PRIVACY POLICY

M3 Capital Partners has created this privacy statement to demonstrate our commitment to privacy.

Our Commitment to you our Client

As a client or prospective client of M3 Capital Partners LLC and/or M3 Capital Partners (UK) LLP and/or M3 Capital Partners (HK) Limited (“M3”, “we”, “us”, or “our”), you may provide us with certain financial and other data. Where your details are provided to M3, we, acting as a data controller, may itself (or through a third party) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (as distinguished from the entity itself) (the foregoing collectively, “Your Personal Information”). This Privacy Policy (the “Policy”) explains how we will collect, store and use any personal data you provide via our website, email or networking with our people and when you otherwise communicate with us (including in the course of the services we provide or the running of our business).

We understand that your relationship with us is based on trust. Because such data is your private information, we hold ourselves to the highest standards with respect to its safekeeping and use. We pledge to you that in all cases we will act responsibly and in your best interests regarding such information. Therefore, we maintain physical, electronic and procedural safeguards to protect your private information. This means that we do not sell information, disclose the fact that you are our client or disclose any of such information, to anyone except as may be permitted under applicable law or regulations.

The Information We Collect About You

M3 collects Your Personal Information from the following sources, as applicable:

1. Client agreements and other information provided by the Client in writing, in person, by telephone, electronically or by any other means (this information includes (i) name, address, income, financial and investment qualifications, and tax-related information, birth date, nationality, passport or other identification number, and employment information); and

2. Other interactions with M3 (for example, discussions with our staff).

The provision of your personal data is voluntary: you may choose not to provide us with the requested data, but failure to do so may inhibit our ability to do business with you.

How We Will Use Your Information

Your Personal Information may be processed by M3 (or any of its affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:

1. to facilitate the management and administration of your relationship with M3 on an ongoing basis (the “Services”) which are necessary to fulfill all related contractual and regulatory obligations;

2. in order to carry out anti-money laundering checks and related actions which M3 considers appropriate or necessary to fulfill any of its legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with M3’s anti-money laundering policies and procedures;

3. to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;

4. to disclose information to other third parties such as service providers (including, for example, attorneys, accountants, auditors, or other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on M3 or in order to pursue the legitimate interests of M3;

5. to monitor and record electronic communications and, if applicable, calls, for any of the purposes specified herein; and/or

6. to otherwise pursue the legitimate interests of M3 relating to your investment and/or where the processing of your Personal Information would be in the public interest.

The Manner in Which We Handle Your Personal Information

You should be aware that some of the third parties with whom we share information, may be located outside your country or the country from which the data is provided. Those countries to which your data may be transferred may not have well developed data protection legislation.

For users within the European Economic Area (“EEA”), your information is controlled by M3 Capital Partners (UK) LLP. For the purposes of this Policy, “European Data Protection Legislation” is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 1998) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (“GDPR”) or any equivalent legislation amending, supplementing or replacing the GDPR. If we need to share your personal data with a recipient outside the EEA we will ensure we do so in compliance with European Data Protection Legislation and we require that appropriate safeguards are in place. To find out more about the appropriate safeguards that we have in place, please contact us.

For users in Hong Kong, you should be aware that we may pass your personal information between our companies both within and outside Hong Kong, including countries which do not have strong data protection laws. However, we will always take steps to ensure that your information is always used in accordance with this Privacy Policy.

We employ security measures to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or as long as the law requires. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You have a right to ask us to provide a copy of the personal data we hold about you. In the event that a request is unfounded, excessive or especially repetitive, we may charge a reasonable fee for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information. That reasonable fee will be based upon the administrative costs of providing the information.

Any changes to our Privacy Policy in the future will be posted to the website and, where appropriate, through email notification.

By using this website you consent to us using the information in the manner set out in this Privacy Policy.

This privacy policy was last updated on 23 May 2018

CONTACT US

If you have any questions, comments or requests regarding our Privacy Policy, please contact our Data Manager using the details set out below:

By post to:

Data Manager
M3 Capital Partners (UK) LLP
180 Piccadilly
London
W1J 9ER

By email to:
inquiry@m3cp.com

If your habitual residence or place of work is within the EEA, and you are unhappy with our processing of your personal data, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement. We would, however, appreciate the chance to deal with any concerns before you approach the supervisory authority, so please contact the Data Manager by email in the first instance.