This notice (the “Privacy Notice”) provides information about how each of Duke Street LLP, Duke Street General Partner Limited, Duke Street V Limited and Duke Street Management Services Limited (collectively, “we”, “us”, “our”) gather and use personal information. We are committed to respecting the confidentiality of the personal information you supply to us and all such information will be processed in accordance with applicable data privacy laws.
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights in respect of such use. That is why we are providing you with the information in this Privacy Notice.
If you do not agree with our use of your personal data as set out in this Privacy Notice, you should not submit your personal information to us. However, if you do not wish to submit your personal information to us, or if you wish to exercise your rights to prevent us using your data, you should be aware that we may not be able to do business with you. For more information on this, please see sections 4.1 and 7.
Duke Street LLP is a limited liability partnership, registered with number OC356346, whose registered office is Nations House, 103 Wigmore Street, London W1U 1QS.
Duke Street General Partner Limited is a private company limited by shares, registered with company number 03565673, whose registered office is Nations House, 103 Wigmore Street, London W1U 1QS.
Duke Street V Limited is a private company limited by shares, registered with company number 04071494, whose registered office is Nations House, 103 Wigmore Street, London W1U 1QS.
Duke Street Management Services Limited is a private company limited by shares, registered with company number 03565631, whose registered office is Nations House, 103 Wigmore Street, London W1U 1QS.
For the purposes of data privacy legislation, we are each a ‘controller’.
Should you have any questions or concerns about this Privacy Notice or the processing of personal data we hold about you, please contact us:
|By post:||Nations House, 103 Wigmore Street, London W1U 1QS|
|By phone:||+44(0) 207 663 8539|
You have certain rights in relation to your personal data.
Under certain circumstances, by law you have the right to:
If you want to exercise any of these rights then please contact us using the details at section 3. The various rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you wish to withdraw your consent or object to processing, we may need to discuss with you whether our use of your data needs to continue for other lawful purposes, such as fulfilment of a legal or contractual requirement.
We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights set out in section 4.1 above). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, please contact us on the contact details contained in section 3.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office: https://ico.org.uk/global/contact-us/ or 0303 123 1113.
We collect your personal information from a variety of sources, as set out in this Privacy Notice. Where necessary we collect information directly from you or indirectly from third parties, and through your use of our website.
This section details the information we collect about you in the course of your use of our website and otherwise in your interaction and correspondence with us and our representatives. We will collect:
For the purposes of this Privacy Notice:
“Ad Sharing Data” means the number of times that an article shared via our website was viewed on the platform to which it was shared and the number of times such article was liked on the platform to which it was shared;
“Mailshot Data” means the name, employer and email address of a recipient of a mailshot;
“Website Login Data” means email address used to login to the investor login service provided on our website, name of the user that logged into the investor login service provided on our website, the employer of such user, the date and time of last login, login times, login count, documents downloaded from the investor login service provided on our website, pages viewed on our website and number of pages viewed on our website; and
“Website Only Data” means pages viewed on our website, number of pages viewed on our website, clicks per article on our website; geo location and details of whether our website was accessed via desktop or mobile device.
We may receive information about you from third parties such as third party customer due diligence service providers, your advisers (including your financial and legal advisers), our vendors and publically available sources such as company registrars, LinkedIn (or other professional networking databases) or company websites. We may collect the following information from third parties:
We, Google Analytics, our third party data processor (and their sub-processors) and the advert sharing application on our website collect information about your use of our website and the devices you use. That information comprises Website Only Data, Website Login Data and Ad Sharing Data.
The information which we collect and what we use it for will depend on the nature of our business relationship with you. We use your information:
We use your information to identify products, services, opportunities and events that we think may be of interest to you.
We will only send you marketing messages where you have consented to such contact, or in the case of products and services, where these are similar to those that we have already provided to you.
You have the right to ask us not to not send you marketing messages by post, telephone or e-mail or any combination of these at any time. You can also let us know at any time that you wish to change your mind and to start receiving such messages.
You can do this:
Periodically, we will remind you (possibly along with other communications) that you may unsubscribe if you no longer wish to receive communications from us. If you choose to unsubscribe, we will cease to send you such communications as mentioned above.
We are entitled to use your personal data in the ways set out in this Privacy Notice on the following bases:
We may process your sensitive and special categories of information [gann1](this includes data concerning your health, personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning sexual orientation) where we have asked for your explicit consent or otherwise where this is necessary for the establishment, exercise or defence of legal claims. We will erase such information and cease processing it following the expiry of a five year period commencing on the date on which our business relationship comes to an end.
In the case that you have obviously made information public (e.g. on social media) we will process sensitive/special categories of information for the purposes of carrying out our legal obligations.
If provision of your personal information is a legal or contractual requirement or a requirement necessary to enter into a contract with us, and you choose not to provide it, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you.
If you do choose to provide your consent you can withdraw it at any time by contacting us (see section 3).
We will not disclose your personal information to third parties except as detailed in this Privacy Notice.
Where necessary, we disclose your personal data to third parties that are specifically engaged by us to provide services to us or the investment vehicles that we advise, manage, monitor or operate, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us. The following is a list of the types of third parties who process your personal data on our behalf:
We transfer, use and/or store your personal information outside of the European Economic Area (the “EEA”) to the extent necessary to comply with our legal or regulatory obligations and to fulfil functions that we have contractually agreed with you to fulfil. The laws of some of these destination countries may not offer the same standard of protection for personal information as countries within the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our third party service providers (for example, those who supply support services to us). Save as provided for in this paragraph, we will not transfer or process any of your personal data outside of the EEA without your prior written consent.
We currently transfer data to the following countries outside of the EEA:
Transfers to our third party service providers are to enable them to use and store your personal information on our behalf. We will, however, put in place appropriate security procedures in order to protect your personal information. Where your information is transferred to any country outside the EEA, we ensure that this is done using specific legally- approved safeguards. You can request further details and a copy of these safeguards by contacting us (see section 3).
We will keep your information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy which you can request by contacting us (see section 3).
When determining the relevant retention periods, we will take into account factors including:
Unless your personal data is erased on a prior date in accordance with the provisions of section 4.1 above, we shall retain your personal data until it is no longer necessary for the relevant purpose it was collected. In certain cases, personal data will need to be retained until we are dissolved or cease to operate in the private equity industry.
We acknowledge that the information you provide may be confidential and will maintain the confidentiality of and protect your information in accordance with our normal procedures and all applicable laws. We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
In addition, those employees, agents, contractors and other third parties who process your personal data will only do so on our instructions and they will be subject to a duty of confidentiality.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data. Any transmission is at your own risk. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.
We reserve the right, at our discretion, to change, modify, add to, or remove portions from, our Privacy Notice. We will of course notify you of any changes where we are required to do so.
Cookies are small data files that many internet sites automatically download to a user’s computer, phone or tablet’s hard disk. They are primarily used to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of a website, improve the functionality of a website and to compile statistical reports on website activity.
This data is collected primarily for monitoring the usage and performance of our website. We may use your IP address and track browser types to build a profile of our users.
For further information about cookies, visit www.aboutcookies.org or www.youronlinechoices.eu. You can set your web browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, some of our website features may not function as a result. The way in which you adjust your browser security setting varies from browser to browser.