Policy on processing of personal data by P Capital Partners

P Capital Partners AB, reg. 556930-7027, (“P Capital Partners” or “we”) . We are part of the M&G Investment group; a list of the key entities within that group is available here.

P Capital Partners wishes to provide you with company related information, such as newsletters, financial reports and other forms of correspondence in the course of business, and therefore takes this opportunity to inform you of how we collect and process your personal data.
This information is provided to you in light of the General Data Protection Regulation (EU) 2016/679.

Handling of personal data

P Capital Partners takes the privacy and protection of your personal data seriously. So we’ve set out below information about our processing of your personal data, what rights you have, and how you can get in touch if you want to know more. The concept of personal data encompasses any form of information relating to you or that can be linked to, or used to identify, you. This includes, for example, your name, date of birth, location, employment details, information about your finances, and contact details.

As a controller of personal data, P Capital Partners is responsible for ensuring that the collection and processing of your personal data is done in accordance with applicable laws and regulations.

What data P Capital Partners collect, how and why

P Capital Partners and M&G group will use the personal information you provide to us, together with other information, for the purposes set out below. 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 M&G group, when you register for any of our events or information you provide via our website.

We also collect personal information about you from third parties and public sources, such as credit referencing agencies, market research, agencies working on your behalf, financial crime prevention and law enforcement agencies, service providers, bankruptcy registers, sanctions lists, tax / government / regulatory authorities, data brokers and publicly available databases/sources.

We strive to process as little personal data about you as possible for the purposes set out below. Unfortunately if you don’t provide all of the information we require this may mean we are unable to provide our products and/or services to you.

We and M&G group will use the personal information you provide to us, together with other information, for the following purposes:

• complying with any regulatory or other legal requirements and obligations
• maintaining the security of our services, as well as preventing, detecting and investigating activities that may be illegal or prohibited such as fraud or other financial crimes
• to send you any direct marketing communications we are permitted to
• keeping your information accurate and up to date on record and carrying out other internal business administration.

The legal basis for our processing of your personal data

Some of the purposes above are necessary to allow us to perform our contractual obligations to you and toenable us to comply with applicable laws and regulation. We may also rely on legitimate interests or other legalbases in using and sharing your personal information for the purposes described above, for example to improveour products and services. A legitimate interest is when we have a business or commercial reason to use your personal data including but not limited to internal administrative purposes, product development and enhancement, preventing fraud, ensuring network and information security.

To whom we disclose your data

We do not disclose your data to other companies or organisations unless required by law or necessary to perform our statutory or contractual obligations towards you, or necessary for the purposes set out above.
We may disclose your personal data to any of our partners, suppliers or subcontractors or service providers, but only if that is necessary for the purposes set out above. We never provide more personal data than is necessary for those purposes.

Your personal data is processed by members of P Capital Partners’ staff and, potentially, certain third parties such as service providers and industry advisers. Moreover, for the purposes of IT hosting and maintenance, P Capital Partners stores your personal data on servers, physical or virtual, within the European Union. No third party has access to your personal data unless they have a legal or contractual right to such information.

When required by law, we may need to disclose your data to public authorities and other organisations. We may also need to disclose your data if it is necessary to exercise, establish or monitor our legal claims.
We never disclose your personal data to other companies or businesses for marketing purposes.

M&G plc: As part of M&G group, P Capital Partners’ may disclose your personal information to any member of our group (see list of key M&G plc entities here), which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

Service providers: our service providers and third parties who provide services on our behalf include (but are not limited to) agents and administrators who we use to help run your accounts; our mailing agents; credit referencing agencies; fraud prevention and law enforcement agencies; accountants; auditors; IT service and platform providers; intermediaries; reinsurers; retrocessionaires; investment managers; agents; introducers; selected third party financial and insurance product providers, and our legal advisers.

International transfers: As P Capital Partners’ is an affiliate of M&G plc (a global company), and some of our service providers are global companies, we might need to send your personal information to countries that have different data protection laws to the European Economic Area. These transfers will only be to countries in respect of which the European Commission has issued a data protection ‘adequacy’ decision, or to other countries, such as India or the United States of America, but only where appropriate safeguards have been put in place first. In more limited circumstances, we may also need to rely on a derogation under applicable privacy laws - further information is available on request at the contact details below.

Other disclosures: Notwithstanding the terms of this Privacy Policy, we may disclose your personal data to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or
• to protect the rights, property, or safety of P Capital Partners, our service, our users and any third party we interact with to provide the services.

Protection of your personal data

P Capital Partners has implemented purpose-oriented technical and organizational measures in order to keep your personal data safe. We regularly analyse and evaluate the measures in order to ensure that protection of your data is as safe as possible.

Storage time of personal data

We will retain your personal data for as long as is necessary for the purposes described above. Typically, we will retain your personal data in accordance with the time stated in applicable law and legislation to fulfil our business purposes, to comply with legal and regulatory requirements, or for any legal claims. We may keep your data for longer where this is necessary for statistical and historical research purposes. However, we will ensure all personal data is removed where technically feasible. We will maintain the security and protection of any data we hold..

Your rights

When we process personal data about you, you have a number of data protection rights. You have the right to contact us at any time with respect to these, and if you wish to exercise any of the rights described below, you can reach us most easily at de@pcapital.se
We reserve the right to take appropriate protective and security measures in order to ensure that you are the person you claim to be when you contact us. If you cannot satisfactorily demonstrate your identity, we may not be able to respond to your request.

Access to personal data

You have the right to know what personal data we process about you. You may request a copy of your personal data for free (we may charge you for this if the request is manifestly unfounded or excessive).

Correction and deletion

If we process your personal data incorrectly or your data is inaccurate then you can request that we correct it. If we no longer need the data for any of the purposes above, you are entitled to request that it be deleted. If the data is incomplete, you have the right to request that it be supplemented. Please keep in mind that we may not be able to provide you with our services if you request to have your personal data deleted.

Data portability

In certain circumstances you have the right to receive the data that we process about you in a general, written, machine-readable and structured format. You have the right to do so for the personal data that you have provided to us and which we process with your consent or when the personal data is required to enter into or complete an agreement.

Restrictions to processing

Under certain conditions, you have the right to request that we restrict our processing of your data. This means that we mark the data so that in future we only process it for certain specific purposes. We may not be able to provide you with our services if we restrict the processing of your personal data.

Right to make objections, opt out or withdraw consent

You have the right to opt out of direct marketing, and / or object to us using your personal data for direct marketing (including related profiling) or other processing based on legitimate interests. You have the right to withdraw any consents (including for automated decision making) you have given for the processing of your personal data - this does not affect the lawfulness of our processing based on consent before its withdrawal.

Right to lodge a 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 directly with us using the contact details below. You also have the right to lodge a complaint with a data protection authority or another independent regulator about how we’re using your personal data. This includes the Swedish Authority for Privacy Protection - you can read more about this on the Swedish Authority for Privacy Protection’s website: www.imy.se.

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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.