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Privacy Policy


In this policy, “Equistone”, “we” and “our” refer to Equistone Partners France SAS, a société par actions simplifiée with share capital of €4,000,000, whose registered office is located at 43-45 avenue Kléber, 75016 Paris, France, registered with the Paris Trade and Companies Register (RCS) under number 379 716 699, and the funds managed by us (the “Funds”).


Equistone is committed to protecting personal data, such as names, contact details and identity document data (the “Personal Information”), which are provided to us or which we otherwise obtain in relation to any individual (“you”), including our clients, investors, any other individual with whom we interact and any visitor to the website www.equistone.fr (the “Website”). Any Personal Information collected will be processed in accordance with the Data Protection Legislation (as defined below). Please read this Privacy Policy carefully, as it explains how we process and protect your personal data.

We will use Personal Information only where it is provided to us or otherwise obtained by us in accordance with this Privacy Policy. We will ensure that your Personal Information is processed in compliance with the “Data Protection Legislation”, meaning any applicable law relating to the processing of Personal Information and/or privacy, including, without limitation, (i) French Data Protection Act No. 78‑17 of 6 January 1978 as amended, (ii) the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and (iii) the 2002 ePrivacy Regulation.


By browsing the Website, contacting us through the Website, or otherwise interacting with us (for example in the context of investor relations), you acknowledge that we may collect, use and transfer your Personal Information as described in this Privacy Policy. Equistone may amend this Privacy Policy from time to time; therefore, we invite you to review it regularly to ensure that any changes are acceptable to you. Equistone and each of the Funds act as “data controllers” within the meaning of the Data Protection Legislation when processing Personal Information relating to you.

This Privacy Policy governs:



1. PERSONAL INFORMATION WE COLLECT FROM YOU


When you contact us (for example by email, telephone, by browsing the Website or submitting a request via the Website), you may provide us with Personal Information relating to you, including your name and contact details (for example your email address and telephone number). When you use the Website, we may also, where you have consented, collect information about such use (such as your IP address and browser information).


Certain Personal Information is collected and processed to enable us to perform a contract with you; other Personal Information is processed to comply with our legal or regulatory obligations; and other Personal Information is processed on the basis of our legitimate interests (namely, to operate our business and improve our processes, analyse the use of our Website and services, or provide support to our teams and clients). Each time we carry out a processing activity, we will inform you of the specific legal basis applicable to that processing.


If you apply for a position with us, we may collect from you, and where applicable and to the extent permitted by law from third parties, Personal Information such as your CV and references. If your application is unsuccessful, unless you consent to our retaining such information for future opportunities, or unless we must retain it to comply with legal obligations, we will retain such Personal Information only for as long as necessary to review your application.

Where you provide us with Personal Information on behalf of another person, you undertake to inform that person that you have provided us with their Personal Information and to direct them to this Privacy Policy so that they may understand how their Personal Information will be processed.



2. PERSONAL INFORMATION WE RECEIVE FROM THIRD PARTIES


We may receive Personal Information relating to you from third parties. This may occur where: (i) key personnel of third‑party companies provide information when we conduct due diligence on potential targets to decide whether to invest; (ii) our teams provide us with information about emergency contacts and may provide data relating to family members or beneficiaries for insurance purposes; (iii) where a person invests on your behalf, they may provide us with your Personal Information to enable the transfer of the investment to you (such as your name and contact details); (iv) your employer may provide us with your Personal Information in connection with services it provides to us or services we provide to our clients; and (v) we may receive information from former employers about your past experience when you apply for a role with us and you have expressly authorised us to contact them.


In such circumstances, the third party is solely responsible for providing you with the information it must provide regarding the transfer of your Personal Information, and must refer you to this Privacy Policy and obtain any necessary consent to ensure that you consent to our processing of your Personal Information. Once we are in possession of your Personal Information, we will process it only in accordance with this Privacy Policy.



3. HOW WE USE YOUR PERSONAL INFORMATION


We use your Personal Information only for the purposes of: (a) managing our relationships with our investors and providing you with support in connection with our services; (b) improving our Website and services; (c) complying with our legal and regulatory obligations, including in relation to financial promotion, anti‑money laundering and counter‑terrorist financing, the Common Reporting Standard and FATCA; and (d) our internal processes, including supporting our teams and analysing potential investment targets.


Where you have expressly consented at the time of collection of your Personal Information, or where we are otherwise permitted to do so, we may also use your Personal Information to inform you by email about services we believe may be of interest to you and/or about important changes or developments relating to our services.


Where you and/or your employer (or any other entity for which you work) provide services to us, you and/or they may provide us with Personal Information in connection with the provision of such services, such as your name, professional contact details and other identity information. We will process such Personal Information only for the purpose of receiving and managing the services (for example, using your contact details to communicate with you about the service) and in accordance with this Privacy Policy. Where necessary, we may also share your Personal Information with our investors or third parties in order to provide our services (for example, where you or your company provides investor administration services, we may share your professional contact details with our investors so that they may contact you).


