At Lion Capital, we are committed to protecting and respecting your privacy. This policy explains how we collect and use any personal information (i.e., any information that relates to you and that identifies or can be used to identify you) that you share with us both via the Lion Capital website (the “Website”) and in an offline context, including how we collect, process, protect and share your personal information.

You do not need to take any action as a result of this privacy policy, but you may have certain rights as described below.

We keep this privacy policy under regular review and will advise you of any updates or changes to this privacy policy from time to time. This privacy policy was last updated on 24 May 2018.

When you provide us with your personal information, Lion Capital LLP and, in each case, its affiliated companies (together, “Lion Capital”, “we”, “us” and “our”) act as “data controllers” as such term is defined in Regulation (EU) 2016/679 (the General Data Protection Regulation). In simple terms, this means that we: (i) “control” the personal information that you provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect such personal information, but only to the extent that we have informed you about the use or are otherwise permitted by law.

If you have any questions regarding our use of your personal information, or this privacy policy, please contact Lion Capital’s Compliance Officer, Simon Brown at Brown@lioncapital.com.

 

1. What information do we collect about you?

The types of personal information we collect about you depends on the product or service you have requested from us and/or the nature of your interaction with us. The types of personal information we collect includes:

• technical information: this will include information such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information (if appropriate), browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

• information about your visit: this will include the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;

• personal information including name and email addresses as may be provided by you by email or telephone when contacting us or creating user profiles; and

• statistical information about your visit to the Website including the pages you visited and which browsers are used to visit the Website.

The personal information collected about you will help us provide you with a better service and facilitate our business relationship.

We do not knowingly collect or solicit personal information from anyone under the age of 16.

2. How we obtain your personal information

We collect information about you directly when you provide it to us in correspondence and conversations (including via email and telephone) and through forms and contracts we may enter with you. We may also receive information about you from your employer, service providers or other transaction parties in connection with our review of investment opportunities. Depending on the nature of the relationship, such may include information about your name, address, email address, date of birth, passport details or other national identifier, driving licence, your national insurance or social security number and income, employment information and details about your investment or retirement portfolio(s).

In connection with an employment inquiry, we also collect information regarding your work authorisation status, education history, employment history and professional designations; and other information about your qualifications.

We will only collect and process personal information about you where we have a lawful basis to do so (please see section 3 below).

We may combine personal information that you provide to us with information that we collect from, or about you, in some circumstances. This will include information collected in an online or offline context.

3. Why we use your personal information

We will use the personal information you provide us with for the following purposes, and pursuant to the corresponding legal basis:

Purpose	Legal Basis
To enter into, and perform, contracts with you that you have requested.	Contractual necessity
To improve the Website and the products and services that we offer and notify you about changes to our services.	Legitimate interest
To respond to requests for information submitted by you through the Website.	Legitimate interest
To keep a record of your relationship with us.	Legitimate interest
To assess your qualification for available employment opportunities.	Legitimate interest
To conduct know-your-customer, anti-money laundering and similar reviews in connection with potential investments.	Legitimate interest

Additionally, we will use your personal information to keep you informed of our products and services (e.g. future funds that we are raising) based on our legitimate interest where we have an existing relationship with you and we wish to contact you about products and services similar to those, which we provide you, in which you may be interested.

No automated decision-making, including profiling, is used when processing your personal information.

4. Who we share your personal information with

We will share your personal information with third parties as required by law or regulation.

We will also share your personal information with affiliates and certain service providers and professional advisors, including our lawyers, auditors and other professional advisors and service providers as necessary to fulfil the purposes set out in this privacy policy.

We will require that any third party that acts as a data processor on our behalf:

(i) enters into an agreement with us and meets our standards for data security;

(ii) does not use your personal information for any purpose other than the clearly defined purpose relating to the service that such party is providing;

(iii) treats your personal information as confidential; and

(iv) holds your personal information securely and retains it only for such period of time as we instruct.

We will also share your personal information with applicable third parties in the event of a reorganisation, merger, sale, acquisition, assignment or other disposition of all or a portion of our business, assets or shares.

5. How we keep your personal information secure

We are committed to protect the personal information you entrust to us, and to that end we employ appropriate organisational, physical, technical and procedural safeguards to protect your personal information in our possession or under our control to the extent possible from unauthorised access and improper use.

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.

6. Our retention of your personal information

We will keep your personal information only for as long as is necessary for the purposes it was collected, set out in section 3 of this privacy policy, unless a longer retention period is required under applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Transfer of your personal information

To the extent that you reside in the European Union, or EU data privacy legislation applies to you, and we transfer your personal information to countries located outside of the European Economic Area (“EEAM”), such transfers are made in accordance with applicable data privacy laws. For further information on the safeguards applied to such transfers of personal information, please contact us at Brown@lioncapital.com.

8. Your rights

To the extent that you reside in the European Union, or EU data privacy legislation applies to you, you have the right to access the personal information we hold about you, and there are, subject to certain limitations, a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us at Brown@lioncapital.com.

• Access: You have the right to access the personal information that we hold about you free of charge (subject to certain situations where we may charge a ‘reasonable fee’).

• Correction: You have the right to correct any inaccuracies in the information we hold about you.

• Deletion: You have the right to request that we delete your personal information in certain situations (subject to any legal obligations for us to retain it).

• Restrictions on use: You may request that we stop processing your personal information (other than storing it): (i) while its accuracy is verified; (ii) if the processing is illegal; (iii) if the processing is no longer necessary for the purposes for which it was collected; or (iv) if 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 (from which you may opt-out at any time); (ii) for research or statistical purposes; and/or (iii) where processing is based on legitimate interests.

• Withdrawal of consent: If you previously gave us your consent to process your personal information for a particular purpose, you may withdraw that consent at any time.

This website may contain links to other websites. Lion Capital is not responsible for the privacy practices or the content of such third party websites. Please see our Terms and Conditions for more information about our online terms and policies.

9. Cookies

The Website uses cookies. A cookie is a small file of letters and numbers which is downloaded to your device when you visit a website. Whenever you visit the same website again, the information stored in the cookie can be retrieved to notify the website of your previous activity. We use cookies to facilitate website navigation, maintain quality of online service, provide additional security, allow the customisation of your access to the Website and to remember you when you return to the Website.

A cookie cannot give us access to your computer or to information beyond what you provide us and we don’t store personally identifiable information such as your name or address in cookies we create, but we do use encrypted information gathered from them to help improve your experience of the Website. If you don’t wish to enable cookies, you’ll still be able to browse the Website and use it for research purposes.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off/on certain cookies. You do this through your web browser settings. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookie settings.

When you visit the Website you may notice some cookies that aren’t related to Lion Capital. If you go on to a web page that contains embedded content you may be sent cookies from these websites. We don’t control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.

If you’d like to learn more about cookies in general and how to manage them, visit aboutcookies.org or www.allaboutcookies.org/.

10. Contact us

For any questions regarding our processing of your personal information (including the rights and controls explained in section 7 of this privacy policy) please contact us at Brown@lioncapital.com.

11. Complaints

If you reside in the European Union, or EU data privacy legislation applies to you, and should you wish to lodge a complaint with regards to how your personal information has been processed by Lion Capital, please contact your local supervisory authority. In the UK, this is the Information Commissioner (https://ico.org.uk/).

12. Governing Law and Jurisdiction

This privacy policy is governed by and is to be construed in accordance with English law. The courts of England and Wales shall have exclusive jurisdiction to settle any dispute arising out of or in connection with this privacy policy.