This privacy notice (“Notice”) explains how FL Partners collects, uses, shares and otherwise processes your personal data. This Notice also describes your choices and rights regarding use, access and correction or deletion of your personal data. All your personal data will be used in compliance with the General Data Protection Regulation 2016/679 EU (the “GDPR”) and Data Protection Acts 1988 to 2018 (the “Data Protection Acts”).
Unless indicated otherwise, this Notice applies to our website and to our provision of services and assistance (the “Services”).
FL Partners fully respects your right to privacy and we are committed to ensuring that all Personal Data are:
- Processed lawfully, fairly and transparently
- Processed for specific, explicit and legitimate purposes only, and not in any manner incompatible with those purposes
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
- Accurate and, where necessary, kept up to date
- Not kept in an identifiable form for longer than is necessary for the purposes for which the personal data are processed
- Processed in a manner that ensures appropriate security of the personal below.
1. What is personal data?
Any data that identifies you, or could be used to identify you, which is submitted to and/or collected by FL Partners.
2. Who are we?
We are FL Partners, 51 Dawson Street, Dublin 2, an investment boutique, established to acquire scale businesses across Ireland, the UK, Europe and the US. In this Notice, the use of “we”, “us”, and “our” means FL Partners.
3. Application of this Notice
We collect and process information which relates to a variety of categories of individuals. These include individuals who may not have a direct relationship with FL Partners. We have described below the main types of individuals whose information we collect, use and otherwise process:
- Contacts and related individuals: We collect and use information relating to our prospective, current and former contacts. We also collect and use information relating to individuals connected with contacts and investee companies to which we provide management services, such as their employees, partners, directors, company secretaries, customers, intermediaries, investors, shareholders or beneficial owners.
- Individuals whose information is relevant to the Services: We also collect, use and otherwise process information relating to individuals where their information is considered by us or our contacts to be relevant to the Services we provide to our investee companies and contacts.
- Business and marketing contacts: In the course of providing and marketing our Services, we also collect and use information relating to visitors to our office, event invitees or attendees, and other business and marketing contacts.
4. What information do we process?
We process the following categories of personal data:
- Providing our Services: If you are client of FL Partners, we will collect and use information relating to you. While much of this information will relate specifically to the type(s) of the Services we provide to you, we will also use information as part of our administrative, financial and operational processes. This information may include your contact details, payment and financial information, [marketing profiles, including what events and communications we think you might be interested in, and client relationship and feedback information,] in addition to the information you give us so we can provide our Services to you. In carrying out this processing, we rely on the following legal bases: contractual necessity and legitimate interests (described below).
- [If you are not a client of FL Partners, we may also collect, use and otherwise process your information in the course of providing our Services to our clients where your information is considered by us or our clients to be relevant to the Services we provide to our clients. The precise information in this regard will depend on the Services we are providing. In carrying out this processing we rely on the following legal bases: legitimate interests (described below).
- CRM and business contacts: If you are a current or former client, we will include your information in our CRM database. We do so to keep in touch with your such as to send you communications and to identify what other Services we think you might be interested in. We may receive your business contact information directly from you, as a client or from business cards, or we may get information from third party sources, such as your website or professional network profile. In carrying out this processing, we rely on the following legal basis: legitimate interests.
5. Our Legal Bases
We use your personal data for the purposes outlined above, except where restricted by law. In doing so, we rely on a number of separate and overlapping legal bases to lawfully process your personal data, including where:
- necessary to perform a contract we have with you, such as our Terms of Engagement, and to provide the Services (we refer to this as contractual necessity above)
- you have consent to the processing (in which case you may revoke your consent at any time)
- necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims
- necessary for the purposes of FL Partner’s or a third party’s legitimate interests, such as those of clients, partners, staff or others, provided that those interests are not overridden by your interests or fundamental rights and freedoms; and
In particular, we use your personal data for the following purposes to pursue the legitimate interests:
- Providing our website: We will use your personal data to pursue our legitimate interest of providing our website to users.
- To operate our business: Where you have provided us with your personal data so that we may contact you in relation to specific matters, we will use personal data in this way to pursue our legitimate interest of operating our business. We will not contact you in relation any other unrelated matter, and we do not process your data for any marketing purposes.
- Improving efficiencies: We will use your personal data to pursue our legitimate interests of improving efficiencies in how we operate our website.
- Legal process: We will use your personal data when it is in our legitimate interests or necessary to preserve to defend our rights in court, to respond to law enforcement requests or discovery procedures, or where required or permitted by applicable laws, court orders, government regulations, or government authorities, which may include lawful access by courts or governmental authorities outside your country of residence.
- Safety and security: We will process your personal data for safety and security purposes as is necessary to pursue FL Partner’s legitimate interests of protecting against security risks of all types. Any such processing in this respect would also be in your legitimate interests.
6. Do we share your personal data?
We keep your information private. We don’t sell your personal data. However, in limited circumstances we may share your information with third parties. These are set out below:
- With our service providers: To a limited extent, we may share personal data with our service providers where this is necessary to provide our Services to you. Categories of service provides include IT software and hosting providers and records-storage companies. Where such service providers are processors, these third parties are contractually obliged to keep your personal data confidential, safe and secure and to use it only to provide their service to us.
- For legal and safety reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons.
- Business re-organisation: In instances where our business is subject to a re-organisation, such as a merger or acquisition of some or all of its assets, we may, in accordance with our legitimate interests, need to share information in the course of the transaction. In such circumstances, your information may be disclosed, where permitted by applicable law, in connection with a corporate restructuring, sale, or assignment of assets, merger, or other changes of control or financial status of FL Partners.
7. How long do we keep your personal data?
We will keep your information in accordance with applicable legal requirements, and only for as long as necessary for the purposes described in this Notice, or as long as required by law or to defend potential legal claims. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other mean, and the applicable legal requirements. We also consider regulatory guidance, as appropriate.
8. How do we keep your personal data secure?
We take our security responsibilities seriously and deploy appropriate organisational and technical security measures to keep personal data secure. We review our security policy regularly.
The data you provide to us is protected using SSL (Secure Socket Layer) technology, which encrypts data being transmitted over the Internet.
9. What are your rights?
You have the right to obtain a copy of your personal data in an easily accessible format. In certain circumstances, you also have the right to object to the processing of your personal data, to request the amendment or deletion of your personal data and to withdraw your consent to the processing of your personal data (where we are relying on consent as the legal basis for processing your personal data).
Without prejudice to any other rights you may have, you may file a complaint with the Irish Data Protection Commission. The Commission’s website is www.dataprotection.ie.
If you would like to exercise any of your rights or you have any questions about your rights please email us at email@example.com. Alternatively, you can contact us by telephone or post using the contact details available below.
10. International Transfers
We do not transfer personal data outside the European Economic Area.
12. Contacting us
If you have any questions regarding this Privacy Notice or our use of your personal data, please contact us using the following information:
Telephone: +353 (0)1 603 5000
51 Dawson Street
13. Changes to this Notice
We keep this notice under regular review. If we make material changes to the Notice, we will take steps to notify you, such as by posting a notice on our website.
Last updated November 2018