Policy on processing of personal data by P Capital Partners

P Capital Partners (“PCP”, “we”, “us”, “our”) is committed to protecting the privacy and security of personal data. This Privacy Notice explains how we collect, use, share, store and protect personal data when you interact with us, visit our website, or engage with us as an investor, portfolio company representative, business contact, or service provider.

PCP and the wider M&G group will use the personal information you provide to us, together with other information, for the purposes set out in this Privacy Notice. We obtain information about you during your interactions with our representatives, when you apply for our products and/or services, through analysis of your transactions and activities with us and other members of the M&G group, when you register for any of our events, or when you provide information via our website.

P Capital Partners (registration number 556930-7027) and our registered office is Sturegatan 6 SE-114 35 Stockholm, Sweden. It is part of the M&G Group of entities.
All personal data collected in accordance with this Privacy Notice will be processed lawfully in accordance with applicable Data Protection Laws, including the EU and/or UK General Data Protection Regulation. The personal data we collect is only used for the purposes set out in this privacy notice.
This Privacy Notice explains who we are, how we collect, share and use your personal data, and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal data, then please contact us using the details below:
By post: PCP Sturegatan 6 SE-114 35 Stockholm, Sweden.
By email: de@pcapital.se

Updates to this Privacy Notice
We update this Privacy Notice from time to time in response to changing legal, technical or business developments. You can see when this Privacy Notice was last updated by checking the 'last updated' date given at the end of this document.
You can request a hard copy of the Privacy Notice by getting in touch using the contact details above.
We collect and process the following personal data about you:
- Identification information (e.g., passport, driving licence).
- Contact details.
- Financial and investment information.
- AML/KYC results.
- Website usage data including IP address and cookies
Sharing of Personal Data:
We may share your personal data with:
- Fund administrators.
- Portfolio companies.
- Professional advisers.
- Regulatory bodies.
- IT and cloud service providers.
- AML/KYC screening providers.

Legal basis for processing personal data
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you where we need the personal data to perform a contract with you, to comply with a legal or regulatory obligation or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may collect personal data from you with your consent or may otherwise need the personal data to protect your vital interests or those of another person.

Personal data captured through call recordings where this is necessary to comply with a legal or regulatory obligation, to establish, exercise or defend legal claims, or where it is in our legitimate interests to maintain accurate records of relevant interactions for business, governance, security or quality assurance purposes. Where required by applicable law, we will inform participants when calls are being recorded and rely on consent.

We may also process personal data that is publicly available—such as information contained in official registers, company websites, public filings, press releases or reputable professional networking platforms—where this is necessary for our legitimate interests in conducting due diligence, verifying identity, monitoring regulatory compliance or assessing business related risks. Such processing will only occur where these interests are not overridden by your rights and freedoms, and only where the information has been made public by you or is otherwise lawfully accessible.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the details provided at the end of this notice.

Protecting your personal data
We always maintain the security and protection of any personal data we hold by putting in place administrative, technical, and physical measures designed to guard against and minimise the risk of loss, misuse, or unauthorised processing or disclosure of personal data. We place similar obligations on our service partners and undertake robust risk assessments of their security measures, ensuring that the depth and focus of these assessments are proportionate to the level of risk involved.

Profiling and automated decision making
We do not engage in any profiling activities with your personal data

Your data subject rights
You have certain rights relating to the personal data we hold about you which are outlined below:
Transfers of your personal data outside the UK
Your personal data can be transferred outside of the UK and EEA from time to time to trusted service providers and other third parties when necessary. When we do this; we require third parties to keep your personal data confidential and secure in compliance with applicable data protection laws and regulations. We ensure that suitable protection is maintained by ensuring that appropriate safeguards are in place again in line with applicable data protection laws and regulations.
Where we are required by law to disclose, we may not always have control over the terms under which we are required to share your personal data. We will make sure that any disclosure is lawful.
Retaining your personal data
We retain your personal data for as long as is necessary for the purposes described above.

We keep personal data for as long as it is required by us to meet our legal or regulatory obligations and in the defence of any legal claims.

Profiling and automated decision making
We do not engage in any profiling activities with your personal data
We do not use any automated processes to make decisions about you which produce legal or significant effects concerning you.

Request access to the personal data we hold about you
(Data Access Request)

Object to processing (Right to Object)

Request a copy of your personal data
(Data Portability)

Request that your personal data is deleted (Right to be Forgotten)

Amend or correct your personal data
(Right to Rectification)

You may request access to a copy of the personal data we hold about you.
We can refuse to provide personal data where to do so may reveal another person's personal data or would otherwise negatively impact another person's rights.
You may object to us undertaking automated processes, or fully automating decision making, using your personal data except where used to detect, prevent and investigate fraud and other financial crimes.

You may also object to us using your personal data for direct marketing purposes. This includes any profiling we perform as part of our direct marketing activities. Once we receive and have processed your objection, we will stop using your personal data for these purposes.
Where you gave us the personal data directly and it was processed
electronically, you can request the data we hold on you in a commonly used machine-readable format.

You can ask us to delete the personal data we hold about you when it is
no longer required for a legitimate business need, legal or regulatory obligations, where you have withdrawn your consent or for the purposes it was collected for.
If you believe that the personal data we hold about you is inaccurate, incorrect or incomplete, please contact us as soon as possible so we can update it.

Restrict the processing of your personal data (Right to Restrict)
Rights in relation to consent
(Right to Withdraw)

You may ask us to restrict our processing of your personal data whilst we resolve any complaints you have about the way your data is used, require it for a legal claim, believe
the personal data is not accurate, we no longer need the data, you have objected to the processing of your personal data or if you think our
processing is unlawful but you do not want us to delete your data.
At any time, you may withdraw the consent you granted for your personal data to be used for direct marketing.
When you withdraw your consent, it will not affect the lawfulness of any past activities we have undertaken based on the previous consent.

None of these rights are absolute and are subject to various exceptions and limitations. You can exercise these rights at any time by contacting us using the details below.

Making a data protection complaint
If you have any concerns about the use of your personal data, or the way we handle your requests relating to your rights, you can raise a complaint with us by contacting the privacy team using the details below:
By post: P Capital Partners (PCP), Sturegatan 6 SE-114 35 Stockholm, Sweden
By email: de@pcapital.se

You may complain to your local supervisory authority in the Member State of your place of engagement or Residence.

If you are based in Sweden, or your concerns relate to processing activities carried out in Sweden, you may also raise a complaint with the Swedish Data Protection Authority (Integritetsskyddsmyndigheten, “IMY”). IMY can be contacted via their website at www.imy.se, or by post at:
Integritetsskyddsmyndigheten (IMY)
Box 8114
104 20 Stockholm
Sweden

You may contact IMY at any time if you believe your personal data has been processed in a way that does not comply with applicable data protection laws.

Questions or concerns

Please contact P Capital Partners’ data protection officer, Damla Kesen, by sending an email to de@pcapital.se if you have any further questions or concerns, of if you would like to exercise any of your data protection rights.