Atlantic Pacific Capital

DATA PROTECTION PRIVACY POLICY

Atlantic-Pacific Capital is committed to protecting your privacy. This Privacy Policy (“Policy”) describes how we collect and use your personal data and the information we collect on you in the course of our regular business and through our website.

We encourage you to read this Policy carefully and contact us with any questions or concerns regarding our privacy practices. We reserve the right to update this policy based on changes in our business or regulations which may require an update to be made. You are encouraged to check this page www.apcap.com privacy_policy from time to time for any revisions to this Policy.

Who We Are:

When we refer to Atlantic-Pacific Capital or “we”/“us”/“our”, we mean Atlantic-Pacific Capital Limited and our domestic and international affiliates. Our registered office is located at 60 St. James's Street 6th Floor, London, England SW1A 1LE and is authorised and regulated in the UK by the Financial Conduct Authority (www.fca.org.uk). Our affiliated offices are registered in the US by FINRA (www.finra.org) in Hong Kong by the SFC (www.SFC.hk) and in Malta by the MFSA (www.mfsa.mt). Contact details for all of our office locations may be found in the Contact section of our website at www.apcap.com.

The Information We Collect:

"Personal data" is any information relating to an identified or identifiable natural person which we have in our possession or control. Examples of such information we collect include your name, job title, email address and telephone number.

In the course of our business, we do not collect “sensitive personal data” examples include; racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning a natural person's sex life or sexual orientation.

Information You Provide to Us Directly:

We will process personal data that you provide to us when you email us or contact us regarding the following:

General Partner: If you are a fund manager (or other fundraising/advisory) client of Atlantic-Pacific Capital, you may provide us with personal data when you became, or in connection with becoming or continuing to be a client of Atlantic-Pacific Capital.
Limited Partner: If you are an investor or potential investor, you may provide us with personal data in connection with receiving information about our current offerings.
Recruitment: if you apply for an employment opportunity with us you may provide us with personal data including your CV, contact details and other details set out in your application.

Additional Circumstances We May Collect Personal Data:

We may collect personal data when you use our website or provide services to us. We may also collect information that is available through a publicly available source.

Cookies:

A cookie is a text file that downloads to your hard drive, tablet or mobile device containing small amounts of information. The purpose of a cookie is to create a better experience for the end user when visiting a particular website and to recognise you when you return to our site. Cookies used on our website do not collect personal data and do not link the information collected to an individual. We may also obtain your IP address, browser information, user agent strings or other anonymous data sources. All data collected in this manner is anonymous and in aggregated form.

At any time you reserve the right to refuse the acceptance of cookies used on our website. You may exercise this right by adjusting the settings on your web browser. If you do not make this adjustment, our system will activate cookies when you access our website.

Data Retention Period and Security:

Personal data may be kept for different periods of time based on the following varying criteria.

The length of time we have had a relationship with you.
The types of services we provide to you.
The purpose by which we have collected your personal data.
When you will stop being having a relationship with us.
The length of time that has been set or recommended by regulators or the law to demonstrate we have met all appropriate obligations.
Any relevant proceedings that apply.
We will take the security of your personal data seriously. We will maintain the appropriate level of security to ensure your data remains secure.

We will not maintain personal data for a period longer than is necessary for any of the above reasons.

How We Use Personal Data:

Personal Data we collect may be used in our daily business activities as follows:

To provide marketing, advisory and fundraising services to our clients.
As requested by legal and regulatory agencies in reference to our business activities.
For internal audit requirements.
Delivering fundraising communication and business opportunities to our clients and potential clients.
In the legitimate operation of our daily fundraising and advisory business.
Internal research and business development.
Website activity, performance and usage.
Job application review for recruitment and on-boarding procedures.

Basis for Processing Your Personal Data:

We process your personal data on the following legal basis:

While we do not necessarily need your consent to use your personal data, you may at any time withdraw consent by contacting us directly.
In the course of doing business directly with us, we may need to process your personal data in respect to entering into a contract with you.
We reserve the ability to use your personal data in regards to our legitimate business interests.
We may from time to time be required to use your personal data in relation to compliance with a regulatory or legal obligation.

Sharing Your Personal Data:

Atlantic-Pacific Capital maintains offices outside of Europe with which it may share your personal data for legitimate business purposes. We treat all personal data with concern to respect confidentiality. At no time will we share or release any personal data to an unaffiliated entity for the purpose of marketing.

Your Rights:

You have legal rights in regards to your personal data we have in our possession. You may exercise these rights by contacting us at any time using the contact information listed below.

You have the following rights (certain exceptions apply).

The right to make a written request for details of your personal data and a copy of that personal information. Please note that there may be certain circumstances when we are entitled to refuse requests for access to copies of personal information.
The right to have inaccurate information about you corrected or removed.
The right to have certain personal information about you erased or “the right to be forgotten”. Please note, there are certain circumstances for legal or regulatory purposes that this request may not be granted.
The right to request that your personal information is only used for restricted purposes or object to it being used at all. Please note, there are certain circumstances for legal or regulatory purposes that this request may not be granted.
The right to withdraw consent you have previously given us to process your personal data.
The right to file a formal complaint with the authorities should you believe we have infringed on your rights.

The above listed rights are not absolute and do not apply in all cases. Requests may be denied if such request would expose personal data regarding another subject or for other legal instances.

If you chose to exercise your rights, we may ask you to confirm your identity and to provide information that helps us to understand your request better. If we are unable to process your request, we will provide an explanation.

Getting in touch with us:

If you would like to contact us with any queries or comment on this Policy or our website, please contact us by writing to us at:

Data Privacy Officer
Atlantic-Pacific Capital Limited

60 St. James's Street, 6th Floor

London, England SW1A 1LE