ATLANTIC BRIDGE SERVICES LIMITED DATA PROTECTION NOTICE
1. PURPOSE AND SCOPE OF NOTICE
This data protection notice ("Notice") is intended to explain how your personal information will be handled by Atlantic Bridge Services Limited ("Atlantic Bridge" "we", "our" and "us) of 22 Fitzwilliam Square, Dublin 2, D02 FH68 and sets out the information including the personal information detailed below relating to you ("Personal Data") that will be collected and processed by Atlantic Bridge and/or on its behalf by its third party service providers in the context of your engagement with us.
If you give us the Personal Data of someone else, please make sure you have the authority to give us such data, and make them aware of this Notice.
For the purposes of this Notice, the controller of your Personal Data is Atlantic Bridge. If you have any questions or concerns about this notice, please contact our Data Protection Representative Des Shiels at 22 Fitzwilliam Square, Dublin 2, Ireland, by phone on +353 1 603 4450, or by email at firstname.lastname@example.org.
2. APPLICATION OF THIS NOTICE
IMPORTANT: Please note that this Notice, while intended to be as complete and accurate as reasonably possible, is not exhaustive and may be updated from time to time in accordance with section 10 of this Notice.
This Notice applies to the way we collect and process your Personal Data. Personal Data will be collected and processed during the course of our relationship with you and for a period afterward as may be required by Irish or European Union law.
During the course of your dealings with us, we will collect Personal Data:
* from you: for example when you communicate with us, visit the Atlantic Bridge premises, work with us or supply us with services, when you supply Personal Data via our website, our Submit a Proposal website form, email, in person, by telephone or otherwise, and subscribe to or express an interest in any of our newsletters or mailing lists; and
* from third party sources: for example companies through which you are connected, or through software platforms we use for business processes, statutory and regulatory authorities, and third party service providers and occasionally some additional sources.
3. WHAT PERSONAL DATA WE PROCESS
Atlantic Bridge will collect and process Personal Data including, where applicable:
* your name;
* your employer, your job title and/or position;
* your contact details, including your address and phone number;
* documentation confirming your identity, such as your passport or driving licence;
* financial information, including information necessary to make or receive payments to and from you and for the purposes of fraud prevention;
* CCTV footage, when you visit our premises;
* details of your visits to Atlantic Bridge and your correspondence, communications and connections with our staff;
* publicly available information;
* any information which is provided to us by you or on your behalf;
* information about your visits to our website(s) such as the domain and host from which you access the Internet, the Internet protocol (IP) address of the computer you are using; the browser software you use; your operating system and the date and time you access the website;
* your business activities and your areas of interest; and
* information relating to your subscription to, receipt of or interest in any of our mailing lists or newsletters.
4. WHY WE PROCESS YOUR PERSONAL DATA
The following table details the key context for which ("Legal Basis") and why ("Purposes") we collect, obtain and process your Personal Data:
NECESSARY FOR ENTERING INTO OR PERFORMANCE OF A CONTRACT
Legal Basis It is necessary to process your Personal Data to enter into and perform our contract with you as part of our investment activities.
Purposes We obtain, collect and process your Personal Data: Entering Into and Performing our Contract with you as part of our Investment Activities: * to determine, perform and execute the terms on which you will engage with us as an investor, investee or investment fund as part of your engagement with us as part of our investment activities ("Investment Activities"); * to ensure the smooth running of the Investment Activities (including all of the activities that need to be undertaken before, during and after your engagement in Investment Activities); * to add you and your contact details to our internal databases as part of the Investment Activities; * to arrange, administer and send you information pursuant to the Investment Activities; * to process payments pursuant to the Investment Activities; and * to administer requests or procedures requested by you pursuant to the Investment Activities. Assessing your eligibility for our Investment Activities * to determine, perform and assess your eligibility for engagement in Investment Activities.
Assessing your eligibility as a Selected International Co-Investment Partner * to determine, perform and assess your eligibility as a Selected International Co-Investment Partner; * to determine, perform and execute the terms on which you will engage with us as a Selected International Co-Investment Partner.
IMPORTANT You are obliged to provide us with your Personal Data as it is necessary to enter into a contract with us for Investment Activities. In the event that you do not wish to provide us with your Personal Data for the above purposes, you may not be able to participate in our Investment Activities.
Legal Basis We may obtain, collect and process your Personal Data where we have a legitimate interest to do so part of your engagement with us as a recipient of our Investment Activities.
Purposes We obtain, collect and process your Personal Data: Assessing your eligibility for the Investment Activities * to determine, perform and assess your eligibility to avail of our Investment Activities as either an investor, investee or investment fund; and * to review any investment proposals submitted by you in the context of your engagement with us or via our Submit a Proposal form on the Atlantic Bridge website. Marketing, News & Events Communications * to provide you with information in relation to our events programme, general news from Atlantic Bridge and other communications from Atlantic Bridge deemed to be of probable interest (please note that you may opt-out of receiving such marketing information by contacting us at email@example.com. Facilitate Atlantic Bridge Events * to add you to our attendee lists for Atlantic Bridge events; * to notify are investment teams of your attendance at Atlantic Bridge events; and Promote Atlantic Bridge For the purposes of promoting Atlantic Bridge and its Investment Activities including: * to photograph and video-record members at Atlantic Bridge events; * to share photographs and recordings of Atlantic Bridge events on social media and the Atlantic Bridge website; and * to produce Atlantic Bridge promotional material.
