Mayfair Equity Partners LLP Privacy Policy

Introduction

At Mayfair Equity Partners LLP, we and our affiliated undertakings (“Mayfair”, “we”, “us” and/or “our”) value the relationship we have with you. Protecting the confidentiality and integrity of personal data is a critical responsibility that Mayfair takes very seriously.

This Privacy Policy explains how we collect, use, share, store and otherwise process your personal data when you use this website (the “Mayfair Website”) or we otherwise receive your personal data in connection with our relationship with you or the business you work for. It also explains your rights under applicable data protection laws, including the European Union’s (“EU”) General Data Protection Regulation (“GDPR”) and the United Kingdom’s (“UK”) Data Protection Act 2018 (the “Data Protection Laws”).

Where the GDPR applies to the processing of your personal data, the data controller for your personal data is Mayfair Equity Partners LLP, unless we advise you otherwise. The data controller decides how personal data about you is processed.

We keep this Privacy Policy under regular review and we will advise you of any updates or changes to this Privacy Policy, from time to time. This Privacy Policy was last updated on 10/11/20.

Information We Collect; Purpose of Processing

We regularly collect personal data in the contest of our business activities. The types of personal data relating to you that we may collect, and the purposes for which we process this data, depends on the nature of your interaction with us. Please read the table below for more information. Under the GDPR, we are required to specify the legal basis under which we are allowed to process your personal data. Generally, we may process your personal data to perform a contract with you or for your benefit, for the establishment, exercise or defence of legal claims or proceedings and to comply with our legal and regulatory obligations. Other bases for processing your personal information is described below.

How we obtain your personal data	Types of personal data that we may process	Purpose / legal basis for processing
When you browse or interact with the Mayfair Website, including through the use of cookies (for more information, read our Cookie Policy	Name, title, gender Contact details (email address, physical address, phone numbers) Your employer Description of yourself, your position, your requirements or comments, and your relationship to a person Technical information (including your IP address, domain name, type of browser and operating system used) Your preferences	Legitimate interests: Managing business communications Maintaining and managing the Mayfair Website Responding to your communication(s) with us. Improving the quality of our communications and interactions with our visitors Understanding visitor behaviour patterns to improve the Mayfair Website
When you provide personal data to us in correspondence and communications and through forms and contracts submitted to us or executed with us.	Name, title, gender Contact details (personal or business email address, telephone numbers, physical address) Company and position Information you disclose to us, which may include special categories of data Information from identification documents	Contract: Fulfilling our obligations under our engagement or other agreement with you Legitimate interests: Managing business communications Responding to your communication(s) with us.
When you provide personal data to us in order to receive event invitations, business updates, or other marketing materials	Name, title, gender Contact details (personal or business email address, telephone numbers, physical address) Company and position Your communication preferences Personal data that you disclose to us, such as dietary and access requirements, comments, or requests	Consent (opt in): On the basis of the consent that you have provided us to receive certain communications Legitimate Interests: Ensuring the efficient management of events To promote our business and relationships
If you are a member of the management team in, or employed by, a business that Mayfair has invested in, or is contemplating investing in	Name, title, gender Contact details (personal or business email address, telephone numbers, physical address) Company and position CV details of your previous employment history and professional activities	Legitimate interests: When we are required to comply with laws other than EEA or UK laws Evaluating and administering potential transactions Keeping records of assets and investments Receiving advice from our professional advisors, including accountants, lawyers and other consultants Providing business updates
If you offer or provide services to us as our service provider or professional advisor	Name, title, position, employer, qualifications, physical address, email address, phone numbers Any other personal data disclosed to us	Legitimate Interest Running and promoting our business Managing and preserving records of services or advice we have received and authorising further services Contract: Fulfilling our obligations under our agreement with you and/or your employer Legal obligation: Monitoring the risk of modern slavery in our supply chain
When you apply for a job. In certain limited circumstances, personal data may be received by Mayfair from a third party, for example a recruiter	Name, title, gender, date of birth. Results of background checks including references, qualifications, and to the extent permitted by law, criminal background checks (unspent convictions) Passport, work permit, visa, or other immigration documentation Contact details (personal, business or educational institution email address, telephone numbers, physical address) CV, including relevant skills and experience Special requirements (such as, or relating to, a disability/health issue) Any other personal data that you may provide to us through the application process	Legitimate interests: Fulfilling our staffing requirements Ensuring potential recruits of any kind are appropriately qualified for positions at the firm Consent: On the basis of any consent that we are required to obtain under applicable law, in relation to our criminal background checks Legal obligation: Acting in compliance with anti-money laundering regulations concerning screening Verifying your right to work lawfully

