SAGA PRIVATE EQUITY ApS - PRIVACY NOTICE
This Privacy Notice explains how Saga Private Equity ApS (“we”, “us”) processes (e.g. collect, use, share and otherwise process) your personal information. As a data controller, we are required to protect your personal information, and our aim is to make you feel secure when we process your personal data as we recognise and respect the importance of your privacy. We will process any personal information about you in accordance with this Privacy Notice, as well as the at all times applicable law.
The entity responsible for the processing of your personal information is:
Saga Private Equity ApS
Amaliegade 24, 1
DK-1256 Copenhagen K
Tel +45 8181 5959
In the course of our business, we register and use information about you (personal data), when you interact with us as an individual who is connected with an investor or a business partner of ours. You could be an authorised signatory, a beneficial owner, a director, an employee, or a third party connected to one of our investors or business partners. We may process your personal data for any of the following purposes, depending on the capacity in which you interact with us:
- Meeting our obligations and providing services to our Investors and business partners
- Complying with applicable law, including anti-money laundering legislation
- For administrative purposes, including to secure and maintain our internal systems
- Carrying out controls to prevent fraud and financial crime
- Managing the relationship to our investors and business partners, including marketing of services.
We will only register and process your personal data if we have a legal basis to do so. This means that we register and use personal data when:
- you have made, or you are considering making an agreement with us
- you have granted us consent to use your personal data for a specific purpose
- we have to comply with certain legal obligations in accordance with
- The Danish Anti-Money Laundering Act
- The Danish Tax Control Act
- The Danish Bookkeeping Act
- The Danish Alternative Investment Fund Managers Act
- The Danish Data Protection Act
- we or the investor or business partner that you have a connection with pursue a legitimate interest. This could be when we or the customer have a business or commercial reason, such as administrate the services that the investor has requested, to use your personal data, need to prevent abuse and loss, or want to use it for marketing purposes. We will only do so if our interest clearly outweighs your interest in not having your personal data processed by us, cf. the GDPR art. 6.1(f).
What personal data do we register and use?
We typically process the following types of personal data:
- Basic personal information, for instance your name, address, contact information, country of residence, education and occupation.
- Identification documentation, for example a photocopy of your passport, driving licence, or other documentation required by law.
How long do we store your personal data?
We keep your data only for as long as it is needed for the purpose for which your data were registered and used. Therefore, we keep your information as long as we are providing a service to you. When your business connection with us has terminated we normally keep your data for a further 5 years. This is primarily due to our obligations under the Bookkeeping Act, the Anti-Money Laundering Act and requirements from the Financial Supervisory Authority.
Third parties and personal data
Personal data from third parties
We register and use data from third parties, for instance:
- the Danish Business Authority and other publicly accessible sources and registers. We register and use the data they have about you to check that the data you have provided to us is accurate
- public accessible databases providing data and information within private equity (Funds and fundraising, performance, fund managers, institutional investors and deals)
Which third parties do we share your personal data with?
In some cases, we may share personal data with third parties if there is a legal basis for doing so.
- We disclose personal data to public authorities as required by law, including to the State Prosecutor for Serious Economic and International Crime (SØIK) in accordance with the Danish Anti-Money Laundering Act, to the Danish tax authorities (SKAT) in accordance with the Danish Tax Control Act, to the depositary of the managed alternative investment funds and to the Danish Financial Supervisory Authority (Finanstilsynet) for various purposes.
- For the performance of a contract, with your consent or if we are allowed by law, we may disclose data to external business partners (e.g. banks and external advisors).
- In connection with IT development, hosting and support, we transfer personal data to data processors, within the EU and the EEA.
- Your data might also be processed by one of our data processors, e.g. one of our suppliers of IT-services. You can be certain that we have entered into the necessary data processing agreements with the relevant suppliers, and that we audit them regularly to make sure that they comply with the security measures in our agreement.
What are your rights?
You have the following rights:
- You have the right to request access to and rectification or erasure of your personal data.
- You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
- If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will
not affect the lawfulness of the processing carried out before you withdrew your consent.
- You have the right to receive your personal information in a structured, commonly used and machine-readable format (data portability).
- If you are dissatisfied with how we register and use your personal data and your dialogue with us has not led to a satisfactory outcome you can lodge a complaint with the Danish Data Protection Agency: Datatilsynet, Borgergade 28, 5., DK-1300 Copenhagen K, mail: firstname.lastname@example.org.
There may be conditions or limitations on these rights. It is therefore not certain for example you have the right of data portability in the specific case – this depends on the specific circumstances of the processing activity.
You are always welcome to contact us if you have any questions about your privacy rights and how we register and use personal data. You can contact Saga Private Equity via email email@example.com.
May 25, 2018