EEA-UK Privacy Notice Supplement
This EEA-UK Privacy Notice Supplement supplements the Privacy Policy with respect to our use of personal data to the extent that EEA-UK Data Protection Laws (as defined in the Privacy Policy) apply to our processing of your personal data.
Information required to be disclosed under EEA-UK Privacy Notice Supplement regarding the collection of your personal data that is not set forth in this EEA-UK Privacy Notice Supplement is otherwise set forth in the Privacy Policy above. To the extent there is any conflict in respect of any processing subject to EEA-UK Data Protection Laws between the general Privacy Policy and this EEA-UK Privacy Notice Supplement, this EEA-UK Privacy Notice Supplement shall apply. Please read this EEA-UK Privacy Notice Supplement carefully.
You do not need to take any action as a result of this EEA-UK Privacy Notice Supplement, but you may have certain rights as described below in the section headed “Your Rights”.
If you have any questions regarding our use of your personal data, or this EEA-UK Privacy Notice Supplement, please contact info@roseparkadvisors.com.
The Controller
For the purposes of EEA-UK Data Protection Laws, Rose Park and certain of its affiliates will each be a controller of any personal data collected by us. In simple terms, this means that we: (i) “control” the personal data that we collect from you or other sources provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data.
Any Additional Personal Data We May Collect
As discussed in the “The Personal Information We Collect ” section of the Privacy Policy, the types of personal data we collect about you depends on the nature of your interaction with us.
Please note that we 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). Nor do we directly collect any information about criminal convictions and offences.
How We Obtain Your Personal Data
We collect and process your personal data from you and other third parties and/or publicly available sources listed in “How We Obtain Your Personal Information ” section of the Privacy Policy above.
How We Use Your Personal Data and Lawful Basis
Further information about the legal bases under which we process your personal data is included in the section of the Privacy Policy headed “ How We Use the Personal Information We Collect.”
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. 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.
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 to verify your identity for the purposes of anti-money laundering regulations).
No solely automated decision making, including profiling, is used when processing your personal data.
Disclosure and Transfers of Personal Data
Further information about who we may disclose your personal data to is included in the section of the Privacy Policy headed “Disclosure of Personal Information .”
To the extent your personal data is transferred to a Non-Equivalent Country (as defined below), such transfers will only be made in accordance with EEA-UK Data Protection Laws.
For the purposes of this EEA-UK Privacy Notice Supplement,“Non-Equivalent Country”means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK, or the UK Information Commissioner (as applicable) in accordance with the applicable EEA-UK Data Protection Laws to ensure an adequate level of protection for personal data. For further information about the safeguards/derogations used, please contact info@roseparkadvisors.com.
Retention and Security of Personal Data
Information about the legal bases under which we process your personal data is included in the section of the Privacy Policy headed “Security and Retention .”
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EEA-UK Privacy Notice Supplement 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@roseparkadvisors.com.
Your Rights
To the extent the EEA-UK Data Protection Laws apply to our processing of your personal data, you may have the following rights:
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 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 data we hold and process about you is inaccurate or it needs to be updated.
Deletion : If you think that we shouldn’t 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 it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your 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 unless we reasonably demonstrate compelling legitimate grounds for the processing.
Portability : If you wish to transfer your personal data that we hold and process about you on the legal ground of contractual necessity to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
Withdrawal of consent : If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose not specified in this EEA-UK Privacy Notice Supplement, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.
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.
Contact Us
If you have any questions or concerns about this EEA-UK Privacy Notice Supplement, please contact us by emailing us at info@roseparkadvisors.com.
Complaints
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, you may do so with your local supervisory authority, including under:
the UK GDPR and/or Data Protection Act 2018, by contacting the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
the EU GDPR, by contacting 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.
We would, however, appreciate the opportunity to address your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.