External Privacy Notice
(A) This Notice
This Notice is issued by each of the Controller entities listed in Section (O) below (together, “Novator”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including investors, services providers, and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (P) below.
This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.
(B) Collection of Personal Data
We collect or obtain Personal Data about you from the following sources:
- Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
- Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
- Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
- Site data: We collect or obtain Personal Data when you visit any of our Site or use any features or resources available on or through a Site.
- Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).
(C) Creation of Personal Data
We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your purchase history.
(D) Categories of Personal Data we Process
We Process the following categories of Personal Data about you:
- Personal details: given name(s); preferred name; and photograph.
- Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
- Contact details: correspondence address; telephone number; email address; details of personal assistants, where applicable; messenger app details; online messaging details; and social media details.
- Financial/transaction information: including, but not limited to, income, assets, investments, savings, start and end dates of investments, investment income charges on assets, shareholdings, tax date, participation in a stock option plan, ownership of all types of assets.
- Compensation: details of compensation, amounts paid, other kind of compensation.
- Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
- Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
- Data relating to our Site device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; aggregate statistical information.
- Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
(E) Sensitive Personal Data
We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
- Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
- Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
- Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or
- Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
(F) Purposes of Processing and legal bases for Processing
| Summary – Purposes of Processing and legal bases for Processing |
| We Process Personal Data for the following purposes: providing our services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our services; fraud prevention; and recruitment and job applications. |
The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
| Processing activity | Legal basis for Processing |
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(G) Disclosure of Personal Data to third parties
We may disclose Personal Data to other entities within the Novator group, for legitimate business purposes and the operation of our Site, or services to you), in accordance with applicable law. In addition, we disclose your Personal Data to:
- you and, where appropriate, your appointed representatives;
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- accountants, auditors, lawyers and other outside professional advisors to Novator, subject to binding contractual obligations of confidentiality;
- your co-investors, co-shareholders, investment partners and directors, employees, officers, direct and indirect shareholders, ultimate beneficial owners or any such other entity or persons (in Luxembourg/London or any other location) to whom you direct or allow us to disclose personal information;
- our information technology service providers and consultants located in London/Luxembourg for hosting, back-up, and maintenance, IT security and IT support purposes;
- third party Processors (such as payment services providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties; and
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
We expect you to inform us in writing and without undue delay of changes in the information you provided to us or others about you, so that we can keep it up to date.If you provide us with personal information not relating to you (e.g. information about your respective representatives, staff members and agents, beneficial owners, shareholders, etc. or about any third party), you must first inform them about this fact and make sure they acknowledge that we can use such information as set out in this Notice. In particular, you must provide them with the information relating to their rights as Data Subjects. We assume that these third parties are informed of the Processing of any personal information relating to them that we may carry out in accordance with this Notice, including the disclosure of the same to third parties and countries as described in it and that, as far as necessary, you obtained these Data Subjects‘ prior written consent.
(H) Transfer of Personal Data
Depending on the nature and scope of the service requested from us, we may transfer Personal Data abroad to the extent that such transmission is deemed reasonably necessary or desirable for satisfying the purposes mentioned in section (G) above, including outside of the European Union/European Economic Area, to countries not recognised by the European Commission as having an adequate level of protection for personal information.
Personal Data may be sent to, or accessed from, any country where:
- it is necessary or useful in the context of our services;
- we travel (since we can access our files remotely through mobile devices or using a secure virtual private network);
Depending on the circumstances, all such transfers will be made:
- in countries which have been granted an adequacy decision by the European Commission;
- according to appropriate safeguards (i.e. the entry into EU Commission approved data protection clauses with the data importer or, in respect of transfers to the United Sates, to Privacy Shield self-certified entities);
- as necessary for the performance of the contract we have with you or for the implementation of pre-contractual measures taken at your request;
- if necessary for the conclusion or performance of a contract concluded in the interests of you between the Controller and another natural or legal person;
- if necessary for important reasons of public interest or for the establishment, exercise or defence of legal claims; or with your explicit consent.
(I) Data security
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
(J) Data accuracy
We take every reasonable step to ensure that your Personal Data that we Process are accurate and, where necessary, kept up to date, and any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
(K) Data minimisation
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.
(L) Data retention
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:
| (1) we will retain Personal Data in a form that permits identification only for as long as: |
| (a) we maintain an ongoing relationship with you; or |
| (b) your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g. where we have a legal obligation to retain your Personal Data), |
| plus: |
| (2) the duration of: |
| (a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and |
| (b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim), |
| and: |
| (3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim. |
During the periods noted in paragraphs (2)(a)and (2)(b)above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2)and (3)above, each to the extent applicable, have concluded, we will either permanently delete or destroy the relevant Personal Data or anonymize the relevant Personal Data.
(M) Your legal rights
| Summary – Your legal rights |
| You may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights. |
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
- the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our services, if you do not provide us with your Personal Data);
- the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
- the right to request rectification of any inaccuracies in your Relevant Personal Data;
- the right to request, on legitimate grounds:
- erasure of your Relevant Personal Data; or
- restriction of Processing of your Relevant Personal Data;
- the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
- where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
- the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:
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This does not affect your other statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (O)below.
(N) Direct marketing
We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our other services, and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional emails at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any services you have requested.
(O) Details of Controllers
For the purposes of this Notice, the relevant Controllers are:
| Controller entity | Contact details |
| Novator Partners LLP | 25 Park Lane, London, W1K 1RA |
| Novator (Luxembourg) S.à.r.l | 16 Avenue de la Gare, L-1619, Luxembourg |
(P) Definitions
- “Controller”means the entity that decides how and why Personal Data are Processed.
- “Cookie” means a small file that is placed on your device when you visit a website (including our Site). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
- “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- “EEA” means the European Economic Area.
- “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
- “Process”, “Processing” or “Processed”means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- “Processor”means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
- “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
- “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
- “Site” means any website operated, or maintained, by us or on our behalf.
(Q) Ethical Conduct Policy
Novator has a zero tolerance policy to bribery and corruption, money laundering, tax evasion and the facilitation of tax evasion, and any other form of illegal or unethical business conduct, and this policy is fully endorsed by our partners and senior management. We are fully committed to complying with all legislation and applicable guidelines designed to prevent bribery and corruption, money laundering, tax evasion and the facilitation of tax evasion, and any other form of illegal or unethical business conduct in the jurisdictions in which we, our suppliers, and our business partners operate.