Privacy policy

Silverfleet Capital respects the privacy of every individual whose personal information it handles. This Privacy Policy explains how Silverfleet collects, stores and uses personal information.

Where used in this Policy, “Silverfleet Capital”, “Silverfleet” or “the Firm”, shall mean Silverfleet Capital Partners LLP, or any of its subsidiaries or related companies. For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented (the “Data Protection Laws”), the Silverfleet company that you have dealings with is the controller of your personal information.

Personal information of business contacts

If you have had contact with Silverfleet, for example from a previous meeting or making contact with the Firm, we may store limited amounts of personal information relating to you, such as your name, job title, employer organisation, (potential) transactions that we have discussed and contact details. We will collect and store this personal information for the purposes of:

• providing periodic business updates (see below);
• organising meetings between you and Silverfleet’s representatives;
• inviting you to events; and
• similar communication of a professional nature.

The personal information we hold about business contacts may be shared with:

• companies who process personal information on Silverfleet’s behalf;
• professional advisors, for example accountants, lawyers or other consultants; and
• other companies within the Silverfleet group.

In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.

Personal information of suppliers and professional advisors

If you are a supplier or professional adviser to Silverfleet Capital, we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation, (potential) transactions that we have discussed and contact details. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received, commissioning further services, and for other purposes of this nature.

The personal information we hold about suppliers and professional advisors may be shared with:

• companies who process personal information on Silverfleet’s behalf;
• professional advisors, such as accountants, lawyers or other consultants; and
• other companies in the Silverfleet group.

In accordance with the Data Protection Laws, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business.

Personal information of actual/potential management teams

If you are involved in a transaction that Silverfleet and/or the funds that it manages or advises enters into, or a potential transaction that Silverfleet considers, we may store personal information such as: your CV, details of your previous employment history, your financial status and dealings, nationality information (including copies of a passport etc), references provided by third parties, and results of other due diligence carried out. This information is collect and stored in order to:

• assessing and administering actual and/or potential transactions;
• assessing your suitability for involvement in future transactions;
• complying with our regulatory and legal obligations, including assessing and managing risk;
• safeguarding our legal rights and interests;
• seeking and receiving advice from our professional advisors; and
• providing periodic business updates, as described below.

The personal information we hold about actual and/or potential management teams may be shared with:

• companies who process personal information on Silverfleet’s behalf and third party outsourced services providers;
• credit reference agencies;
• financial intermediaries;
• professional advisors;
• other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Silverfleet transaction, for example: co-investors, finance providers and investors in Silverfleet’s funds; and
• other companies in the Silverfleet group.

In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that its processing is necessary for our legitimate interests in running our business. Should we enter into a transaction with your involvement, it will also be necessary to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.

Mandatory provision of information

We shall explain to you when the provision of particular information is mandatory and the possible consequences of not providing particular information. Silverfleet will only process the personal information you provide to Silverfleet for the purposes listed above.

Sensitive or special category personal data

Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. Please do not send us sensitive personal data as generally we do not need it.

International transfers of personal information

Silverfleet has operations throughout Europe and as such, the personal information that we hold may be transferred to and stored at a country outside of your country of residence, including countries outside of the EEA. In the event that Silverfleet transfers personal information to Silverfleet group companies or third parties outside of the EEA, we shall endeavour to ensure that those transfers take place in accordance with the Data Protection Laws, for example by entering into data transfer agreements with the recipient.

Cookies

We use cookies (small text files stored in your browser) to facilitate and improve your experience of our website. Certain features of our website depend on cookies to function. These are deemed to be “strictly necessary”. You may still choose to block these cookies by changing your browser’s settings as detailed below, please be aware that our website may not work properly if you do so.

We use analytics services provided by Google. This allows us to collect anonymous usage information to better understand how our website and web-related services are used. Our use of these cookies does not pose any risk to your privacy or your safe use of our website, it does enable us to continually improve our website, making it relevant to your interests and needs.

We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit our website again.

You can choose to refuse cookies, or set your browser to let you know each time a website tries to set a cookie. For further information on cookies, visit www.aboutcookies.org or www.allaboutcookies.org where you can also find information on how to turn them off.

The table below explains the cookies we use and why.

Google may adjust their cookies from time to time, please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage#gtagjs_google_analytics_4_-_cookie_usage to review their latest cookie details.

To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout

By using our website without adjusting your web browser to block them, you are consenting to these types of cookies being stored on your device.

Periodic business updates

We may use personal information that we hold to send you periodic updates about Silverfleet’s business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us (see “Silverfleet Data Privacy Contacts” below), or by clicking the “Unsubscribe” link in any email that you receive.

Retention of personal information

The period for which Silverfleet will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you provide us with your information in connection with a potential management position with one of our portfolio companies, we may keep your information for up to fifteen years from the date of last contact with you.

Your rights

Individuals whose personal information we hold may be entitled to access their personal information, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to the Data Protection Team (info@silverfleetcapital.com). Individuals also have the right to complain about the use of their personal information to the Supervisory Authority, which in the UK is the Information Commissioner’s Office (www.ico.org.uk).

Accuracy and security

Silverfleet will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that Silverfleet holds about you is incorrect please notify Silverfleet (see “Silverfleet Data Privacy Contacts” below).

Silverfleet will take all reasonable steps to protect the confidentiality and security of your personal information, but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Silverfleet responsible for any breach of security unless this is due to Silverfleet’s negligence or wilful default.

Silverfleet’s websites may contain hypertext links to external websites. Silverfleet is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

Silverfleet Data Privacy Contacts

For all enquires, please email info@silverfleetcapital.com

Changes to Silverfleet’s Privacy Policy

Any changes to this Privacy Policy will be posted here, so please check Silverfleet’s Privacy Policy on a regular basis when you visit the Silverfleet website.