If you no longer wish us to use your Personal Information as described in this Privacy Policy, please inform us by email at: diane.vignalou@equistone.fr. You may also opt out of receiving unsolicited marketing emails by following the instructions provided in such emails or by contacting: diane.vignalou@equistone.fr.



4. HOW WE SHARE YOUR PERSONAL INFORMATION



Where necessary for the performance of a contract with you or for our internal processes, we may share your Personal Information with third parties such as our fund administrators and depositaries, as well as other professional advisers, service providers, regulatory authorities, auditors, IT providers and any duly authorised agents, or any companies related to, associated with or affiliated with the foregoing, for the same purposes.


By providing us with your Personal Information, you acknowledge that these third parties may receive and process your Personal Information. We require all such third parties to process your Personal Information securely and in accordance with this Privacy Policy and we will take all reasonable steps to ensure compliance with these obligations. We will never sell your data.


In addition, we may disclose your Personal Information where we are required to do so to comply with legal obligations (such as anti‑money laundering and counter‑terrorist financing requirements), to conduct internal investigations, to enforce the Website terms and conditions or any other contract, or to protect the rights, property or safety of Equistone, the Funds or our clients, directors, employees or other personnel. This may involve exchanging information with other companies and organisations for the purposes of detecting or preventing fraud. In particular, to comply with the Common Reporting Standard and FATCA, Personal Information may be disclosed to the tax authorities of the jurisdiction in which the relevant Fund is domiciled. Those authorities may in turn exchange information (including Personal Information and financial information) with foreign tax authorities (including outside the EEA).


Exceptionally, if we are sold to or merged with another entity, we may disclose your information to a potential acquirer, including your Personal Information and other information relating to your relationship with us, so that it may continue to provide services to you.



5. SECURITY MEASURES AND RETENTION OF PERSONAL INFORMATION


We retain your Personal Information only for as long as it is necessary for our purposes and, in any event, only for the period permitted by the Data Protection Legislation.


Unfortunately, the transmission of information over the internet is not completely secure and, although we take appropriate measures to protect your Personal Information, we cannot guarantee the security of Personal Information transmitted via the Website; any such transmission is therefore at your own risk.


Video surveillance may be in place in our premises for security purposes.



6. TRANSFERS OF PERSONAL INFORMATION OUTSIDE THE EEA


All Personal Information provided to Equistone will be transferred to and stored on the servers of OVHcloud in France. We implement appropriate security measures to protect your Personal Information against unauthorised or unlawful access, accidental loss, destruction or damage.


When processing your Personal Information, it may sometimes be necessary to transfer your Personal Information outside the European Economic Area (“EEA”) to our teams or third‑party service providers.


Where Personal Information is transferred to countries outside the EEA, we will ensure that one of the following safeguards is in place:


If you would like further information regarding the safeguards we apply to transfers of Personal Information outside the EEA, please contact Diane Vignalou by email at diane.vignalou@equistone.fr.



7. YOUR RIGHTS


In accordance with the Data Protection Legislation, you have the right of access, rectification and erasure of your Personal Information; the right to object to or restrict the processing of your Personal Information; the right to data portability; and the right to set instructions regarding the handling of your personal data after your death.


Right to be informed: You have the right to receive clear, transparent and understandable information about how we use your Personal Information and about how to exercise your rights. This is why we provide the information in this Privacy Policy.


Right of access: You have the right to obtain a copy of your Personal Information.


Right to rectification: You have the right to have your Personal Information corrected if it is inaccurate or incomplete.


Right to erasure (the “right to be forgotten”): You have the right to request the erasure of your Personal Information. However, this right is not absolute and is subject to specific conditions. We may retain your Personal Information to the extent permitted by applicable law, in particular where processing remains necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.


Right to restriction of processing: You have the right to obtain restriction of processing in certain circumstances (for example, where we no longer need your personal data but it is still required for the establishment, exercise or defence of legal claims).


Right to data portability: In certain circumstances, you have the right to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine‑readable format and to transmit it to another controller.


Right to object: You have the right to object to certain types of processing (for example, where processing is based on the legitimate interests of the controller).


Right to withdraw consent: Where you have given consent to the processing of your Personal Information, you have the right to withdraw it at any time.


Right to set instructions regarding your data after death: You may set instructions regarding the retention, erasure and communication of your personal data after your death. Such instructions may be general or specific. General instructions may be registered with a trusted third party; specific instructions may be recorded with the controller.



8. COMPLAINTS


If you have any questions or complaints regarding the use of your Personal Information, please contact Diane Vignalou (diane.vignalou@equistone.fr).


You also have the right to lodge a complaint with the French data protection authority (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France. Tel: +33 (0)1 53 73 22 22.


Our Website may contain links to third‑party websites. If you follow such links, please note that those websites have their own privacy policies and we are not responsible for such websites or their policies. We recommend that you check those policies before providing any Personal Information via those websites.



9. CHANGES TO THIS PRIVACY POLICY


Equistone may amend this Privacy Policy at any time, subject to providing reasonable prior notice where required. We invite you to refer to it regularly.



10. CONTACT


For any questions (including regarding transfers of your Personal Information outside the EEA), you may contact Diane Vignalou (diane.vignalou@equistone.fr).