DH privacy policy
DH Private Equity Partners takes privacy and the use of data obtained from third parties seriously and is committed to protecting personal information – such as names, contact details and ID information (“Personal Information”).
This Privacy Policy applies to all data including Personal Information that you may provide to us or we acquire through our day to day business which might involve acquiring Personal Information from groups of people we do not have a direct relationship with (such as individuals within corporate entities we deal with). It explains what we hold, why we hold it and how we use it.
We will ensure your Personal Information is handled in accordance with the law. The relevant law with effect from 25 May 2018 is the EU General Data Protection Regulation (which replaces the UK Data Protection Act 1998) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and all similar or related legislation relating to the processing of Personal Information and/or privacy applicable to us from time to time (together “Data Protection Legislation”).
We may amend our Privacy Policy from time to time but will not adversely change your rights without your consent. We will post any changes on this page of the website and, if the changes are significant, provide appropriate notification.
This notice was last revised in May 2018 to comply with the EU General Data Protection regulations.
When do we collect information
We collect Personal Information that you submit when you use our website or contact us online or by any other method including by telephone or when we meet. We may also collect information via research.
Data we collect and why we hold it
The type of Personal Information provided to us when you contact us is likely to include name and contact details (e.g. your address, email address and phone number) and may include ID documentation.
Investors/potential investors
In connection with an investment or possible investment by you (or an institutional investor or investment vehicle with which you are associated) in funds managed by DH, we collect and hold Personal Information including financial data, home address, phone number, email address as well as bank account details and, where such is needed in respect of our due diligence requirements or to satisfy anti-money laundering or other regulatory obligations, ID documentation.
Business Contacts
If you provide services to us or have another form of business dealing with us (a “Business Contact”) or are an employee of or otherwise engaged by a Business Contact, we may acquire Personal Information including financial data, home address, phone number and email address, bank account details and ID documentation (where such is needed in respect of our due diligence requirements or to satisfy anti-money laundering or other regulatory obligations).
Management and employees of our Portfolio Companies
When we acquire a business we may obtain some Personal Information about the employees and other staff who work in the business.
Job Applicants
Job applicants may provide Personal Information which also includes details of their previous employment and we may seek references and carry out checks with third parties if appropriate for the role applied for.
Our Staff and their connected persons
Members of our staff may provide Personal Information which also includes details of their next of kin for emergency planning or in case of an incident at work. We may also ask for details of their dependants, spouses or other individuals in relation to employee benefit arrangements. We only ever use the information for the benefit of our staff and for the purpose provided.
Why we need to hold Personal Information
Some of the Personal Information identified above, is collected and processed so we can perform contracts we have with you, some for legal and regulatory compliance purposes and some for other legitimate business interests (for instance so we can carry on and improve our business, correspond with you for business purposes, process investor subscriptions and transfers, analyse the use of our website, carry out effective recruitment and support our staff and investors). We may use the Personal Information to keep investors updated on investments made by the funds managed by us, inviting them or their representatives to our AGMs and to provide updates on our general business.
How and why we may share your information
From time to time we may share your Personal Information with third parties where such is needed to perform a contract we have with you (or a related Business Contact) or a function for you (or a related Business Contact) or to enable a service to be provided to us (e.g. companies/suppliers that process data on our behalf such as cloud service providers). Other third parties we may share your Personal Information with include our professional advisors such as auditors and lawyers and fund depositaries or fund administrators. By providing your Personal Information to us you acknowledge that such third parties may receive and process such information.
We may also be obliged to disclose your Personal Information if we are under a duty to do so to satisfy our legal and regulatory obligations (e.g. our anti-money laundering/tax reporting obligations), carry out an internal investigation, enforce an agreement we have with you (or a related party) or to protect the rights, property or safety of our staff or investors. This may involve providing information for the purposes of fraud protection and prevention.
In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the European Economic Area (“EAA”) to third party service providers. Your Personal Information may also be accessed by staff operating outside the EEA who work for one of our suppliers. This includes people engaged in, amongst 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 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, in the event 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.
Security and Retention
We take security seriously and have industry standard security measures in place to protect your data. This includes firewalls, password protection, access control and encryption where necessary.
We regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to our systems.
We keep Personal Information only as long as necessary and dependent on the purpose for which we collected it. We regularly review our retention policy and will remove Personal Information unless required to keep it for legal reasons or to satisfy our own internal requirements.
Your Rights and Data accuracy
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 or regulatory obligations or because it is necessary to hold the same to perform our business arrangements with you). Where relevant, we will also ensure that our group companies amend or erase your personal information.
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 transfer any information we hold about you to a specified third party.
Please ensure that any personal information you provide 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.
If at any point you would like to access, review, update or request us to remove your personal data then please contact via email at the email address below. You will need to provide sufficient information to confirm your identity so we can deal with your request appropriately.
Contact us and Complaints
If you have any questions or concerns about the way in which we have handled your Personal Information, please contact us at privacy@dhpep.com. Alternatively you have the right to make a complaint to the Information Commissioner’s Office, the supervisory body in the UK.