OUR COMMITMENT TO PRIVACY
Your privacy is important to Center Rock Capital Partners, LP and its affiliates (together, “Center Rock,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
This privacy notice (“EEA-UK Website Privacy Notice”) applies where you are located in the United Kingdom (the “UK”), the European Union (the “EU”), the European Economic Area (the “EEA”) or Switzerland, in each case to the extent EEA-UK Data Protection Law (as defined below) applies to our processing of your personal information in the following contexts:
- from and about visitors of this website or our other digital platforms;
- when you opt to receive communications from Center Rock, including when you communicate with us offline and online (including via phone, email correspondence or “Contact” links);
- from and about representatives of, or individuals in connection with, our actual or prospective vendors, business partners or portfolio companies;
- to conduct business with you;
- when you apply for a job with us;
- about visitors to our premises and attendants of events or meetings we may arrange; and
- through other data collection points where we refer to this EEA-UK Website Privacy Notice.
This EEA-UK Website Privacy Notice (i) supersedes the general Privacy Policy of Center Rock linked to this website with respect to EU, EEA, UK and Swiss individuals (except in respect of the Capacity, Cookies and Notification of Changes sections of the general Privacy Policy, which apply to this EEA-UK Website Privacy Notice) and (ii) does not apply to any processing of personal information by or on behalf of Center Rock that is covered by a more specific privacy notice, including our privacy notices issued to investors as part of their investment, subscription or interests in our funds.
You do not need to take any action as a result of this EEA-UK Website Privacy Notice, but you do have certain rights as described below in the section headed “Your rights”, however, please read this EEA-UK Website Privacy Notice carefully.
For the purposes of this EEA-UK Website Privacy Notice, “EEA-UK Data Protection Law” means all applicable laws and regulations relating to privacy, protection or processing of personal data in the EEA, EU, UK or Switzerland, including the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the UK’s equivalent to the EU GDPR (the “UK GDPR”) and the Swiss Federal Act on Data Protection.
CONTROLLER OF PERSONAL INFORMATION
For the purposes of EEA-UK Data Protection Laws, Center Rock and certain of its affiliates will each be a data controller of any personal information collected by us. If you have any questions regarding our use of your personal data, or this EEA-UK Website Privacy Notice, please contact the Chief Compliance Officer of Center Rock at [email protected].
THE PERSONAL INFORMATION WE COLLECT
For the purposes described in this EEA-UK Website Privacy Notice, the types of personal information we may collect about you (and which we have otherwise collected in the last twelve (12) months), depends on the nature of your interaction with us, and may include the following:
- Your basic information: such as your name, prefix/title, gender, marital status, age and/or date of birth, job title and/or position.
- Contact information: such as personal and work physical address(es), telephone number(s) and/or email address(es), as well as your username and password that may be required for use on our websites or other digital platforms (such as our “partner access portal” or similar restricted areas).
- Information we obtain by automated means: such as information about your computer / device and IP address, content and traffic data. We may also collect personal data about you through automated technology when you access and use our website, such as cookies and similar technology (please see the “Cookies” section below for information about how we use such technologies).
- Information obtained through communications with us: such as information obtained through telephone calls (which may be recorded for compliance purposes), video communications and other verbal communications, and written correspondence.
- Job applicant information: such as information that you may provide to us in connection with a job application, including CV information and identification documentation.
- Other information: such as background information as made available by third parties or obtained through publicly available sources.
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and nor do we collect any information about criminal convictions and offences. However, there may be limited circumstances where we need to collect this type of personal information (e.g. as part of our legal obligations, in performance of a contract or as may be disclosed in our legitimate interest as part of a job application).
Further information about the legal bases under which we process your personal information is included in the section headed “Why we use your personal information.”
HOW WE OBTAIN YOUR PERSONAL INFORMATION
We may collect and maintain your personal information from the following sources:
- Information you provide to us – we collect your personal information when you decide to interact with us (in an online or offline context) and we only collect the information necessary to carry out our business for the purposes set out below. This personal information can be provided in an online or offline context, including via email, post, telephone, video communications and this website or our other digital platforms, including registration and account information, information provided through online forms, or via any “Contact” or similar pages.
- Information about you through automated technology – we collect your personal information when you access and use our website or other digital platforms through cookies and similar technology.
- Information provided by third parties or publicly available sources – this may be personal information contained in CV sent to us by a recruiting firm, background information from a background check provider, personal data we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions. If you represent one of our vendors or business partners or portfolio companies, we may also collect your personal information from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party. We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. This personal information is often obtained via third parties (i.e., the company in question).
