Privacy notice
1. Inflexion Private Equity Partners LLP Privacy Notice
Inflexion recognises that the correct and lawful treatment of personal data will maintain confidence in the organisation and will help support successful business operations. Protecting the confidentiality and integrity of personal data is a critical responsibility that Inflexion takes seriously at all times.
For the purposes of applicable legislation, including the EU General Data Protection Regulation 2016/679 ("GDPR"), UK GDPR and the Data Protection Action 2018, each as amended, (“Data Protection Laws”), the Inflexion group entity (which will be one of Inflexion Private Equity Partners LLP, Inflexion Private Equity Holdco Limited, Inflexion Nordics AB or Inflexion Deutschland GmbH ("Inflexion", "we", "us" or "our") that you have dealings with is the controller of your personal data. If you have any questions about who the controller of your personal data is, Inflexion has a Data Protection Team who are contactable by email at privacy@inflexion.com.
2. Personal data: Job applicants (individuals applying to work at Inflexion)
This section will apply to individuals when they are applying to work at Inflexion. If you become an employee, you will be provided with a separate employee privacy notice which outlines how we collect and use your personal data during and after your working relationship with us.
- What personal data do we collect and use?
- Personal details such as your name, address, date of birth, country of residence, and contact details, including phone number and email address;
- Identity documents, such as copies of passports (this information is only collected when we offer you a job); and
- Information relevant to the recruitment process, such as your job title, information about your job role, your CV or cover letter, any other information you have shared with us as part of the recruitment process, and any notes taken from an interview with you.
We do not collect any of your special category data; this is any information relating to your health or medical records, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
We obtain your personal data in a number of different ways:
- when you apply to work at Inflexion or during any form of communications such as face to face, written and phone correspondence or interviews;
- from correspondence with you on LinkedIn; or
- from recruitment agencies.
- For what purpose do we use your personal data?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data. For Inflexion these will be:
- it is necessary in order to take steps to enter into a contract with you; or
- it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. In each case we will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
Purpose for processing your personal data |
Lawful basis |
For the purposes of the recruitment process including:
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3. Personal data: business contacts
If you have interacted with Inflexion, whether through email, meeting someone from Inflexion, or otherwise, we may keep limited amounts of your personal data.
- What personal data do we collect and use?
- general information such as your name and contact details including phone number and email address; and
- professional details such as your job title, employer organisation and information about your job role.
We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
- We obtain your personal data directly from you or from your representatives or staff;
- publicly available sources such as internet search engines; and
- invoices, contracts, policies, correspondence and business cards.
- For what purpose do we use your personal data?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data. For Inflexion this will be that it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
Purpose for processing your personal data |
Lawful basis |
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4. Personal data: actual or potential management teams
If you are involved in a transaction that Inflexion and/or the funds that it advises enters into, or a potential transaction that Inflexion is contemplating, we may keep certain limited amounts of your personal data.
- What personal data do we collect and use?
Information relating to your financial status and dealings, your CV, details of your previous and current employment history and professional activities, your nationality (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence we may have conducted.
- How do we obtain your personal data?
We obtain your personal data in a number of different ways:
- directly from you or during any form of correspondence such as face to face, written (including email) and phone correspondence;
- from your representatives, staff or advisors; and/or
- in certain limited circumstances from other third parties, for example, a recruiter.
- For what purpose do we use your personal data?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data.
For Inflexion this will be that:
- it is necessary for compliance with a legal obligation; or
- it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. . We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
Where the information we process is special category data or criminal conviction data, we must have an additional lawful basis and we rely on the following legal bases when doing so:
- There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
- We need to use it to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
Purpose for processing your personal data |
Lawful basis |
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5. Personal data: suppliers and professional advisors
We will store limited amounts of personal data relating to suppliers to Inflexion, or one of Inflexion’s professional advisors.
- What personal data do we collect and use?
- general information such as your name and contact details including phone number and email address;
- professional details such as your job title, employer organisation, qualifications and information about your job role;
- financial information such as your bank details, payment card details, and billing address;
- other information (including publicly available information) obtained as part of our due diligence checks; and
- information captured during any correspondence with you.
We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
We obtain your personal data in a number of different ways:
- directly from you; such as via your website or during any form of correspondence such as face to face, written (including email) and phone correspondence;
- from your representatives, staff or advisors;
- publicly available sources such as internet search engines; and
- invoices, contracts, policies, correspondence and business cards.
- For what purpose do we use your personal data and with whom is it shared?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data.
For Inflexion this will be either that:
- It is necessary for complying with a legal obligation; or
- it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
Purpose for processing your personal data |
Lawful basis |
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6. Personal data: Individual investors
When you become a client of Inflexion or an investor and during the course of our dealings with you, we will collect personal data about you. This includes what you tell us about yourself and what we learn about you by having you as an investor.
