CapVest Partners LLP and CapVest Irish Partners Limited (collectively referred to as “CapVest”) are dedicated to protecting the confidentiality and privacy of information entrusted to us. As part of this fundamental obligation, CapVest is committed to the appropriate protection and use of personal information or data that has been collected online.
Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this privacy statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the personal information that we have obtained.
1. Data Protection Legislation
Personal information provided to us (or otherwise obtained by us) is handled in accordance with applicable data protection legislation. For CapVest, the main pieces of legislation of which to comply are the General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 (which gives further effect to the GDPR in Ireland), the Privacy and Electronic Communications Regulations 2003 (which implement the e-Privacy Directive in the UK) and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (which implement the e-Privacy Directive in Ireland).
2. Collection and Use of Personal Information
We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal information to CapVest (if, for example, you are a former employee). If you choose to register or login to the CapVest website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with CapVest, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.
By registering and/or submitting personal information to CapVest, you are also acknowledging that CapVest may use this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to the CapVest website and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other CapVest sites you visit. If you send us a resume or CV to apply online for a position with CapVest, we will use the information that you provide to match you with available CapVest job opportunities.
In some cases where you have registered for certain services we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).
3. Legal Grounds to Use Your Personal Information
CapVest generally collects only personal information that is voluntarily provided by you and is necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
Both the law in the UK and the law in Ireland allow us to process personal information, so long as we have ground under the applicable law to do so. They also require us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:
- Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
- Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
- Legitimate interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
- Your consent: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting email@example.com
4. Special Categories of Personal Data
Under GDPR, certain types of personal information merit a higher level of protection when being processed, or should not be processed at all, due to their sensitive nature. Such types of information are referred to as special categories of personal data. Such data is any information that can be used to reveal any of the following about an individual: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, health, or information concerning a person’s sex life or sexual orientation.
CapVest does not collect any special categories of personal data, except in very limited and nuanced situations. For example, you are attending an event with us and let us know of specific health-related dietary requirements. In any case, we ask that you use your discretion when providing any information that would be considered special category data to us.
5. Automatic Collection of Personal Information
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
A notification banner will appear requiring your consent to collect cookies when you visit our website. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as “user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings. You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web site’s features.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.
Other third-party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.
CapVest uses Google Analytics. More information about how Google Analytics is used by CapVest can be found here: http://www.google.com/analytics/learn/privacy.html
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. CapVest only uses web beacons in accordance with applicable laws.
We and our service providers may use web beacons to track the effectiveness of third-party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
CapVest may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
Social media widgets and applications
The CapVest website may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of our website. Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, the CapVest website may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any CapVest social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
6. Sharing and Transfer of Personal Information to Third Parties
We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:
- Our service providers: CapVest works with reputable partners, service providers or agencies who may process your personal information on our behalf. We will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
- Courts, tribunals, law enforcement or regulatory bodies: CapVest may disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.
- Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
In addition, CapVest may transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. CapVest may also store personal information outside of the EEA. If we do this your personal information will continue to be protected by means of contracts we have in place with those organisations outside the EEA, which are in a form approved by the European Commission (available here). By providing personal information on online, visitors are consenting to this transfer and/or storage of their personal information across borders.
We will not transfer the personal information you provide to any third parties for their own direct marketing use.
We may require you to provide certain personal information in order for you to receive additional information about our services and events. CapVest may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
8. Your Rights
If you have submitted personal information to CapVest, you have the following rights:
- Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
- Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
- Automated Individual Decision-making – You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
- Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
- Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
You can make a request or exercise these rights by contacting firstname.lastname@example.org and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
9. Data Security and Integrity
CapVest has policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite CapVest’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual’s request or until that person asks that the information be deleted.
10. Links to Other Sites
11. Changes to this Privacy Statement
We may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how CapVest is protecting your personal information.
CapVest is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at email@example.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.
We will acknowledge your email within 14 days and seek to resolve your concern within 3 months or receipt. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.
While you have the right to make a complaint in respect of our compliance with data protection law to the Information Commissioner (in the UK) or the Data Protection Commission (in Ireland), we request that you contact us at firstname.lastname@example.org in the first instance to give us the opportunity to address any concerns that you may have.