It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Collection of Information
We automatically collect certain information about you when you access or use this website, including information about your use of our website, such as the type of browser you use, access times, pages viewed and your IP address. Please see the “Cookies” section below further details of how third party service providers, such as Google Analytics, collect this information on our behalf.
Use of Information
Security of Information
VCP restricts access to information collected about you from this website to those employees, agents, contractors and third parties who have a business need to know such information. To protect your personal data, we have put in place security measures consistent with industry standards and practices for an investment firm such as ours intended to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- This website uses a variety of technologies, such as cookies, as described further below, to collect information that helps VCP understand how the site is used. Specifically, when a user visits the website, VCP may automatically collect a variety of website usage statistics, which may be analyzed to improve the web design and functionality, to enhance VCP’s ability to serve investors and their accounts and to tailor its communications to investors regarding products and services.
- A “cookie” is a small file of letters and numbers that is stored on a user’s computer, tablet, mobile phone, or other device when such user visits a website. Cookies contain information that is transferred to or read on a device and allow websites to recognize devices and store certain information, such as user preferences.
- If you are uncomfortable with the idea of your information being used in this way, most computer systems and web browsers offer privacy settings and options, such as disabling cookies or opting for “Do Not Track” features. This website does not override these settings or options. However, if you do not wish to provide such information through the website or opt to utilize the aforementioned privacy features of your computer system or web browser, you may be unable to obtain certain content, features, services, products, or benefits of this website.
VCP works with third parties to collect the information discussed above to engage in analysis, auditing, research, and reporting. These third parties may set and access cookies on your computer or other devices. In particular, this website uses Google Analytics to help collect and analyze certain information for the purposes discussed above. The information generated about your use of this website may be transmitted to and stored by Google Analytics on servers outside your country of residence. Information on how Google Analytics collects and processes your data is available here: www.google.com/policies/privacy/partners/.
Sharing of Information
VCP may share information collected about you from this website (a) within VCP, including to affiliates of Victoria Capital Partners, L.P., to the extent permitted by law, (b) with nonaffiliated third parties that perform services for VCP, such as fund administration, fraud prevention, risk analysis and analytics, for use in connection with the performance of such services, (c) where disclosure is necessary or advisable pursuant to or in connection with any international, federal, provincial, state or local law, rule, regulation, executive order or policy and such disclosure is not prohibited by law, rule, regulation, executive order or policy or (d) if you direct or authorize us to disclose such information. VCP may transfer information collected about you from this website in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, or any other transaction or proceeding involving the sale, transfer or divestiture of all or a portion of the business or assets of VCP.
Notwithstanding the foregoing, VCP may freely share aggregated or de-identified information, which cannot reasonably be used to identify you, with any third party.
Individuals in the European Economic Area: Your Legal Rights
If you are an individual natural personal located in the European Economic Area (“EEA”), you may, after May 25, 2018, have certain rights under the European Union General Data Protection Regulation (EU) 2016/679 (“GDPR”) in connection with our collection, use or sharing of personal data about you in connection with your use of the website. If (and only to the extent) that Victoria Capital Partners, L.P. (and/or its relevant affiliate) is subject to the GDPR:
- Access. You may contact us at any time in order to request access to the personal data we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned and the reasons for our processing. We can also provide you with a copy of your personal data on request.
- Rectification. If the personal data we hold appears to be inaccurate we will not use it, and not allow others to use it, until it is verified. You can ask us to correct or complete your personal data by contacting us at any time. To the extent possible, we will inform anyone who has received your personal data of any corrections we make to it.
- Restriction. In certain circumstances, it may be possible to require us to limit the way in which we process your personal data (i.e., require us to continue to store your personal data, but not otherwise process it without your consent).
- Erasure. You may ask to have the personal data on your account deleted or removed. We will try to do so promptly, and, to the extent possible, we will inform anyone who has received your personal data of your request. However, we must keep track of certain transaction information, such as past purchases and similar information, for legal compliance purposes, so we may not be able to fully delete your personal data in certain circumstances.
- Receiving/transferring your personal data. You may also ask us to send you the personal data we hold on you in an electronic, structured and user-friendly format, or you may ask us to send this data to another entity. Please note that if you choose to ask us to send your personal data to you or another party, this may impact our ability to provide the products and services you requested.
- Object. Where we are processing your personal data without your consent to pursue our legitimate interests, you may object to us processing your personal data. In particular, where we are using your personal data to contact you for marketing purposes, you may object to such processing at any time.
- Automated decision-making. You have the right to be informed of any automated decision-making, including profiling, used in connection with your personal data, and we will provide information about the logic we apply, as well as the significance and consequences of such processing.
- Complaints. If you are located in the EEA and you believe that our processing of your personal data is in breach of data protection law, you have the right to lodge a complaint with the relevant data protection supervisory authority in the country where you are based or any place in the EEA where you believe the infringement has occurred. A list of EU national data protection authorities can be found here. You may also contact us at any time if you wish to complain about our processing of your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Questions or Concerns
Victoria Capital Partners, L.P. is the controller of, and is responsible for, any personal data about you that is collected, used and shared in connection with your use of this website. Our full details are:
Victoria Capital Partners, L.P.
Privacy contact: Dalmau Garcia
Email address: firstname.lastname@example.org
Postal address: c/o Victoria Capital Partners Services Co. LLC, 500 West Putnam Avenue, Suite 400, Greenwich, CT 06830.
Effective Date: March 22, 2018.