Responding to Queries * to process and respond to any enquiries, requests, proposals and complaints you may submit to us via our website, e-mail or phone. Improving Website Functionality & Efficiency * to provide, improve, test and monitor the effectiveness of the Atlantic Bridge website; * to monitor metrics such as total number of visitors, traffic data and demographic patterns; and * to ensure the content on the website is presented in the most effective manner for you and to enhance your use of the website. Improving Atlantic Bridge services * to provide and process satisfaction surveys, policy surveys and referral forms; * to process and communicate with you when you end your investment relationship.
IMPORTANT Before we process your Personal Data to pursue our legitimate interests for the above purposes, we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms. Please note you have right to object to the processing of your personal data for direct marketing. You may unsubscribe from Atlantic Bridge marketing communications (including but not limited to information regarding our events programme and general news from Atlantic Bridge) by contacting firstname.lastname@example.org.
COMPLIANCE WITH A LEGAL OBLIGATION
Legal Basis It is necessary to process your Personal Data in order to comply with legal obligations to which we are subject.
Purposes We obtain, collect and process your Personal Data in order to comply with the following legal obligations: * To comply with Irish and European Union company law; * To comply with Irish and European Union tax law; and * To comply with other applicable Irish and European Union laws.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may disclose some or all of the Personal Data we collect from and obtain about you to the following third parties:
* Members and shareholders of Atlantic Bridge;
* Internal business units such as Human Resources, IT, Finance/Payroll, Atlantic Bridge Managers, system administrators and support staff;
* Business and joint venture partners;
* Financial institutions;
* Service providers who provide support services or require your Personal Data to perform the services requested by the Atlantic Bridge;
* IT & website service providers, marketing companies, PR agencies, printers, advertising agencies and other suppliers;
* Other people in your business, organisation or university as applicable;
* Third parties involved in hosting or organising events or trade fairs;
* Professional advisors such as tax or legal advisors, consultants and accountants;
* Regulatory authorities (e.g. enforcement agencies and public bodies); and
* Third parties in connection with the sale or purchase of the Atlantic Bridge or assets owned by the Atlantic Bridge or the Atlantic Bridge group of companies ("Atlantic Bridge Group").
6. ATLANTIC BRIDGE TRANSFERS OF YOUR PERSONAL DATA
We may transfer your Personal Data outside of the European Union ("EU") to other members of the Atlantic Bridge Group and other recipients. Certain recipients who process your Personal Data on our behalf may transfer your Personal Data outside the EU to a country that does not provide an adequate level of protection to your Personal Data. Where such transfers of your Personal Data are made they will be made in accordance with applicable law. Where your Personal Data is transferred outside the EU, this may include transfers on the basis of Standard Contractual Clauses, or as is otherwise permitted by applicable law. Standard Contractual Clauses are a form of data processing contract approved by the European Commission. You can find a copy of these clauses here.
7. RETENTION OF YOUR PERSONAL DATA
In general, we expect to keep your Personal Data for as long as is necessary for the purposes for which it was obtained from the date of collection or, where you enter into a contractual arrangement with us, following the end of the performance of our contract or when you engagement with our Investment Activities ends.
Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.
If you would like to know more about how long we will retain your Personal Data, please contact our Data Protection Representative Des Shiels at 22 Fitzwilliam Square, Dublin 2, Ireland, by phone on +353 1 603 4450, or by email at email@example.com.
8. HOW WE STORE AND SAFEGUARD YOUR PERSONAL DATA
We care about protecting your information. That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your Personal Data. These include measures to deal with a suspected data breach.
We are committed to taking reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures.
9. YOUR RIGHTS AND HOW TO EXERCISE THEM
You have a number of rights in relation to your Personal Data, which are set out in this section 9. In particular these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that in certain circumstances these rights might not be absolute.
Right Further Information
Right of Access You have the right to request a copy of the Personal Data held by us about you and to access the information which we hold about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive.
Right to Rectification You have the right to have any inaccurate Personal Data which we hold about you updated or corrected.
Right to Erasure In certain circumstances, you may also have your personal information deleted, for example if you exercise your right to object (see below) and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this notice.
Right to Restriction of
Processing You have the right to ask us to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data we hold about you is inaccurate or our use of your information is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved.
Right to Data
Portability You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where: (1) we process your Personal Data with your consent or where it is necessary to perform our contract with you; and (2) the processing is carried out by automated means.
Right to Object You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests. Please note you have right to object to the processing of your personal data for direct marketing.
You may unsubscribe from Atlantic Bridge marketing communications (including but not limited to information regarding our events programme and general news from Atlantic Bridge) by contacting firstname.lastname@example.org.
You can exercise any of these rights by submitting a request to our Data Protection Representative Des Shiels in writing at 22 Fitzwilliam Square, Dublin 2, Ireland.
We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within 1 month of receiving your request. We may extend this up to 2 months if necessary however we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights.
You also have the right to lodge a complaint with the Data Protection Commission. For further information see www.dataprotection.ie.
10. CHANGES TO THIS NOTICE & QUESTIONS
We may amend this notice on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately upon communicating the revised notice to you.
If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail and you will have a choice as to whether or not we use your Personal Data in the new manner.
If you have any questions, comments or concerns about the way your Personal Data are being used or processed by Atlantic Bridge, please submit your question, comment or concern in writing to our Data Protection Representative Des Shiels at 22 Fitzwilliam Square, Dublin 2, Ireland, by phone on +353 1 603 4450, or by email at email@example.com.