Privacy notice

Last Updated: 12 December  2018

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I. The Purpose of this Privacy Notice

II. Responsibility for personal data

III. Obtaining your personal data

IV. Uses of your personal data

V. Marketing

VI. Disclosure to third parties

VII. Location and transfers of personal data

VIII. Security and retention periods

IX. Individual rights

X. Cookies

XI. Links to other sites

XII. Automated decision-making processes

XIII. Updates

XIV. Feedback or Complaints

I. The Purpose of this Privacy Notice

This Privacy Notice sets out how the personal data provided to Triton Investment Management Limited (the “Manager”), Triton Investments Advisers LLP and their affiliated entities and funds (together, “Triton”, "we" or "us") is used, stored, transferred or otherwise processed, and other matters relating to it. You do not need to take any action as a result of this Privacy Notice, but you do have certain rights as described below. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

The Manager can be contacted at Charter Place (1st Floor), 23-27 Seaton Place, St Helier, Jersey, JE2 3QL. Triton can also be contacted at 9 South Street, 3rd Floor, London, W1K 2XA in the United Kingdom.

Any questions about the contents of this Privacy Notice or how personal data will be used, stored, or transferred, should be sent to Matthew Crill via email at crill@triton-partners.com or post at Charter Place (1st Floor), 23-27 Seaton Place, St Helier, Jersey, JE2 3QL.


II. Responsibility for personal data

For the purposes of applicable EU data protection laws, the Manager and each separate Triton entity is a data controller of personal data collected by us through and in connection with www.triton-partners.com (the “Website”).

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information may mean that we cannot provide certain of our services to you. In this case, we may have to cancel or withdraw a service we provide you, but we will notify you if this is the case at the time.


III. Obtaining your personal data

Information you provide to us

Triton collects personal data for the purposes set out below when individuals voluntarily submit information to, or contact Triton through the Website via the ‘Contact Form’, the careers recruitment email address and the ‘Email News Notifications’ form, by emailing Triton using the contact details available on the Website or through other interactions with Triton via email, post or telephone. The personal data which Triton collects is: names, email addresses and company email addresses. For example, individuals may provide Triton with personal data in a request for general information, through the submission of a business proposal or when expressing an interest in working with, or otherwise discussing employment with, Triton or any portfolio company of Triton.

Other than as noted below, we do not collect any special categories of personal data about you (meaning details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you attend a Triton event, we may take photographs where your personal image including your race or ethnicity may be identifiable.

Information provided by third parties or publicly available sources

 Other than as noted below, we do not process personal data provided by third parties or obtained from publicly available sources.

We process personal data in relation to [companies that we are evaluating in connection with a potential investment in or purchase of such companies]. This personal data is obtained via third parties (i.e. the target company in question).

We may obtain photographs which include your personal image from third party providers and/or from any portfolio company of Triton for the purposes set out below.


IV. Uses of your personal data

To the extent you provide us with any personal data through or in connection with this website, we use such information for the following purposes and rely on the following legal bases. Note that in certain circumstances detailed below, we will process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data:

Purpose

Legal Basis

Providing you with our services, fulfilling requests or reply to inquiries made by the relevant individual

Performance of a contract or our legitimate interests

To keep a record of your relationship with us

Legitimate interests

Sending newsletters that we believe may be of interests to you via email. Please see the section below on ‘Marketing’ for further information.

Consent; or

Legitimate interests

Verifying your identity

To comply with our legal obligations

Protecting against, identifying and preventing fraud and other unlawful activity

Legal requirement; or

Legitimate interests

Complying with and enforcing applicable legal requirements, including, without limitation, with respect to compliance with FATCA and CRS (as well as any legislation, regulations or guidance enacted in any jurisdiction that seeks to implement a similar tax reporting or withholding tax regime), and relevant industry standards and Triton policies

To comply with our legal obligations

Litigation management and conducting internal audits and investigations

Legitimate interests

To administer and protect our business and this Website

Legitimate interests

Using photographs which include your personal image for business interests

Consent; or Legitimate interests

In limited circumstances, Triton may approach the relevant individual for explicit consent to allow us to process certain special category personal data. If we do so, we will provide the individual with full details of the information to be processed and the reasons for the processing.

Triton employees, workers and/or contractors should refer to the Triton Employee, Workers and Contractors Privacy Notice available on the Navigator intranet site, for information relating to the processing of their personal data.


V. Marketing

We will send you direct marketing communications where we have obtained your prior consent to keep you informed of our services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar services in which you may be interested. You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by entering your email address in the ‘Email News Notifications’ box displayed on the Website and by ticking the applicable (unticked) marketing communication preference boxes displayed on our Website. You may withdraw your consent to receiving marketing emails from us at any time by emailing info@triton-partners.com or by clicking on the “opt-out”/ unsubscribe link provided in all our marketing emails.


VI. Disclosure to third parties

Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this Privacy Notice, including professional advisors, recruitment firms, consultants and data hosting providers. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards of data security to ensure that they provide sufficient guarantees to protect your personal data.