- What personal data do we collect and use?
- General information such as your first and last name, date of birth;
- Contact information including telephone number, business and/or personal address(es), and email address;
- Information regarding your job including your employer/company, job title, salary, employment history etc.;
- Financial information, including the amount you are looking to invest, any monthly payments you may wish to make, your investment selection(s), your investment history, your net-worth, income, your investment history and your bank account information for any distributions or other payments to be made;
- Proof of identification, including copies of your passport, driver's license or other identifying documents and information such as utilities bills, tax bills, national identification numbers etc.;
- Personal data and contact information provided in correspondence with us, whether by email, letter, telephonically, or online (this will be information volunteered by you, it could include the reasons why you have decided to invest, or where your investment money has come from, by way of example);
- IP address, login and browsing history on the limited partner extranet, or any other data room or portal we may use, operate or provide ("Data Rooms");
- Transaction history with Inflexion and its affiliates (including account balance, commitment, other account data, and participation in other investments);
- Information relating to your use of any other Inflexion services you currently have, have applied for or have previously held;
- Information included in limited partnership agreements, investment advisory contracts, investment management agreements or subscription agreements, as applicable; and/or
- Other information regarding your preferences where relevant to the services that we provide you.
- How do we obtain your personal data?
We obtain your personal data in a number of different ways:
- when you complete investor questionnaires, applications and other related documentation;
- directly from you or during any form of correspondence such as face to face, written (including email) and phone correspondence;
- from your representatives, staff or advisors; and/or
- when you access our Data Rooms.
- For what purpose do we use your personal data?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data. For Inflexion this will be:
- it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests. In each case we will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest;
- it is necessary for us to enter into or perform a contract with you;
- where we need to so we can comply with our legal and regulatory obligations; and
- in limited circumstances, where you have given your consent.
- [Where the information we process is special category data, we must have an additional lawful basis and we rely on the following legal bases when doing so:
- There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks
- We need to use it to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.]
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
Purpose for processing your personal data |
Lawful basis |
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· Legitimate interests (to effectively manage our business). |
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7. Personal data: Event attendees
This section will apply to individuals when they attend events hosted by Inflexion.
- What personal data do we collect and use?
- general information such as your name and contact details including phone number and email address;
- dietary requirements (if required); and
- professional details such as your job title and information about your job role.
We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
We obtain your personal data directly from you.
- For what purpose do we use your personal data?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data. For Inflexion this will be that it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
Purpose for processing your personal data |
Lawful basis |
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8. Personal data: website users
This Notice also applies to how Inflexion controls, processes, handles and protects your personal data while browsing or using Inflexion’s website (www.inflexion.com), including your rights under current laws and regulations. Inflexion uses this information to provide you with a better service, and, in particular, for the following reasons.
- What personal data do we collect and use?
- general information such as your name and contact details including phone number and email address;
- professional details such as your job title and information about your job role;
- any information that you choose to provide to us in relation to the nature of your query;
- information obtained through our use of cookies such as unique user identifiers, IP address and login data; please see our Cookie Policy for more information; and
- your marketing preferences, subject to any requirements regarding marketing consents under law.
We do not collect any of your special category data; this is any information relating to your health or medical records, criminal records or convictions, sexual orientation, racial or ethnic origin, political or philosophical opinions or affiliations, religious or philosophical beliefs or affiliations or trade union membership or genetic or biometric data.
- How do we obtain your personal data?
We obtain your personal data:
- directly from any of Inflexion's websites that you use; and/or
- via our website collected via cookies.
- For what purpose do we use your personal data?
We only process personal data for the purposes described in this Notice. Data Protection Laws require companies to have a "lawful basis" to collect and use personal data. For Inflexion these will be that it is necessary for legitimate business interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
We will always consider your interests and undertake a balancing exercise to ensure that our business interest does not cause you harm or override your own interest.
We will process your personal data for the following purposes and in reliance of the listed lawful bases:
Purpose for processing your personal data |
Lawful basis |
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Inflexion’s websites may contain hypertext links to external websites. Inflexion is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.
9. Marketing Activities: Mailing lists
As part of our marketing activities, Inflexion collects and use personal data to provide updates on our activities and to issue invitations to events we host. We don’t rent or trade email lists with other organisations and businesses.