Automatically Collected Data

When you interact with us through the Mayfair Website, we automatically collect information about you through cookies (small text files placed on your device). Please read our Cookie Policy to learn more about how we use cookies. Our servers also record information (“log data”), including information that your browser automatically sends whenever you visit the Mayfair Website. This log data includes your Internet Protocol (“IP”) address (from which we can discern the country you are connecting from at the time you visit the Mayfair Website), browser type and settings, and the date and time of your request. Where the information that we collect automatically on the Mayfair Website is personal data, our legal basis for the use of this information is that it is necessary for the purposes of our legitimate interests in maintaining the safe operation of the Mayfair Website and learning how Mayfair Website visitors interact with the Mayfair Website to improve your use of it. How We Share Your Personal Data We share your information as follows:

Third party service providers: Third parties who provide services to us have access to your personal data, for example, we engage providers of website analytics, hosting and cloud computing services and other IT services, background checks, talent management and recruitment services, in addition to other administrative services.
Event co-hosts. We may share limited personal data (name, title, employer) with co-hosts of events we host or otherwise sponsor in order to administer the event and provide a list of attendees.
Administrative and legal reasons. We may disclose personal data as we deem necessary and appropriate under applicable laws, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process; in response to lawful requests by public, governmental and regulatory authorities.
Business transfers. We may disclose and transfer your information and data to a third party: (a) if we assign our rights regarding any of the information to a third party or (b) in connection with a corporate merger, consolidation, restructuring, sale of certain of our ownership interests, assets, or both, or other corporate change, including without limitation, during the course of any due diligence process.
Mayfair entities. When using your personal data for the purposes described above, we may share your personal data with other Mayfair affiliates entities around the world. Please read the International Data Transfers section below for more information on how we transfer your personal data.

International Data Transfers For the purposes described in this Privacy Policy, we may transfer your personal data from the European Economic Area (EU Member States, Iceland, Liechtenstein and Norway) or the United Kingdom to a Mayfair affiliated entity or a third party outside of the EEA or the UK. The level of information protection in countries outside the UK and EEA may be less than that offered within the UK and EEA. When we transfer your personal data to outside of the EEA or the UK, for example third party service providers, we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure the integrity and protection of your personal data wherever processed. Retaining Your Personal Data We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws or until you withdraw your consent (where applicable). To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we use your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data. Protecting Your Personal Data We use a variety of technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data, in accordance with our internal security procedures and applicable law. Personal data may be stored on our own technology systems or those of our service providers or in paper files. We also train and instruct our employees that all personal information must be handled in accordance with this Privacy Policy and applicable privacy and data protection laws, and any misuse by employees is subject to disciplinary action. What are your rights? You have the following rights with respect to your personal data:

Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
Right to correct or request deletion: You may ask us to correct, delete or remove your personal data.
Right to object to or restrict processing: You may object to the processing of your personal data and, where you consented to processing, you may withdraw your consent. You may also ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest its accuracy or object to us processing it. If you exercise your rights, we will respect your decision in accordance with our legal obligations.
Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
Right to lodge a complaint with the data processing authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the UK Information Commissioner’s Office (“ICO”). You can find details about how to do this at https://ico.org.uk/concerns

You may exercise your rights under the GDPR by contacting us as indicated under the ‘How to Contact Us’ section below. How To Contact Us If you have any questions about our Privacy Policy, or if you would like to access personal data we hold about you or exercise your other rights under the applicable law, you can contact us at info@mayfairequity.com