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 in applicable law. You are encouraged to check this page from time to time for revisions.

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, including Atlantic-Pacific Capital Malta Limited (“APCM”). Our registered office is located at 60 St. James's Street, 6th Floor, London, England SW1A 1LE, and we are 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), where APCM is registered as a tied agent of Mirabella Malta Advisers Limited (“MMAL”). Contact details for all office locations are set out in the Contact section of our website.

APCM's Malta establishment satisfies the territorial establishment requirement under the EU General Data Protection Regulation (“EU GDPR”) for our EU-directed processing; we do not separately appoint an Article 27 EU representative on that basis. For UK-directed processing, Atlantic-Pacific Capital Limited's London establishment satisfies the equivalent requirement under the UK GDPR.

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 include your name, job title, email address and telephone number.

In the course of our business, we do not seek to collect “special category” personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning a natural person's sex life or sexual orientation.

Information You Provide to Us Directly

General Partner: if you are a fund manager (or other fundraising/advisory) client of Atlantic-Pacific Capital, you may provide us with personal data in connection with becoming or continuing to be a client.
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 personal data including your CV, contact details, and other application details.

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 available through publicly available sources.

Cookies

A cookie is a text file that downloads to your device containing small amounts of information, used to improve your experience and recognise you on return visits. 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. All such data is anonymous and aggregated.

You may refuse cookies at any time by adjusting your browser settings. If you do not do so, our system will activate cookies when you access our website.

Data Retention Period and Security

Personal data is kept for different periods depending on: the length of our relationship with you; the types of services we provide; the purpose for which the data was collected; when our relationship with you ends; retention periods set or recommended by regulators or law; and any relevant legal proceedings. We maintain appropriate technical and organisational security measures and will not retain personal data longer than necessary for the purposes above.

How We Use Personal Data

To provide marketing, advisory and fundraising services to our clients.
As requested by legal and regulatory agencies in connection with our business activities.
For internal audit requirements.
To deliver fundraising communications and business opportunities to clients and potential clients.
In the legitimate operation of our daily fundraising and advisory business.
For internal research and business development.
To monitor website activity, performance and usage.
To review job applications for recruitment and on-boarding.

Legal Basis for Processing

We rely on the following legal bases, applied according to the specific purpose of processing:

Contract: where processing is necessary to enter into or perform a contract with you (e.g., onboarding a General Partner client).
Legitimate interests: for fundraising communications, internal research, business development and website analytics, save where overridden by your interests or fundamental rights.
Legal obligation: where processing is necessary to comply with regulatory or legal requirements, including those arising under our MFSA, FCA, FINRA or SFC authorisations.
Consent: only where we specifically rely on your consent (for example, certain marketing communications or optional cookies); you may withdraw consent at any time by contacting us.

Sharing Your Personal Data

We share personal data only where necessary for the purposes described in this Policy, including with:

Our domestic and international affiliates, including APCM, for the purposes described above.
Regulatory principals and oversight bodies necessary to our regulatory structure — in particular, MMAL, which as APCM's MiFID principal reviews and approves marketing and financial promotion materials, and receives certain investor-related information, in the exercise of its regulatory oversight and compliance-monitoring responsibilities under the Tied Agent Agreement between APCM and MMAL. This sharing is for regulatory compliance and oversight purposes and is not a sale, rental, or release of personal data to a third party for that third party's own independent marketing purposes.
Regulators, courts, or other authorities, where required by law.
Service providers who process personal data on our behalf (e.g., IT and compliance service providers), under contractual terms requiring them to protect that data.

Other than as set out above, we will not share or release personal data to an unaffiliated third party for that third party's own independent marketing purposes.

International Transfers

We maintain offices outside the UK and European Economic Area (“EEA”), including in the United States and Hong Kong. Where we transfer personal data originating in the UK or EEA to these or other offices or service providers located outside the UK/EEA, we do so using an appropriate safeguard recognised under the UK GDPR and/or EU GDPR, which may include:

An adequacy decision of the UK Government or European Commission in respect of the recipient country;
Standard Contractual Clauses approved by the European Commission, and/or the UK's International Data Transfer Addendum, entered into with the recipient; or
Another lawful transfer mechanism available under Chapter V of the EU GDPR or the equivalent provisions of the UK GDPR.

You may request further information about, or a copy of, the safeguard relevant to a specific transfer by contacting us using the details below.

Your Rights

Subject to applicable exceptions, you have the following rights in respect of your personal data:

The right to request access to, and a copy of, your personal data.
The right to have inaccurate personal data corrected.
The right to have personal data erased (“the right to be forgotten”), in certain circumstances.
The right to restrict, or object to, our processing of your personal data, in certain circumstances.
The right to data portability — to receive personal data you have provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller, where technically feasible and where the processing is based on consent or contract and carried out by automated means.
The right to withdraw consent previously given, at any time, without affecting the lawfulness of processing carried out before withdrawal.
The right to lodge a complaint with a supervisory authority — in the UK, the Information Commissioner's Office (ico.org.uk); in Malta, the Office of the Information and Data Protection Commissioner (idpc.org.mt); or the supervisory authority of your own EU member state of residence or work.

These rights are not absolute and do not apply in all circumstances; a request may be declined, in whole or in part, where permitted by law (for example, where it would expose personal data about another individual, or conflict with a legal or regulatory obligation).

To exercise any of these rights, please contact us using the details below. We may ask you to verify your identity and provide further information to help us process your request, and will explain our reasoning if we are unable to fulfil it.

Getting in Touch With Us

If you have any queries or comments about this Policy or our data practices, please contact:

Data Privacy Officer

Atlantic-Pacific Capital Limited

60 St. James's Street, 6th Floor

London, England SW1A 1LE