Cipio Partners respects the privacy of every individual whose personal information it handles. This Privacy Policy explains how Cipio Partners collects, stores and uses personal information.

Where used in this Policy, “Cipio Partners” means Cipio Partners GmbH and Cipio Partners S.à r.l. as the case may be, or any of its subsidiaries or related companies. For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented (the “Data Protection Laws”), the Cipio Partners company that you have dealings with is the controller of your personal information.

Personal information of business contacts

If you have had contact with Cipio Partners, for example through emailing us or meeting a Cipio Partners’ representative, we may store limited amounts of personal information relating to you, such as your name, job title, employer organisation and contact details. We will collect and store this personal information for the purposes of:

• maintaining a record of contacts
• providing periodic business updates as described below
• inviting you to presentations and events and organising meetings between you and Cipio Partners’ representatives

The personal information we hold about business contacts may be shared with:

• companies who process personal information on Cipio Partners’ behalf, such as providers of cloud hosting solutions
• professional advisors, such as auditors, accountants, lawyers or other consultants
• other companies belonging to the Cipio Partners group

In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.

Personal information of suppliers and professional advisors

If you are a supplier to Cipio Partners, or one of its professional advisors, we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal information for the purposes of:

• administering and maintaining records of services or advice we have received, and commissioning further services.

The personal information we hold about suppliers and professional advisors may be shared with:

• companies who process personal information on Cipio Partners’ behalf, such as providers of cloud hosting solutions
• professional advisors, such as auditors, accountants, lawyers or other consultants
• other companies belonging to the Cipio Partners group

In accordance with the Data Protection Laws, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business.

Personal information of actual or potential management teams and shareholders of portfolio companies

If you are involved in a transaction that Cipio Partners and/or the funds that it manages or advises enters into, or a potential transaction that Cipio Partners considers, we may store personal information relating to you. This might include your name, job title, qualifications, employer organisation, contact details as well as your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out. We collect and store this information for the purposes of:

• assessing potential transactions
• maintaining records of investments
• administering any transaction that we enter into
• assessing your suitability for involvement in a transaction, including by verifying your identity
• complying with our regulatory and legal obligations, including assessing and managing risk
• safeguarding our legal rights and interests
• seeking and receiving advice from our professional advisors, including auditors, accountants, lawyers and other consultants
• providing periodic business updates, as described below

The personal information we hold about actual or potential management teams and shareholders of portfolio companies may be shared with:

• companies who process personal information on Cipio Partners’ behalf, such as providers of cloud hosting solutions and third-party outsourced services providers
• professional advisors, such as auditors, accountants, lawyers or other consultants
• other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Cipio Partners transaction, including co-investors, other providers of finance and investors in Cipio Partners’ funds
• other companies belonging to the Cipio Partners group

In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running our business, in particular by considering potential investments, and administering transactions that we enter into. If we enter into a transaction that you are involved in, it will also be necessary for us to process your personal information for the purpose of performing the respective legal agreements and contracts and to comply with our regulatory and legal obligations.

Personal information of investors of Cipio Partners’ funds

The personal details of all our investors who hold direct participations in one or more Cipio Partners funds, or details of the nominee accounts in which some retail and institutional shareholders hold their participations, are held and maintained by Cipio Partners. Investor information is collected and maintained on our behalf for the purposes of:

• complying with our regulatory and legal obligations
• communicating with investors (including the mailing, in physical or electronic format, of quarterly and annual reports, notices for general meetings or proxy cards, or communications in relation to other corporate actions)
• facilitating capital calls, distribution notices and the payment of distributionsperforming mandatory reporting requirements, such as AML, CRS and FATCA Reporting
• tax filings

The personal information we hold about shareholders may be shared with:

• companies who process personal information on Cipio Partners’ behalf, such as our transfer agent and registrar and providers of cloud hosting solutions
• professional advisors, such as tax advisors, auditors, accountants, lawyers, proxy advisers or other consultants
• financial institutions and authorities and other companies in the Cipio Partners group.

In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and operating our business, ensuring effective communications with shareholders and complying with mandatory reporting requirements.

Mandatory provision of information

We will explain to you when the provision of particular information is mandatory, including the possible consequences of not providing particular information, for example, preventing us from proceeding with a transaction involving you. Cipio Partners will only process the personal information you provide to Cipio Partners for the purposes listed above.

Sensitive or special category personal data

Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. Please do not send us sensitive personal data as generally we do not need it.

International transfers of personal information

Cipio Partners has operations in Luxembourg and Germany. As such, the personal information that we hold may be transferred to, and stored at, Luxembourg and/or Germany. Where we transfer personal information to Cipio Partners group companies or other third parties outside of the European Union, we will ensure that those transfers take place in accordance with the Data Protection Laws, including by entering into data transfer agreements with recipients. If you would like more information about how your personal information may be transferred, please contact us (see “Cipio Partners Data Privacy Contacts” below).

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

We do actively use cookies. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

By using our website without adjusting your web browser to block them, you are consenting to cookies being stored on your device.

Google Analytics

With your consent we use Google Analytics to optimize our website.

Allow Google Analytics Deny Google Analytics

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

Periodic business updates

We may use personal information that we hold to send you periodic updates about Cipio Partners’ business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us (see “Cipio Partners Data Privacy Contacts” below), or by clicking the “Unsubscribe” link in any email that you receive.

Retention of personal information

The period for which Cipio Partners will retain personal information will vary depending on the purposes it was collected for, as well as the requirements of any applicable law or regulation. For example, if you provide us with your information as investor of a Cipio Partners fund, we will keep your information for ten (10) years from the date of dissolution of the respective Cipio Partners fund.

Your rights

Individuals whose personal information we hold may be entitled to access their personal information, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to us (see “Cipio Partners Data Privacy Contacts” below). Individuals also have the right to complain about the use of their personal information to the responsible national supervisory authority, which is in Luxembourg the Commission Nationale pour la Protection des Données (https://cnpd.public.lu/de.html) and in Germany the Landesamt für Datenschutzaufsicht (https://www.lda.bayern.de).

Accuracy and security

Cipio Partners will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that Cipio Partners holds about you is incorrect, please notify Cipio Partners (see ”Cipio Partners Data Privacy Contacts” below).

Cipio Partners will take all reasonable steps to protect the confidentiality and security of your personal information but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Cipio Partners responsible for any breach of security unless this is due to Cipio Partners’ negligence or wilful default.

Cipio Partners’ websites may contain hypertext links to external websites. Cipio Partners is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

Cipio Partners Data Privacy Contacts

For all enquiries, please email AOIEVaW5mb0BjaXBpb3BhcnRuZXJzLmNvbQ==.

For Germany, please contact:
Cipio Partners GmbH
Ottostr. 8
80333 Munich
Tel +49 89 55 06 96 0

For Luxembourg, please contact:
Cipio Partners S.à r.l.
12E, rue Guillaume Koll
1882 Luxembourg
Tel +352 26 20 10 54

Changes to Cipio Partners’ Privacy Policy

Any changes to this Privacy Policy will be posted here, so please check Cipio Partners’ Privacy Policy on a regular basis when you visit any Cipio Partners website.