Bregal Investments takes privacy and its use of your data seriously and acknowledges the importance of protecting any personal information – such as names, contact details and ID information – hereafter called "Personal Information" that it holds.
We will ensure that your Personal Information is handled in accordance with the law. The relevant law here is: (i) the UK Data Protection Act 2018, (ii) the EU General Data Protection Regulation, (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (iv) the French Data Protection Act and (v) all similar or related legislation relating to the processing of Personal Information and/or privacy applicable to Bregal Investments from time to time (together the "Data Protection Legislation").
The "data controllers" (as defined in the Data Protection Legislation) in respect of your personal information will be Bregal Investments LLP with registration number OC318320.
1. USE OF YOUR PERSONAL INFORMATION
1.2 What sort of Personal Information do we collect?
When contacting us online, via telephone, in writing or otherwise you may provide Personal Information about yourself to us including your name and contact details (e.g. your address, email address and telephone number).
1.2.2 Information submitted when you apply to work at Bregal Investments
If you apply for or enquire about working for us (as an employee or an intern) we may also ask you to provide details such as your previous job title, your employment history, a copy of your CV and references and information relating to your right to work. We may also seek references and carry out checks with third parties if appropriate for the role you have applied for. This processing is justified either by our legitimate interests to carry out effective recruitment or it is necessary for us to comply with our legal obligations.
1.2.3 Information about those related or otherwise connected to our staff
We sometimes ask members of our staff to provide details of their next of kin for the purpose of our emergency scenario planning or in case an incident occurs at work. We may also ask for details of their dependents, spouses and/or other people in relation to their employee benefits arrangements. We will only ever use this information for the benefit of our staff and only when justified by our legitimate interest to support our staff.
1.2.4 Information about management and employees at our portfolio companies
When we acquire a business, we will obtain some information about the employees and other staff who work in that business to carry out and improve our business in the pursuit of our legitimate interest.
1.2.5 Information about investors/potential investors/those who work for or are connected with investors
If you (or an institutional investor or investment vehicle with which you are associated) consider investing with us, you may also provide us with your financial information and various other necessary Personal Information. This processing will be justified by the performance of a contract concluded with you, or for the purpose of corresponding with you for business purposes, providing any support you may require or to process an investment application in accordance with our legitimate interests. In certain circumstances, we may also process your Personal Information for the purpose of complying with our KYC-AML obligations.
1.2.6 Information about individuals who are our suppliers or other business contacts (and individuals who are employed by our suppliers and business contacts)
If you provide services to us or have a business dealing with us (or are employed or engaged by an entity which provides services or has a business dealing with us), we may acquire your name, contact details, some employment information and we may acquire copies of ID documents or similar information, for the purpose of corresponding with you, carrying out and improving our business and analysing the use of our website and services in the pursuit of our legitimate interests. In certain situations, for example, if you are a director at a business, we are required under our legal obligations to conduct due diligence or carry out anti-money laundering processes.
2. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
2.1 We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation and our own internal rules and policies allow.
3. YOUR RIGHTS AND DATA ACCURACY
3.1 You have certain rights in relation to your Personal Information – for example the right to request that we erase your Personal Information (or part thereof) at any time, which request we will comply with unless we have a lawful reason to keep your information (for example, to comply with our legal obligations). Where relevant, we will also ensure that our group companies amend or erase your Personal Information (as applicable). Please contact us at the email address set out below if you wish to request any changes.
3.2 You also have the right, subject to certain exemptions, to: (a) see the Personal Information we hold about you and withdraw any consent you may have given to us; (b) to ask us to make any changes to ensure that any Personal Information we hold about you is accurate and up to date; and (c) in some cases communicate any information we hold about you to a specified third party. In certain jurisdictions, you have the right to provide instructions on the processing of personal data after your demise. If you wish to exercise any of these rights, please contact us at the email address set out below.
3.3 Please ensure that the Personal Information you provide via the website is accurate and complete and you notify us of any changes to your Personal Information as soon as possible so that we can update our records.
3.4 Whilst we will take all reasonable steps to protect your Personal Information, we cannot guarantee the security of any Personal Information you disclose online. You accept the inherent security implications of disclosing Personal Information online.
4. HOW AND WHY WE SHARE YOUR PERSONAL INFORMATION
4.1 Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties who reasonably need it in order to perform a function for you or provide a service to us – such as our group fund(s), the funds' administrator, and our other group companies and our advisers. By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We will never sell your data.
4.2 In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as anti-money laundering obligations), carry out an internal investigation, enforce any agreement we have with you or with a related party, or protect the rights, property or safety of Bregal Investments, its group companies and/or our clients, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.
4.3 In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the European Economic Area ("EEA") to our staff and our third party service providers. It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to our non-European offices and to third parties based outside the EEA in accordance with the Data Protection Legislation. We may enter into contracts with entities based outside the EEA, where this is required by the Data Protection Legislation – and a copy of such contracts will be available to you on written request to the email address below (subject to certain redactions and/or an undertaking from you to respect the confidentiality of that contract). For the avoidance of doubt, now that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.
5.1 When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. We use two types of cookies on our website: (a) strictly necessary cookies and (b) analytics cookies. Because we respect your right to privacy, you can choose not to allow some types of cookies, please click on the cookie banner pop-up on the home page to find out more and change our default settings. Strictly necessary cookies are always ‘Active’ and analytics cookies are defaulted to ‘Active’, if you wish to turn the analytics cookies off, you can do so by unticking ‘Active’ saving within the Analytics tab on the Cookie Settings. Please be aware that by blocking some types of cookies it may impact your experience of the site and the services we are able to offer.
In particular, we use the following cookies:
- bregal_consent – This is stored when (if) a user accepts the analytics cookie.
- _ga – Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
- _gat – Used by Google Analytics to throttle request rate.
- _gid – Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
- mf_[website-id] – Used by Mouseflow to identify the current session on a website.
- mf_user – Used by Mouseflow to identify if a user is new or returning.
(a) Strictly necessary cookies*. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
(b) Analytics cookies**. These are Google Analytics and Mouseflow cookies which allow us to count visits and traffic sources so we can measure and improve the performance of our site. Information is derived both from website traffic which helps us to know which pages are the most and least popular and see how visitors move around the site and social media platforms. All information these cookies collect is aggregated and therefore anonymous. These cookies are turned on by default but the user can deactivate them by clicking onto Cookie Settings.
We may also use banners and pop-ups from time to time to give you options around cookies use.
6. AGGREGATED DATA
To enable us to monitor and improve this website, we may gather and record on our servers certain aggregated data about you when you use it, including without limitation, the URL that you came from and go to and the parts of our website that you visit. Such aggregated data is primarily used to provide you with an enhanced online experience and will not include any Personal Information.
Bregal Investments may amend this Policy at any time. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the website. Any changes to this Policy will be posted on the website.
8. CONTACT US AND COMPLAINTS
8.1 You can opt out of receiving communications from us at any time by sending an email to email@example.com or by contacting our Legal Team at the following address: Michelin House, 81 Fulham Road, London SW3 6RD.
8.2 If you have any questions or concerns about the way in which we have handled your Personal Information, please contact us at the email address above. Alternatively you have the right to make a complaint to the Information Commissioner's Office, the supervisory body in the UK, or to one of the competent European supervisory authorities.