Alantra Partners, S.A., together with its subsidiaries and affiliates (the “Alantra Group” or “Alantra”, “we” or “us”), is a global provider of investment banking, asset management and wealth management services

General

This Privacy Policy (the “Policy“) is to explain what personal data the Alantra Group collects and how Alantra uses it. Personal data is any data which is provided to us or which we obtain that can be used to identify you (“you”) or that Alantra can link to you (“Personal Data”).

For the purposes of data protection law, Alantra is a data controller in respect of your Personal Data. You can find contact details of our subsidiaries and affiliates, and the details of the data controllers within the Alantra Group, by contacting Alantra in accordance with the “Our Contact Information” section below.

Our commitment to privacy

We believe that the responsible use of Personal Data collected is critical to our business objectives and reputation. As part of our commitment to privacy, we have adopted this Policy.

Categories of personal data processed

We will process the following Personal Data:

• When you provide it to us (e.g. sending us emails, signing an agreement, filling forms, contacting us via telephone or visiting or making an enquiry through our websites, or by any other means).
• Identifying Personal Data: name, address, email address, telephone, ID number,
• Data related to commercial activities and invoicing of services
• Data related to the use of services: enquires made, your interests, statistics on the use of services
• Browsing Personal Data: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information Data related to social media interaction: the information included in your profile.
• Data related to applicants: your CV, work experience, references
• KYC data: Identification and financial data to comply with AML regulations: name.
• CRM data: Name, employment history, position, company, email, telephone, address, business sector, type of company, Alantra contacts, registry of meetings, assistant’s name and contact details
• Data from whistleblowing complains: name, position, contact details of reporters (telephone, email), name, position, and contact details of reportees (telephone, email).

Sources of personal data we collect

The Alantra Group may collect Personal Data about you, subject to applicable law, from a variety of sources as follows:

• provide you with a personalised service;

• When you provide Personal Data to us (e.g. sending us emails, signing an agreement, filling forms, contacting us via telephone or visiting or making an enquiry through our websites, or by any other means). If you are a contact registered in CRM, we may create statistics about interactions with Alantra based on the intensity of e-mail correspondence.
• In the ordinary course of our relationship with you (e.g. in the course of managing your transactions or your investment in our funds, and in transactions and meetings).
• Where you apply for a job with us, we may collect Personal Data from you and additional data from third parties (where relevant) such as your CV and any references.
• That you manifestly choose to make public, including via social media (e.g., we may collect information from yoursocial media profile(s), to the extent that you choose to make your profile publicly visible and interact in social media with us).
• From third parties that may provide Personal Data to us (e.g., your employer; our clients; credit reference agencies; law enforcement authorities; etc.).
• From third parties, where you purchase any of our products or services through such third parties.
• When you visit any of our websites or use any features or resources available on or through a website. When you visit a website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.
• Alantra may also record the phone calls with clients, potential clients and third parties, both inbound and outbound calls in accordance with financial regulations.
• When you make a report in our whistleblowing inboxes.

Where you provide Personal Data on behalf of another individual, you are responsible for notifying that individual that you have provided their Personal Data to us and directing them to this Policy so they can see how we will process their Personal Data.

The purpose and legal basis of personal data processing

Categories of personal data	Purposes of processing	Legal basis
CRM data, contact details, e-mail and data from marketing forms and meetings	To provide you with information on market trends and opportunities. To engage in marketing and business development activities and understand the effectiveness of our marketing. To understand our clients and their business objectives. To manage the relationship with our clients. To provide with a personalized service. To carry out analysis and create statistics about e-mail interactions with contacts registered in CRM.	Legitimate interest to market products and services and consent (if required).
KYC data (identification and financial data)	To verify your identity (including for fraud prevention purposes), to assess your ability to meet your financial commitments (if any) and manage Alantra’s relationship with you and/or the client to whom you are connected. To carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management. To comply with Alantra’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations. To update and enhance client records. To defend Alantra or our partners against or exercise legal claims and investigate complaints; and inspection procedures.	Compliance with legal obligations. Legitimate interests to prevent fraud.
Data related to commercial relationship and the provision of services	To perform the contract with you or a client/supplier to whom you are connected. To improve our products and services.	To perform legal contracts. Legitimate interest to improve our products and services.
Browsing data and data obtained from cookies	To keep our site and systems safe and secure. To improve our website and your experience. To know your interests.	Legitimate interest to analyze interactions through the website and to improve the website experience.
Social media data	To interact with customers and contacts, to market products and services and to improve products and services.	Legitimate interest of Alantra to market its products and services and to interact with customers and contacts.
Applicants data	To manage recruitment processes.	Legitimate interest to manage recruitment processes and to carry out precontractual measures.
Whistleblowing data	To ensure misbehaviors are reported to comply with applicable regulations.	Compliance with legal obligations. Legitimate interest to prevent and investigate misbehaviors.

