com makes available separate privacy notices on the Investor Center here which apply to individuals associated with investors in the funds operated by Atwater-Capital.com. This privacy notice does not form part of any contract of services.
This website is not intended for children and we do not knowingly collect data relating to children.
About Atwater-Capital.com
This privacy notice is issued on behalf of the Atwater-Capital.com Group so when we mention “Atwater-Capital.com”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant entity in the Atwater-Capital.com Group responsible for processing your personal information.
Unless otherwise specified, the designated contact entity in relation to Atwater-Capital.com matters in the EU and EEA is Atwater-Capital.com You may contact us at dataprivacyofficer@Atwater-Capital.com.com or via the contact details listed for the relevant country below.
For the purposes of the GDPR, the Atwater-Capital.com company that you have dealings with is the controller of your personal information, for further details of which, please click below as appropriate. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the GDPR to notify you of the information contained in this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Team at dataprivacyofficer@Atwater-Capital.com.com or using the details set out below for the country relevant to you.
You have the right to make a complaint at any time to the relevant data protection authority (for details of which please click below). We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.
If you have dealings with Atwater-Capital.com in the United Kingdom, please click here for further details.
If you have dealings with Atwater-Capital.com in the Republic of Ireland, please click here for further details.
If you have dealings with Atwater-Capital.com in Luxembourg, please click here for further details.
If you have dealings with Atwater-Capital.com in Spain, please click here for further details.
If you have dealings with Atwater-Capital.com in France, please click here for further details.
If you have dealings with Atwater-Capital.com in Germany, please click here for further details.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.
2. DATA PROTECTION PRINCIPLES
We will comply with applicable data protection law. This says that the personal information we hold about you must be:
used lawfully, fairly and in a transparent way;
collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
relevant to the purposes we have told you about and limited only to those purposes;
accurate and to the extent appropriate, kept up to date;
kept only as long as necessary for the purposes we have told you about; and
kept securely.
3. PERSONAL INFORMATION WE HOLD ABOUT YOU, PURPOSES AND LAWFUL BASIS FOR PROCESSING
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are more sensitive types of personal data which require a higher level of protection, known as ‘special categories’ of personal data under the GDPR. We do not collect any ‘special categories’ of personal data about you except in the context of dietary requirements for events and meetings and limited health data to assist in the control of infectious diseases (such as the virus Covid-19) that you voluntarily provide to us. We do not collect any information about criminal convictions and offences, unless revealed by due diligence conducted to comply with a legal or regulatory obligation, transactional due diligence or as part of our recruitment processes.
Please click on the relevant section to see the categories of personal information about you that we collect, store, and use, the purposes of processing and our lawful basis for doing so.
Visitors to Atwater-Capital.com’s website
Visitors to Atwater-Capital.com’s offices
Individuals with whom Atwater-Capital.com has contact for business purposes
Individuals who are associated with Atwater-Capital.com’s suppliers, vendors or professional advisers
Individuals are who are involved in transactions or potential transactions by or on behalf of Atwater-Capital.com
Public shareholders in Atwater-Capital.com & Co. Inc. and investors
Individuals with whom Atwater-Capital.com has contact during a recruitment process
Lawful basis for using your personal information
If you fail to provide personal information
Change of purpose
4. COOKIES
Managing Cookies
The help menu of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies completely. Additionally, you can disable or delete similar data used by browser extensions by changing the extension’s settings or visiting the website of its manufacturer. However, if you disable cookies, you may experience reduced functionality and, for sites using cookies for authentication, declining cookies will prevent you from using the website altogether.
To learn more about what cookies are set on your computer as you browse the Web and how to manage or delete them, visit www.allaboutcookies.org.
Performance
We want to ensure that our websites provide a good experience. These cookies (which are set by third parties providing services to us) allow us to monitor how visitors use our Site. These cookies provide us with anonymous statistics on how many people visit the Site and where they have come from and the pages they visit so that we can continue to develop and improve the Site and our services. They also help us understand the effectiveness of our advertising.
Third party
Description
Google Analytics
Collects statistical information about how you use the site so that we can improve the site http://tools.google.com/dlpage/gaoptout
Functionality
These cookies allow you to set and store preferences for the Site, such as when you login to post comments or where you are offered the option to customize elements of the layout or content of the Site.
Third party
Description
AddThis
Provides easy social media bookmarking http://www.addthis.com/privacy/opt-out
Refusing or withdrawing your consent to the use of cookies
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.
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 Site.Updates to this policy
So that we can offer you the best possible online experience, new services using cookies may be added to our site from time to time. We aim to keep the cookies information provided here as accurate as possible and use all reasonable efforts to regularly review and update the details. When we update these details we will post changes on this page or on other pages of our Site or let you know about changes in our communications with you.
5. DATA SHARING
We seek to share your personal information with third parties only where we believe it is necessary or consistent with our legitimate interests, including to third-party service providers and other companies in the Atwater-Capital.com Group.
We require third parties to respect the security of your personal information and to treat it in accordance with the law. We use a range of third parties from time to time to provide a wide range of services, including telecoms, IT, courier, HR, security, legal, accountancy, data, and catering services.
We transfer your personal information outside the European Economic Area and when we do, you can expect a similar degree of protection in respect of your personal information.
Why do we share your personal information with third parties?
How secure is your personal information with third-party service providers and other companies in our group?
When do we share your personal information with other companies in the Atwater-Capital.com Group and with Atwater-Capital.com Capstone companies?
When do we share your personal information with any other third parties?
Transferring your personal information outside Europe
6. DATA SECURITY
We have put in place appropriate security measures to protect personal information.
Third parties will only process your personal information held by us where they are obliged to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to access it.
They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
7. DATA RETENTION
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with your personal information
Under certain circumstances, under applicable data protection law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact us via email at dataprivacyofficer@Atwater-Capital.com.com or via the other methods set out above.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Your right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us via email at dataprivacyofficer@Atwater-Capital.com or via the other methods set out above. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.