Inflexion uses third-party providers, Dispatch (an integrated product of DealCloud) and Campaign Monitor, to deliver its updates and issues events. Inflexion gathers statistics around email opening and clicks using industry standard technologies to help us monitor and improve the e-newsletter. For more information, please see the privacy policy of Dispatch and Campaign Monitor. You can unsubscribe to general mailings at any time by clicking the unsubscribe (or “Forget Me”) link at the bottom of any of Inflexion’s emails or by emailing privacy@inflexion.com.
- Who we share your personal data with
When we share your personal data, we do so in accordance with Data Protection Laws and our internal security standards. We may disclose your personal data to:
- our legal and other professional advisers, auditors, and independent consultants;
- governmental and regulatory bodies such as tax authorities, financial regulators and non-financial regulators (depending on the circumstances of the sharing);
- overseas tax authorities, to the extent that you are subject to tax in a different jurisdiction than the fund. This may include us sharing your personal data directly with the relevant tax authorities (instead of through the local authority);
- other organizations and businesses who provide services to us under contract, such as maintaining or servicing customer accounts, providing marketing services to us (such as a placement agent), back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;
- buyers or successor managers of a fund and their professional representatives, as part of any restructuring or sale of our business or assets;
- administrators or custodians;
- identity verification agencies, anti-money laundering screening services; and/or
- companies related to Inflexion by common ownership or control, including financial and nonfinancial companies for administration of their products and services, conducting marketing and credit checks.
10. Personal data: international transfers
Due to the international nature of Inflexion’s operations, any personal data that we hold may be transferred to, and stored at, a country outside of your country of residence. This could include countries outside of the EEA, such as the U.S. and Brazil. To the extent we transfer personal data outside of the EEA, we will ensure such transfers comply with the Data Protection Laws. This may include entering into data transfer agreements with recipients.
11. How long do we keep your personal data?
We will only keep your personal data for as long as is necessary to fulfil the relevant purposes as set out in this privacy policy and more widely to comply with our legal obligations.
12. What are your rights?
If Inflexion holds your personal data you may be entitled to make certain requests of us in relation to the personal data that we hold about you. If you wish to make any such request you should submit it by email to the Data Protection Team (privacy@inflexion.com).
Please note that not all of your data subject rights will be absolute; this means that there may be some circumstances where we may not be able to comply with your request (such as where this would conflict with our obligation to comply with legal requirements). However, if we cannot comply with your request, we will tell you the reason, and we will always respond to any request you make.
There may also be circumstances where exercising some of these rights (such as the right to erasure, the right to restrict processing and the right to withdraw consent) will mean we can no longer provide you with our services. We will inform you of these consequences when you exercise your right.
Your rights under applicable Data Protection Laws are:
- the right to access your personal data:
- you are entitled to a copy of the personal data we hold about you and certain details of how we use it; and
- we will usually provide you with your personal data in writing, unless you request otherwise, or where you have made the request using electronic means, in which case the information will, where possible, be provided to you by electronic means;
- the right to rectification: we take reasonable steps to ensure that your personal data that we hold is accurate and complete, however, you can ask us to amend or update the personal data if you do not believe that this is so or if your details change;
- the right to erasure: you have the right to ask us to erase your personal data in certain circumstances, for example where you withdraw your consent or where the personal data we obtained is no longer necessary for the original purpose; this right, will, however, need to be balanced against other factors, for example, we may have legal obligations which mean we cannot comply with your request;
- the right to restrict processing: in certain circumstances, you are entitled to ask us to stop using your personal data, for example where you think that we no longer need to use your personal data or where you think that the personal data we hold about you may be inaccurate;
- the right to data portability: you have the right, under certain circumstances, to ask that we transfer personal data that you have provided to us to another third party of your choice;
- the right to object to marketing: you can ask us to stop sending you marketing messages at any time. You can exercise this right by either clicking on the "unsubscribe" link which is contained in any email that we send to you or you can contact us at privacy@inflexion.com. Please note that exercise of this right does not extend to service related communications which, where necessary, we will continue to send;
- the right to object to processing: where we process your personal data based on our legitimate business interests (indicated in this privacy policy), you can object to our processing. We will consider your objection and determine whether or not our legitimate business interests prejudice your privacy rights;
- the right to withdraw consent: we may ask for your consent for certain uses of your personal data – we have indicated in this privacy policy where we need your consent. You have the right to withdraw your consent at any time;
- rights relating to automated decision-making: we do not carry out any automated decision making. If this changes in the future, we will let you know; and
- the right to lodge a complaint with the Information Commissioner's Office: you can find out more information at the Information Commissioner’s Office website: https://ico.org.uk/. The ICO helpline is +44 0303 123 1113. Please note that lodging a complaint will not affect any other legal rights or remedies that you have. Inflexion is registered with the ICO under the Data Protection Register, with registration number: ZA153072.
October 2024