Marketing materials, event invitations and news

The legal basis for processing your Personal Data for receiving marketing materials from the Alantra group, event invitations and news is:

• Consent – we may need your consent to use your Personal Data by asking you to sign up to our marketing databases, for example to receive commercial communications by electronic means. You can withdraw your consent by contacting us in accordance with the “Our Contact Information” section below.
• Legitimate interest – we may use your personal data for our legitimate interests to contact you to invite you to an event, interact with our clients and to improve our products and servives.

If you do not wish to receive Marketing Materials from us you can opt out at any time by contacting Alantra using the details set out in the “Our Contact Information” section below. Your request will be analyzed and answered within one (1) month from receipt by us. Such withdrawal does not affect the legality of the operations for processing of your Personal Data prior to it. You may still receive other information directly from Alantra Group staff and employees you are in touch with based on the legal grounds applicable for the case (e.g. performance of a contract).

Transfers of data

As an international group we share information between our offices (you can find contact details for our subsidiaries and affiliates, by contacting Alantra in accordance with the “Our Contact Information” section below), and your Personal Data may be transferred and/or accessed by some of those entities for the mentioned purposes. Some of these offices are located outside the European Economic Area (EEA) and the laws in these countries may not provide the same level of protection as in countries within the EEA. However, all our offices at all times will ensure a level of data protection at least as protective as that required in the EEA and will implement adequate safeguards to comply with applicable law. We may also instruct third party suppliers to perform services such as software support, e-marketing campaigns, hosting our website, etc. on our behalf. In such cases we take the necessary contractual steps to ensure the adequate protection of your Personal Data.

In principle, your our Personal Data will not be assigned to to other third parties acting as data controllers, apart from the following limited circumstances:

• When we host a joint event with a third party, and you register to attend it. In such cases, you will be informed in advance that this is a joint event and if you register to attend it, your contact data will be shared with the other event organizers.
• In case of an inspection, complain or report by authorities or in case Alantra needs to make a report to the authorities to comply with applicable law.
• In case of a claim before courts.

Your rights

In accordance with the relevant provisions, you have the right to:

• Confirm whether Alantra is processing Personal Data that concerns you, and access to the Personal Data Alantra holds about you.
• Request the rectification of Personal Data.
• Request the erasure of Personal Data in certain circumstances (there may be cases where Alantra is legally entitled to retain it such as the defense against potential claims).
• Request the limitation of the processing of your Personal Data (again, there may be cases where Alantra is legally entitled to continue processing your Personal Data).
• Object to the processing of your Personal Data, in which case, Alantra shall cease to process your Personal Data (except where Alantra is legally entitled to continue processing your Personal Data).
• Data portability, i.e. receiving, in a structured, widely-used format that can be mechanically read, the Personal Data that concern you and that you have provided to Alantra or request that Alantra transfers them directly to another controller when technically possible.
• Withdraw the consent granted, although in certain circumstances it may be lawful for Alantra to continue processing your Personal Data where Alantra has another legitimate reason (other than consent) for doing so.
• Lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by the Alantra Group.

You can exercise your rights by contacting Alantra using the details set out in the “Our Contact Information” section below. Your request will be analyzed and answered within one (1) month from receipt by us.

You can find out more information about your rights by contacting the relevant data protection authority. We can, on request, tell you which data protection authority is relevant to the processing of your personal data. To know the contact details of EU data protection authorities please check https://edpb.europa.eu/about-edpb/about-edpb/members_en

Data retention periods

The Personal Data provided will be kept for the period determined by various criteria including: (i) legal retention periods; (ii) term of the contractual relationship and service of any responsibilities derived from said relationship; and (iii) If and when applicable request of removal by the interested party.

Security

Keeping your Personal Data secure is of utmost importance to us. We take appropriate technical and organizational measures according to industry standards to keep your information secure and protect it from unauthorized use or damage, both online and offline. For security reasons we cannot disclose these measures in details.