There may also be circumstances where Triton is obliged by law to disclose personal data, including to law enforcement agencies and applicable regulators, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the prospective or new owner of the relevant business and their advisors on the basis of our legitimate interest.

VII. Location and transfers of personal data

To the extent it is necessary for Triton or its affiliates to effect cross-border transfers of personal data, including to the United States of America and to other countries outside the the EEA, such transfers will only be made in accordance with applicable EU data protection laws.  In some cases, personal data may be transferred to jurisdictions outside of the EEA that are not deemed by the European Commission to have data protection frameworks that are equivalent to those of the EU countries, such as the United States of America. [Where such transfers are made to other Triton entities or affiliates, Triton uses data transfer agreements incorporating standard contractual clauses approved by the European Commission to legitimise the transfer personal data to such jurisdictions.] Transfers to outside of the EEA may also be made to governmental, regulatory or judicial authorities, auditors, legal advisors or agents as well as to sub-contractors engaged by Triton. For further information about the safeguards/ derogations used, please contact Matthew Crill via email at crill@triton-partners.com.

VIII. Security and retention periods

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorised access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to appropriate duties of confidentiality.

We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information and data via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our Website.

Triton will only retain your personal data for as long as is necessary for the purposes set out in this Privacy Notice or other purposes agreed with you, or notified to you, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact Matthew Crill via email at crill@triton-partners.com.


IX. Individual rights

  • Individuals whose personal data is processed by Triton have certain legal rights in respect of their personal data where EU data protection laws apply. To exercise these rights and controls, please contact Matthew Crill via email at crill@triton-partners.com. These individual rights include: The right to request a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’ if we think that your request is excessive, unfounded or repetitive, to help us cover the costs of locating the information you have requested. Alternatively, we could refuse to comply with your request in these circumstances.
  • The right to require rectification (correction) of errors in personal data if it is inaccurate or needs to be updated.
  • The right to have personal data erased in certain circumstances where you think that we shouldn’t be holding or processing your personal data any more. Please note that this may not always be possible due to legal obligations.
  • The right to restrict the processing of your personal data (other than storing it) in certain situations including where: (i) you contest the accuracy of the personal data (until the accuracy is verified); (ii) the personal data is being processed unlawfully but you do not want the personal data erased; (iii) the personal data is no longer needed for the purposes for which it was collected, but you still require that personal data to help establish, exercise or defend legal claims; or (iv) you object to the processing where we process your personal data on the basis of our, or a third party’s legitimate interests pending verification of whether our, or a third party’s legitimate interests override your own rights.
  • The right to receive personal data in a structured, commonly used and machine-readable format and (if certain conditions are satisfied), transmit that personal data to a third party, if we have the technical means.
  • The right to object to processing, including: (i) for direct marketing (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.

In the limited circumstances where the individual may have provided their consent to the collection, processing and transfer of personal data for a specific purpose, the individual has the right to withdraw consent for that specific processing at any time.

To withdraw consent, please contact Matthew Crill via email at crill@triton-partners.com.

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 facilitate our response.

X. Cookie

When an individual visits the Website or opens emails from Triton, certain information may be collected by automated means, such as cookies.  Information about Triton’s use of cookies can be found at: http://www.triton-partners.com/cookie-policy.


XI. Links to other sites

The Website may provide links to other websites for convenience and information. These websites may operate independently from Triton.  Linked sites may have their own privacy notices or policies, which Triton strongly suggests individuals review.  To the extent any linked websites are not owned or controlled by Triton, Triton is not responsible for their content, any use of the websites, or the privacy or cookie practices of the websites.

XII. Automated decision-making processes

Triton does not use personal data for any automated decision-making or profiling purposes.

XIII. Updates

This Privacy Notice may be updated periodically to reflect changes in Triton’s data processing practices. If we decide to change our Privacy Notice, Triton will post the updated version on the Website and indicate at the top of the notice when it was most recently updated. If at any point we decide to collect personal data or use any collected data in a manner different from that stated at the time it was collected, we will notify applicable users.

XIV. Feedback or Complaints

Any questions or concerns about the contents of this Privacy Notice or Triton’s use of personal data should be addressed to Matthew Crill via email at crill@triton-partners.com or post at Charter Place (1st Floor), 23-27 Seaton Place, St Helier, Jersey, JE2 3QL.

If EU data protection laws apply to the processing of your personal data by us, and you wish to make a formal complaint regarding how your personal data is processed by us, please contact your local data protection authority, which is the Office of the Information Commissioner of Jersey or the UK Information Commissioner’s Office or any applicable supervisory authority. We would, however, appreciate the chance to deal with your concerns before you contact the relevant data protection authority, so please contact us in the first instance.

Information regarding the UK Information Commissioner’s Office and its powers can be found on its website at: www.ICO.org.uk. Details of the Office of the Information Commissioner of Jersey can be found at https://dataci.je/.