WHY WE USE YOUR PERSONAL INFORMATION
We may use the personal information collected by us as described above for one or more of the following purposes and on the following legal bases:
| Purpose | Legal Basis |
| To conduct business with you (including to assess you as a job applicant) or to provide you with the services or products you have requested, including to provide you with support and to communicate with you, including responding to requests for information submitted by you to us. | Contractual necessity; and/or our legitimate interest in operating our business |
| Ongoing operations, administrative, reporting and other processes, including to operate, schedule and facilitate meetings (in-person and online), to administer your participation in any of our events or to assess your job application. | Legal requirement; contractual necessity; and/or our legitimate interest in operating our business |
| To keep a record of your relationship with us. | Our legitimate interest in operating our business; and/or legal requirement |
| To verify your identity (including for conflict checks, to conduct anti-money laundering or KYC checks and to enable you to access our offices or to evaluate a business partner or supplier). | Our legitimate interest in operating our business; contractual necessity; legal requirement; or consent (depending on the applicable context) |
| To evaluate or conduct activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to. | Our legitimate interest in operating our business |
| Fraud and abuse prevention. | Legitimate interest |
| Litigation management and conducting internal audits and investigations. | Our legitimate interest in operating our business; and/or legal requirement |
| Complying with our legal obligations (including responding to law enforcement requests and as required by applicable law, court order or government regulations) and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you. | Legal requirement; and/or our legitimate interest in operating our business |
| To administer and protect our business and this website, products and services, databases, technology assets and business including to detect security incidents and to protect against malicious, deceptive or illegal activity (including to ensure compliance with our terms of use). | Our legitimate interest in operating our business |
| To make suggestions and recommendations to you (including to provide you with updates or other information) about our business and services that may be of interest to you, including in relation to services that are similar to those services we currently provide, or previously provided, to you. | Consent or our legitimate interest in operating our business where we have an existing relationship with you |
| Corporate transaction and investment reporting. | Our legitimate interest in operating our business and/or legal requirement |
| For statistical analysis and market research. | Our legitimate interest in operating our business |
| For any other purpose that has been notified in writing. | As identified in the relevant notice or where the data subject has given consent to the processing of their personal information for the specific purpose. |
We may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal data.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so (which may require obtaining your consent).
If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, a failure to provide this information means that we may not be able to conduct business with you or provide our services or products to you. In this case, we may have to cancel our business arrangement you have with us.
No automated decision-making, including profiling, is used when processing your personal information.
MARKETING
As detailed above, we may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by emailing the Chief Compliance Officer of Center Rock at [email protected]. You can also click on the “opt-out”/unsubscribe link provided in all our marketing emails.
DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION
Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this EEA-UK Website Privacy Notice, including our fund administrators, advisory board members, professional advisors, auditors, recruitment firms, consultants, placement agents and data hosting and data security providers. We seek to ensure that anyone who provides a service to, or for us, involving personal data enters into an agreement with us and meets our standards for data security.
To the extent your personal information is transferred to a Non-Equivalent Country (as defined below), such transfers will only be made in accordance with EEA-UK Data Protection Laws. For the purposes of this EEA-UK Website Privacy Notice, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; (iii) Switzerland or (iv) a country or territory which has at the relevant time been decided by the European Commission, the Government of the UK pr the Swiss Federal Data Protection Commission (as applicable) in accordance with the applicable EEA-UK Data Protection Laws to ensure an adequate level of protection for personal data. For further information about the safeguards/derogations used, please contact the Chief Compliance Officer of Center Rock at [email protected].
We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal information to third parties involved in those activities, including the new owner(s) or investors of the relevant business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL INFORMATION
We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, and physical, electronic and procedural protections so the personal information we have about you is protected to the extent possible from unauthorized access and improper use. Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or personal information by you to or through this website is at your sole risk.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this EEA-UK Website Privacy Notice, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact the Chief Compliance Officer of Center Rock at [email protected].
YOUR RIGHTS
To the extent that the EEA-UK Data Protection Laws apply to our processing of your personal information as described in in this EEA-UK Website Privacy Notice, you may have the following rights:
- Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
- Deletion: If you think that we should not be holding or processing your personal information anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests, unless we reasonably demonstrate compelling legitimate grounds for the processing.
- Portability: If you wish to transfer your personal information that we hold and process about you on the legal basis of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
These rights are not absolute and in certain circumstances their exercise may not be possible including when personal information must be maintained to comply with applicable laws.
To exercise these rights and controls or to make a complaint, please contact the Chief Compliance Officer of Center Rock at [email protected]. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
CONTACT US
If you have any questions or concerns about this EEA-UK Website Privacy Notice, please contact the Chief Compliance Officer of Center Rock at [email protected].
COMPLAINTS
Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.