Data Protection Officer contact details

For any doubts or queries about your personal data you may contact Alantra’s Data Protection Officer by sending an email to [email protected]

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RECRUITMENT PROCESS DATA PROTECTION CLAUSE

Please note that registering and using Alantra’s recruitment platform Alantra Career Site and participating in Alantra’s recruitment process implies that the Alantra Group will process your personal data as described below:

• Which personal data will be collected? The following personal data will be processed in the context of your registration and use of Alantra’s recruitment platform and in the  context of the recruitment process:
  • Identyfing personal data: name, contact information, image and voice, age, address, telephone number, email address, date of birth, nationality
  • Your CV including your education, qualifications, interests, training and work experience
  • Any personal data included in the information provided in the recruitment process including interviews
  • Personal data included in public sources such as associations, registers, professional organizations
  • Information from third party referrals
  • Your interactions in social media

• Who will be the data controller? The personal data will be controlled by Alantra Partners, S.A., Calle de José Ortega y Gasset 29, 28006, Madrid, Spain. You may contact Alantra’s Data Protection Officer by sending an email to: [email protected] or by post, sending a letter to the Risk and Compliance Department at the following address: Alantra Partners, S.A., Calle de José Ortega y Gasset 29, 28006, Madrid, Spain. Your personal data will be assigned to the Alantra companies that may be interested or involved in your recruitment. You will be informed of the identity of those companies. You may access a list of the Alantra companies in the following link: https://www.alantra.com/global-presence/

• How will the personal data be collected? Your personal data will be collected directly from you, as a consequence of your registration in the recruitment platform […], your browsing in the platform, your participation in the recruitment process, and from the following third parties:
  • Public registrations and sources to carry out background checks
  • Third parties you may indicate as a source of references or referrals

• For what purposes will your personal data be processed? Your personal data will be processed for the following purposes:
  • To manage your registration to the Alantra recruitment platform
  • To manage your participation in the recruitment process including interviews
  • To manage the pre-contractual process including the negotiation of a job offer and/or an employment contract
  • To contact you by email or by telephone for future recruitment processes
  • To carry out background checks and ask for references to third parties
  • To interact with you in social media
  • The information collected from the use of cookies in the recruitment platform will be used to facilitate how you use it, to follow how you interact with it and to improve it

• Which is the legal basis for the processing? The legal bases to process your personal data will be:
  • To manage your registration to the Alantra recruitment platform: the legitimate interest of both parties in the management of your application and registration and Alantra’s legitimate interest to manage the recruitment processes globally
  • To manage your participation in the recruitment process including interviews: legitimate interest of the parties in the recruitment process
  • To manage the pre-contractual process including the negotiation of a job offer and/or an employment contract: to fulfil the pre-contractual/contractual relationship
  • To contact you for future recruitment processes: legitimate interests of both parties to manage or participate in future recruitment processes
  • To carry out background checks and ask for references to third parties: legitimate interest to know the applicants and consent (that will be provided verbally by you when providing the third party’s contact details) to ask references to those third parties indicated by you

• To interact with you in social media: based on the parties legitimate interest to interact with each other

• To follow your interaction with the platform: based on Alantra’s legitimate interest to know how you use the platform, to facilitate the browsing and to improve the platform

• Who will your personal data be shared with? Your personal data will be shared within the Alantra Group. The personal data may also be accessed by Alantra’s service providers.

• International data transfers: As an international group and to manage recruitment processes the Alantra Group shares information amongst its offices (for information on its global presence please refer to : https://www.alantra.com/global-presence/), and therefore your personal data may be transferred and/or accessed by some of those entities for the mentioned purposes. Some of these offices are located outside the European Economic Area (EEA) and the laws in these countries may not provide the same level of protection as in countries within the EEA. However, all our offices at all times will ensure a level of data protection at least as protective as that required in the EEA and will implement adequate safeguards to comply with applicable law. We may also instruct third party suppliers that are located outside of the EEA, such as Workday Inc. that manages Alantra’s Career Site. In such cases we take the necessary contractual steps to ensure the adequate protection of your Personal Data that may include entering into the corresponding standard contractual clauses approved by the European Commission. For more information on international data transfers please contact [email protected].

• For how long will your personal data be processed? Your personal data will be retained for a two years period if your application is not successful. If you become an employee of the Alantra group, your personal data will be retained as long as the employment contract is in force and until legal responsibilities may be derived from the employment relationship.

• Which rights do you have in relation to your personal data? You will have the right to access, rectification, erasure, objection, restriction of processing and data portability in relation to your personal data by sending a written communication to [email protected]. Please be informed that you may file a complaint before the corresponding data protection supervisory authority: https://edpb.europa.eu/about-edpb/about-edpb/members_en