Effective Date of Current Policy: January 2020
Identity and contact details of data controller
SIG Capital Management LP
Avery House, 8 Avery Hill Road
SE9 2BD, London
Personal Information We May Collect About You
SIG Capital may collect personal data through a range of means. These may include:
When you contact us using our contact details on the website, any personal information submitted (e.g. your name or email address) will be collected and processed by us. We may also process your personal information, such as your username and password, when you use the investor login function on the website.
Direct interactions (where you provide personal data to SIG Capital through telephone or email correspondence or other direct methods of communication, including applications to invest in SIG Capital’s funds or for prospective employment).
From third parties such as intermediaries and banks in the case of prospective investors or third party recruitment firms in the case of prospective employees.
Other publicly available sources (such as a websites (for example, LinkedIn) or publicly available registries (for example, FCA or other regulatory registers)).
In the case of prospective candidates for employment opportunities at SIG Capital, you or your personal referees may share personal information about you with SIG Capital.
We automatically collect basic technical information from all visitors to the website. We collect technical information during your visit to our website through our automatic data collection tools, which may include cookies and other commonly used technologies (e.g. web beacons). Please see the Section on Cookies below for further information.
How We Use Your Personal Information
The provision of personal information by you may be necessary where we have a legitimate interest to carry out the following purposes: (i) to contact you and respond to your enquiry or provide you access to specific information or offers; (ii) to support our relationship with you; (iii) to understand how we can improve our products and services; (iv) in the case of candidate data, to assess your suitability for roles that you have applied for, carry out background checks and to comply with legal or regulatory obligations (v) to personalize your visit to the website and to assist you while you use the website; (vi) to send marketing communications to you; (vii) to improve the website by helping us understand who uses the website; and (viii) to comply with applicable laws, regulations or codes of practice. Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.
Information about past, current and prospective investors in SIG Capital may be used by SIG Capital (a) for the purposes of discussing and reviewing potential investments in SIG Capital (b) assessing an investor’s appropriateness to invest in the fund as an unregulated collective investment scheme (c) to carry out SIG Capital’s obligations relating to contracts to be entered into between SIG Capital and you; (d) for the general administration of potential investments into the SIG Capital funds; and (e) to comply with legal or regulatory obligations applicable to SIG Capital.
Sharing Your Personal Information
Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer your personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise.
Given the global nature of SIG Capital’s activities, where you are located in the European Economic Area (the “EEA”), personal information collected from you, including via our website, may be transferred to recipients including other SIG Capital entities in countries located outside the EEA, including the U.S., which are not considered by the European Commission to provide an adequate level of data protection.
SIG Capital has entered into EU standard contractual clauses (“Model Contracts”) for intra-group transfers of personal information. You can request a copy of these Model Contracts by submitting your request via email to: firstname.lastname@example.org.
Individuals in Europe have certain data subject rights which may be subject to limitations and/or restrictions. These rights may include: (i) the right to request access to and rectification or erasure of their personal information; (ii) the right to obtain restriction of processing or to object to processing of their personal information; and (iii) the right to ask for a copy of your personal information to be provided to you, or to a third party, in a digital format. If you are based in the EEA and would like to exercise one of the above mentioned rights, please send us your request via email to: email@example.com. Individuals in the EEA also have the right to lodge a complaint about the processing of their personal information with their local data protection authority.
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
When you visit our website, we may place a “cookie” or other online tracking device (e.g. web beacons) in order to improve your experience by recognising you when you visit the website, such as by assigning a session ID and to deliver content specific to your interests. The cookies we place may also collect information about your IP address, or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.