EEA-UK Privacy Policy

OUR COMMITMENT TO YOUR PRIVACY

Your privacy is important to Grant Avenue Capital LLC and its affiliates (together, “Grant Avenue”, “we”, “us”, or “our”). To better protect your privacy, we are providing you with information explaining our online information practices.

For the purposes of the EEA-UK Privacy Policy, “UK-EEA Data Protection Legislation” means all applicable legislation and regulations relating to the processing and/or protection of personal data in force from time to time in the European Union (the “EU”), the European Economic Area (the “EEA”), and/or the United Kingdom (the “UK”), including (without limitation): (i) Regulation (EU) 2016/679 (the “EU GDPR”); (ii) the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of Section 3 of the European Union (Withdrawal) Act 2018) (the “UK GDPR”); (iii) and any other legislation which implements or supplements any other current or future legal act of the EU, EEA or the UK concerning the protection and/or processing of personal data and any national implementing or successor legislation, and including any amendment or re-enactment of any of the foregoing. The terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this EEA-UK Privacy Policy shall be interpreted in accordance with the applicable UK-EEA Data Protection Legislation. Unless the context otherwise requires, as used herein the words “include”, “includes” and “including” shall be deemed to be followed by the phrase “without limitation”.

If you are a resident of the EU, EEA, or UK, please read this EEA-UK Privacy Policy carefully as it represents a legally binding agreement between Grant Avenue and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, this EEA-UK Privacy Policy and all additional terms incorporated by reference herein. If you do not agree with any of the terms of this EEA-UK Privacy Policy, please do not access or otherwise use this website. This EEA-UK Privacy Policy applies solely to your interactions with us through this website. If you provide personal information to us through another means (e.g., via email or phone call, or as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

For purposes of applicable EU, EEA, and UK regulation relating to the protection of personal data, as such regulations may be amended or updated from time to time, Grant Avenue will generally be a data controller of any personal data it collects.

Please contact info@grantavecap.com with any questions arising out of this EEA-UK Privacy Notice.

HOW WE OBTAIN YOUR PERSONAL DATA

Information you provide to us

We collect your personal data when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set forth below. You can provide us with personal data via online form, email, post, telephone and this website.

Information provided by third parties or publicly available sources

We collect personal data from third parties, such as background information from a background check provider, personal data viewed on social media, or information obtained from publicly available lists of individuals subject to sanctions or restrictions.

If you represent or work for one of our portfolio companies, we may also collect your personal data (i.e. basic identifying and contact information, including your name, title, work email address, work postal address, job title, or work telephone number), as appropriate from the company that you work for where this is necessary to conduct business, or manage our relationship, 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 data is obtained from third parties involved in that potential transaction (i.e., the company in question).

WHY WE USE YOUR PERSONAL DATA

To the extent you provide us with any personal data, through or in connection with this website (via email, telephone, or post), we may use such information for the following purposes:

Purpose

Legal Basis

To conduct business with you or provide you with the services you have requested.

Contractual necessity; and/or our legitimate interest in operating our business and providing investment services.

To communicate with you.

Our legitimate interest in operating our business and providing investment services.

To keep a record of your relationship with us.

Our legitimate interest in operating our business and providing investment services; and/or legal requirement.

To verify your identity.

Legal requirement; and/or our legitimate interest in operating our business and providing investment services.

To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are a party to.

Our legitimate interest in operating our business and providing investment services; and/or legal requirement.

Fraud and abuse prevention.

Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely.

Litigation management and conducting internal audits and investigations.

Legal requirement; and/or our legitimate interest in operating our business.

To administer and protect our business and this website.

Our legitimate interest in operating our business.

To make suggestions and recommendations to you, or to provide you with updates or other information, about our business and services that may be of interest to you.

Our legitimate interest in operating our business.

DISCLOSURE AND TRANSFER OF PERSONAL DATA

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 this website; any transmission of information or data by you to or through this website is at your sole risk.

Your personal data 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 Privacy Policy, including professional advisors, auditors, consultants, financial institutions, administrators, placement agents, IT and data security providers and/or data hosting providers. We ensure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. To the extent your personal data is transferred to countries outside of the EEA, UK, or EU, such transfers will only be made in accordance with applicable EEA-UK Data Protection Legislation. For further information about the safeguards/derogations used, please contact info@grantavecap.com.

We reserve the right to disclose your personal data 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 data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate data security technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access, disclosure, improper use, and accidental loss. In addition, we limit access to your personal data 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 data 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 data only for as long as is reasonably necessary for the purposes set out in this EEA-UK Privacy Policy, 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 data, please contact info@grantavecap.com.

CAPACITY

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn that we have collected or received personal data from an individual under the age of 18, we will delete that information.

YOUR RIGHTS

You have the right to access the personal data we hold about you, and there are several ways you can control the way in which, and what information, we store and process about you. To exercise these rights and controls, please contact info@grantavecap.com.

Access: You have the right to ask for a copy of the personal data that we hold about you free of charge. However, we may charge a “reasonable fee” if we believe that your request is excessive, or to help us cover the costs of locating the information you have requested.
Correction: You may notify us of changes to your personal data if it is inaccurate or needs to be updated.
Deletion: If you believe that we should not be holding or processing your personal data 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 data (other than storing it), if: (i) you contest the accuracy of your personal data (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your personal data to establish or defend a legal claim; (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, 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.
Portability: If you wish to transfer the personal data that we hold and process about you to another organization (and certain conditions are satisfied), you may ask for us to do so, and we will send it directly if we have technical means.
Withdrawal of consent: If you previously provided us your consent (buy a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to withdraw the consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (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.

NOTIFICATION OF CHANGES

We reserve the right to amend this EEA-UK Privacy Policy from time to time. If we decide to change our EEA-UK Privacy Policy, we will post those changes so our users are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the EEA-UK Privacy Policy under which the information was collected.

CONTACT US

If you have any questions or concerns about this EEA-UK Privacy Policy, please contact info@grantavecap.com.

COMPLIANTS

Should you wish to lodge a complaint with regards to how your personal data 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. In the EU, this is the local supervisory authority in the EU Member State of your habitual residence, place of work, place of the infringement, concern, or complaint.