Garoud Capital Partners - Data Protection

DATA PROTECTION POLICY

This Data Protection Policy (the Policy) describes how Garoud Capital Partners S.à r.l. (hereinafter referred as GCP) collects, shares, uses and otherwise processes your personal data, as a natural person, in connection with your relationship with Garoud Capital Partners, and your rights in relation to your personal data.

This Policy outlines how GCP interacts with natural persons, whether you are visiting the GCP-website, whether you are an investor, a prospective investor in GCP’s investment fund.

You are strongly encouraged to thoroughly read this Policy in order to understand the processing of your personal data. GCP manages an alternative investment fund-business, and this Policy may be updated from time to time, in order to reflect changes in laws and changes in GCP’s procedures. You are encouraged to regularly visit this website to review changes to this Policy.

1. Scope of Data Protection Policy

This policy applies to personal data which GCP collects about individuals visiting this website and contacts GCP in connection with the visiting of this website, who interacts with GCP via social media, including, where individuals selects to follow GCP on social media and selects to receive GCP-newsletters, who are employed by GCP’s service providers, or professional advisors, with whom GCP has a business-relationship with, such as limited partners classified as physical persons subscribing to GCP’s investment fund, and persons dealing with GCP in connection with ongoing transactions, and potential transactions, yet to be realized.

2. What Personal Data Is Processed by GCP and Why the Processing of Data

For individuals who visit this website, or otherwise communicates with GCP through means of social media, GCP collects name and email address, as well as other personal data, which the individual voluntarily discloses to GCP; the reason why individuals’ personal data is processed by GCP is to allow GCP to respond to individuals’ queries, complaints or other general communication.

For information about GCP’s Cookies Policy, please visit, https://garoudcapital.com/garoud-capital-partners-cookies-policy.html.

For individuals who are employed, or engaged by any of GCP’s service providers, or professional advisors, GCP processes the name, contact details, job title and company information, identity and nationality information, as well as other personal data, which the individual voluntarily discloses to GCP. The reason why individuals’ personal data is processed by GCP is to allow GCP to arrange for calls, meetings with the individual, or others employed or engaged by the individual’s company, to conduct GCP’s business, and to manage GCP’s relationships with service providers and professional advisors.

GCP collects personal data, as discussed above, directly from the individual, or from the company which the individual is associated with. In addition, personal data may also be collected when such data is available in the public domain, e.g., internet, news feeds, public directories, or any other source available to the public.

For individuals having a business-relationship with GCP, such as Limited Partners in GCP’s fund, and individuals, which GCP deals with in connection with potential transactions, GCP processes personal data, such as name, date of birth, place of birth, citizenship, country of residence, contact details, job title and company information, images and photographs of the individual, as well as other personal date, which the individual voluntarily discloses to GCP. In addition, GCP processes personal data, such as identity and nationality-information (e.g. passport-details), results from due diligence-analysis, professional opinions, results from analysis related to Anti-Money-Laundering, KYC, and source of funds information, and investor questionnaire. If made available by the individual, GCP equally processes personal data concerning convictions and offences. The reason why individuals’ personal data is processed by GCP is to allow GCP to arrange for calls, meetings with the individual, to conduct the business of GCP, to evaluate, complete and administer transactions. This process may involve seeking advice from professional advisors, undertaking analysis, trade and transactions reporting and market research, as well as maintaining records of investments.

GCP collects personal data, as discussed above, directly from the individual, or from the company which the individual is associated with. With regards to data conquering individuals’ criminal convictions, and offences, GCP may obtain this data from third party sources.

3. Purpose of Processing Individuals’ Personal Data

GCP processes personal data for the purpose of performing Anti-Money-Laundering checks, credit worthiness, conducting ‘Well-Informed-Investor” or ‘Professional Client’ checks in assessing investor-suitability, identifying and preventing fraud, and other unlawful activities, maintaining and managing GCP’s IT-infrastructure, seeking advice from professional advisors, preparing for, responding to and obtaining advice in connection with enquiries, investigations, disputes, organizing events and meetings, performing financial research, maintaining records and accounts, preparing for and participating in transactions, performing internal reporting, responding to data subject requests.

Individuals have the right to object the processing of personal data in instances where the processing is being carried-out for GCP’s legitimate interests; important to note, there may be instances where GCP may not be able to fulfil an individual’s request.

4. Recipients of Data

GCP may disclose personal data, as permitted by EU Data Protection Laws, to corporate affiliates, third-party service providers, investors, financial intermediaries who are considered being involved in transactions, professional advisors (e.g. lawyers, accountants, consultants), independent auditors, third-parties, which are considered acquiring, or acquiring part of GCP’s assets or shares, regulators and other governmental agencies.

5. Transfers of’ Personal Data to Third Countries

Considering GCP’s international nature of business, GCP may transfer your personal data to recipients who are located outside the European Economic Area; and in some cases, it may well be that the European Commission does not consider these countries as countries providing adequate level of data protection.

Individuals’ personal data may only be transferred from the EEA to a recipient in a country, which is not considered providing adequate level of data protections when the transfer is in compliance with applicable data protection- and privacy laws.

For additional information about transfers to third countries, please contact GCP.

6. Retention of Personal Data

GCP may retain personal data for as long as necessary to fulfil the purpose GCP collected the data for, and to perform contractual obligations. In order to determine the appropriate retention period for personal data, GCP considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use, or disclosure of individuals’ personal data, the purposes for which GCP processes personal data and whether GCP may achieve those purposes through means other than the above, and the applicable legal requirements. GCP also considers applicable legal requirements and the extent to which it is necessary to process personal data. It may very well be, as in exceptional cases, that GCP needs to keep personal data for longer periods of time.

7. Individuals’ Data Protection Rights

In order for GCP to be able to maintain accurate and updated records of personal data, individuals are encouraged to contact GCP in the event of any changes, or errors in personal data.

Individuals have the following data protection-rights,

- to request access to personal data, which GCP processes

- to request GCP to rectify any personal date

- to request GCP to restrict the processing of the your personal date.

- to request to receive a copy of the personal date

- to request for the portability of data

- to request GCP to erase the personal data.

- where GCP relies on your consent, to withdraw consent to process data

8. Other Websites

The GCP-website may provide links to third-party-websites, which may operate independently from GCP, and may have their own respective data protection policy. GCP are not responsible for content belonging to websites owned and operated by third parties.

9. Changes to the Policy

It is GCP’s intention to see to it that this Policy is reviewed and maintained up-to-date, as required by laws and and other regulations.

10. How to Contact Garoud Capital Partners

For any issue related this Policy, and in cases of exercising rights, you may contact GCP at, dataprotection@garoudcapital.com