OUR COMMITMENT TO PRIVACY
Your privacy is important to Sunstone Partners Management, LLC and its affiliates (together, “Sunstone,” “our,” “us,” “we” or the “company”). To better protect your privacy, we are providing information explaining our personal data handling practices.
This EU and UK website privacy notice (the “Privacy Notice”) describes how we gather and use personal data that we collect (i) for visitors of this website; (ii) when you opt to receive communications from us; (iii) when you visit our offices; (iv) about representatives of our vendors, business partners or portfolio companies; (v) to conduct business with you; and/or (vi) through other data collection points where we refer to this Privacy Notice. This Privacy Notice does not apply to any processing of personal data by or on behalf of Sunstone that is covered by a more specific privacy notice. Please read this Privacy Notice carefully.
For the purposes of applicable UK and EU data protection laws (the “UK and EU Privacy Laws”), including Regulation (EU) 2016/679 (the “EU GDPR”), the UK equivalent of the EU GDPR (the “UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”), Sunstone and its affiliated general partners and managing members will each be a data controller of any personal data collected by us If you have any questions regarding our use of your personal data, or this Privacy Notice, please submit a request at the link in the footnote below[1] or contact us at the phone number in the footnote below.[2]
We rely on various legal bases under the UK and EU Privacy Laws in order to process your personal data (including basic contact and identifying information and IP addresses, and, where appropriate, more sensitive types of personal data such as passport information, beneficial ownership information, financial information, etc.), including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business, conduct business with you and perform essential or legitimate business operations. We do not collect any information about criminal convictions and offences. We also do not collect any special categories of personal data 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, other than any information you may elect to volunteer to us (such as minority and women owned business status).
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details or other personal information to verify your identity and business relationships for the purposes of anti-money laundering regulations). Failure to provide this information means that we cannot conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.
Further information about why we process your personal data, the legal bases under which we process your personal data, and the justifications we rely on in the limited cases where we need to process any special category personal data, is included in the section headed “Why we use your personal data” below.
You do not need to take any action as a result of this Privacy Notice, but you do have certain rights as described below in the section headed “Your rights”.
THE PERSONAL DATA WE PROCESS AND HOW WE COLLECT IT
We collect your personal data in the following ways, and we only collect the personal data necessary to carry out our business for the purposes set out in the next section headed “Why we use your personal data”:
Information you provide to us and our service providers
We collect your personal data when you decide to interact with us (e.g., information you provide via the “Contact Us” section of the website, when you visit our offices or when you communicate with us over email or the telephone, information you provide via subscription agreements, investor questionnaires, applications or other forms (including any anti-money laundering, identification and verification documentation), information you provide when you apply for a job with us, etc.) including your name, email address, postal address, title, job title, telephone number, passport or other government issued identification, beneficial ownership information and/or financial information, as appropriate.
We may also collect personal data about you such as your IP address 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 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 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, business partners or 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 and/or work telephone number, as appropriate) 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 process information in relation to companies that we are evaluating in connection with a corporate transaction or potential investment. This information may include your personal data including name, title, email address, postal address, job title, telephone number, passport or other government issued identification, financial information and/or job and benefits information, as appropriate.
WHY WE USE YOUR PERSONAL DATA
We may use your personal data for the following purposes:
| Purpose | Legal Basis |
| To conduct business with you or to 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, to operate schedule and facilitate meetings (in-person and online) and to administer your participation in any of our events | 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 (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a potential investor, business partner or supplier | Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely |
| To protect against, identify and prevent, fraud, money-laundering, cyber-attacks, theft of our property and other unlawful activity | Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely and safely |
| To conduct conflicts checks | Legal requirement |
| To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment which are evaluated by us or which we are party to | Our legitimate interest in operating our business and providing our investment services; contractual necessity; and/or legal requirement |
| Corporate transaction and investment reporting | Legal and contractual requirements |
| Litigation management and conducting internal audits and investigations | Legal requirement; and/or our legitimate interest in operating our business |
| To obtain advice from our professional advisors, including lawyers and accountants | 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 |
| For statistical analysis and market research | Our legitimate interest in operating our business |
Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.
No solely automated decision-making, including profiling, is used when processing your personal information.
We will only use your personal data 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 data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
MARKETING COMMUNICATIONS
We will send you direct marketing communications (e.g., marketing newsletters, updates, and alerts by email or LinkedIn) where we have obtained your prior consent to keep you informed of our services in which you might be interested, 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 request that we stop sending you marketing communications by clicking the unsubscribe link in the marketing email, or by submitting a request using the online form at the link in the footnote below.[3]
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 our 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 policy. We use a number of service providers that provide a wide range of services including legal, tax and financial professional advisors, our auditors, consultants, office management companies and security providers, IT and data security providers, data hosting providers and in some instances, placements agents, administration agents, depositaries, investment managers and other fund administrators. We make sure 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 UK or the European Economic Area, such transfers will only be made in accordance with the UK and EU Privacy Laws. For further information about the safeguards used, please contact us or by submitting a request using the online form at the link in the footnote below.[4]
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.
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, measures and policies, so the information we have about you is protected to the extent possible from unauthorized access and 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 and required to keep your personal data secure.
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 Privacy Notice, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact us submitting a request using the online form at the link in the footnote below.[5]
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 we have collected or received personal data from an individual under the age of 18, we will delete that information.
COOKIES
We use strictly necessary cookies only and do not collect any information using those cookies other than anonymized data required for functional purposes.
YOUR RIGHTS
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact us using the online form at the link in the footnote below.[6]
- Access: You have the right to ask for a copy of the personal data that we hold and process 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 data if the information we hold and process about you is inaccurate or it needs to be updated.
- Deletion: If you think that we should not continue to hold or process your personal data, 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 it (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; or (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 on the legal ground 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.
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 Privacy Notice from time to time by updating this Privacy Notice. If we decide to change our Privacy Notice, we will post those changes so our users are always 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 personal data 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 Privacy Notice under which the personal information was collected.
CONTACT US
If you have any questions or concerns about this Privacy Notice, please contact us using the online form at the link below.[7]
COMPLAINTS
Should you wish to lodge a complaint with regards to how your personal data has been processed by us under:
- the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us,
- the EU GDPR, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.
[1] https://sunstonepartners.com/contact/
[2] five-nine-three, one-two-five-zero, in area code eight-seven-seven
[3] https://sunstonepartners.com/contact/
[4] https://sunstonepartners.com/contact/
[5] https://sunstonepartners.com/contact/