Our commitment to privacy
Information we may hold about you and how we obtain that information
When you visit our website, we collect the following basic information about your visit: your internet service provider’s domain name; the date, time and duration of your visit; and information about which pages of the website you have viewed. We also collect the personal data that you provide to us by using the email links under the “Contact” and “Our portfolio” sections of this Website, (i.e., name, title, address, email, date of birth, IP address, financial data, username, password, etc.). We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
We collect your personal data when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal data via email, post and telephone. We also collect information about you through automated technology.
We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. This personal data is obtained via third parties (i.e., the company in question or their advisers).
Why we use your personal data
We may use data (including the personal data of individuals) for the following purposes:
|To keep a record of your relationship with us.||Legitimate interest|
|To verify your identity.||Legitimate interest|
|To conduct due diligence activities in connection with actual or prospective corporate transactions or investments which we or our affiliates are party to.||Legitimate interest|
|Raising private equity investment funds.||Consent / legitimate interest|
|Complying with our obligations under the legal documents which govern private equity investments which we manage.||Contractual necessity|
|Fraud and abuse prevention.||Legitimate interest / legal requirement|
|Litigation management and conducting internal audits and investigations.||Legitimate interest / legal requirement|
|Administering and protecting our business and this website.||Legitimate interest|
|Complying with our legal obligations in relation to the prevention of market abuse and insider dealing where relevant to actual or prospective investments which we or our affiliates are party to (which may include the recording of telephone calls).||Legal requirement|
|Compiling statistical data on the use of our website in order to enable us to evaluate and improve our site.||Legitimate interest|
Retention of personal data
Disclosure and transfer of personal data
Please be aware that information sent to us via this website may be accessible to third parties by means of the Internet or otherwise and you should have no expectation of privacy with respect to any communications on or through this website. You should be aware that the Internet, being an open network, is not secure. If you choose to send any electronic communications to us by means of this website you do so at your own risk.
We may also disclose your information to third parties: in connection with a merger, acquisition, change of control, joint venture or other business combination involving a member of the TDR group on the basis of our legitimate interests; where you have given your consent or where we are required to do so by law, where it is necessary for the purpose of, or in connection with legal proceedings, in order to exercise or defend legal rights, to comply with a request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us.
Information collected through third-party plug-ins and widgets on the website (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and TDR is not responsible for those providers’ information practices.
Some of the third parties with whom we share your information may be located and/or have servers located outside your country or the country from which the data is provided. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws.
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact us.
Access: You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
Correction: You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
Deletion: If you think that we shouldn’t be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
Portability: If you wish to transfer your personal information to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Security of your personal data
We maintain administrative, technical and physical safeguards designed to protect personal data we obtain against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Notification of changes
If you would like to lodge a complaint about TDR’s information rights practices and how your personal data has been processed by us, you have the right to do so with your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.