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Privacy

This version was last updated on 29 April 2024.

Privacy Notice for Professional and Institutional Investors

This Privacy Notice describes how your personal data will be collected and used as a client of investment funds and solutions offered by GPMS, including Patria Capital (Europe) LLP and Patria Private Equity (Europe) Limited, part of the Patria Investments group. 

In this Privacy Notice, ‘we’, ‘us’ and ‘our’ refers to the controller(s) of your personal data, being the GPMS entity with which you have a relationship and, in some circumstances, other entities within the Patria Investments group who are responsible for processing your personal data as part of our group operations.

Patria Investments and its subsidiaries take privacy seriously and is committed to safeguarding any personal information shared. As a consumer of one or more of abrdn plc’s products or services you can be assured that personal information will only be collected and used where it is necessary, fair and lawful to do so to provide you with the agreed product or service and in line with applicable privacy & data protection laws.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We keep our Privacy Policy under regular review. We may need to make changes to this Privacy Policy so please check our website for updates from time to time. If there are important changes such as changes to where your personal information will be processed; we will contact you to let you know.

Our Cookie Policy forms part of our Privacy Policy. When you browse our websites we use cookies to store information about how you use these websites in order to improve the quality of service provided to you.

How to contact us

If you have any questions about this Privacy Notice, our controllers, or the personal information we collect and use about you in connection with the products or services we provide, please contact us at dataprotection@patria.com.

Information we collect and use

The information we collect and use about you depends on the context of your relationship or interaction with us. Where you are investing on your own behalf, this may include information required to verify your identity and to comply with Anti‑Money Laundering Regulations, such as your name, date of birth, national identifiers or tax numbers, passport details, contact details, occupation, and source of wealth. Where you are investing on behalf of a company, or representing a company, we may collect information about you, the company, and your relationship with it. We also collect information connected to the products or services you have with us, such as bank account details and email address, as well as information about your communications with us, including meetings, phone calls, emails, or letters. In addition, certain information is automatically collected through cookies when you visit our websites or access any online tools we may provide, such as your username and details about your activity on our website.

Where we collect your information

We may collect your personal information directly from you and from a variety of sources. This may include information provided through application forms for products or services, phone conversations with us, emails or letters you send, meetings with one of our client relationship managers, registrations for events, participation in research surveys conducted to help us better understand you and improve our products and services, or participation in competitions, for example to win tickets to a sporting event that we sponsor. We may also collect personal information through our online services, such as client portals, websites, and social media platforms. In addition, we may obtain personal information about you from business directories and other commercially or publicly available sources, for example to verify or improve the accuracy of the information we hold (such as your address) or to obtain better contact details where we are unable to contact you directly.

Why we collect and use your information

We take your privacy seriously and will only collect and use personal information relating to you where it is necessary, fair, and lawful to do so. We will collect and process your information only where we can satisfy one of the lawful bases for processing set out in data protection laws. This includes situations where the processing is necessary to provide the product or service you have requested, for example where you wish to invest in one of our funds or products and we therefore need to collect certain personal information such as your name, address, date of birth, and bank account details. It may also include processing that is necessary for us to comply with our legal or regulatory obligations, such as issuing Annual Statements, notifying you of changes to our Terms and Conditions, or detecting and preventing fraud. In addition, we may process your personal information where it is in our legitimate interests, including to provide appropriate information and guidance so that you are aware of the options that may help you achieve the best outcome from your product or investment, or where we need to better understand you and your needs in order to send more relevant communications about the products you hold with us and to develop new products and services. Where processing is based on our legitimate interests, we will always carry out an assessment to ensure that such use of your personal information is not excessive, unnecessary, or more intrusive than required. Finally, we may process your information where you have given us your consent, for example where we are collecting and using sensitive personal information or carrying out certain types of direct marketing. We sometimes use systems to make automated decisions based on personal information we have - or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with some of our products or services.

Who we share your information and why

We will share your information with selected third parties and with other entities within our group for the reasons described in the section “Why we collect and use your information”. This may include sharing your information with other group entities that support us in providing the products or services agreed with you or with the company you represent. We may also share your information with technology providers, software suppliers, or other service providers who assist us in communicating with you, such as internet service providers, as well as with credit reference and identity verification agencies for the purposes of identity checks and credit assessments. In addition, we may share your information with third parties that support us in delivering our products and services to you and other clients, including research firms, consultants, administrators, custodians, and technology companies that help us improve our services. Your information may also be shared with our regulators, including financial services regulators and data protection supervisory authorities, with law enforcement bodies and other agencies involved in the prevention and detection of crime, or with local tax authorities for tax relief purposes (where applicable), tax reporting, or the prevention and detection of tax fraud. We may further share your information with third parties involved in the negotiation of a sale, restructuring, or reorganisation of all or part of our business, such as professional advisers or prospective purchasers, and with relevant third parties for the purposes of responding to complaints, including the payment of any compensation. Please note that where we share your personal data with selected third parties, they may be required to retain certain information in accordance with their own regulatory obligations, for example custodians or fund managers.

Where your information is processed

The Patria Investments group is a global organisation and third parties and service providers we work with are based in locations outside of the UK and European Economic Area (EEA), including countries such as the United States, Brazil, the Philippines, Uruguay, the Cayman Islands and Chile, and so your information may be processed in these countries. Where your information is being processed outside of the UK or the EEA, we take additional steps to protect your information to at least an equivalent level as would be applied by UK or EEA Data Protection Laws e.g. we will put in place legal agreements with third parties and entities in our group with ongoing oversight requiring them to meet these obligations.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations. Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information whether it is being processed by us or a third party acting on our behalf. Our colleagues also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this. We also use internal and external audit and specialist third party consultants to conduct regular, independent assurance and benchmarking exercises across our business to ascertain the effectiveness of our security control environment and our security strategy.

How long we keep your information

To provide you with the service or product agreed, and to fulfil our legal and regulatory obligations, we will keep your personal information and copies of records we create (e.g. calls with us) while you are a prospective client or investor. Even when you no longer have a relationship with us, we are required to keep information for different legal and regulatory reasons. The length of time will vary and we regularly review our retention periods to make sure they comply with all laws and regulations.

Your rights

You have a number of rights under data protection laws, which may be exercised in certain circumstances. These rights include the right to be informed, meaning you are entitled to receive clear and easy‑to‑understand information about what personal information we hold about you, why we hold it, and who we share it with; this information is provided in our Privacy Notice on our websites and in documents such as product application forms and terms and conditions. You also have the right of access to your personal information and may request a copy of the personal data we hold about you by making a data subject access request (DSAR) and contacting us as set out in the “Contact Us” section. Where your personal information is inaccurate or incomplete, you have the right to request that it be corrected. You may also request the erasure of your personal information where there is no compelling reason for us to continue processing it. In addition, you have the right to request the restriction of processing of your personal information in certain circumstances; this means we may retain the data but will not use it for the purposes you have restricted. You have the right to data portability, which allows you to request a copy of your personal information for your own purposes and, in certain circumstances, to move, copy, or transfer that information to another organisation in a secure manner, for example where you are transferring your investments or assets to another provider. You also have the right to object to the processing of your personal information where it is based on our legitimate interests, used for direct marketing purposes (including profiling), or processed for research and statistical purposes. Finally, where you have provided your consent to the collection, processing, or transfer of your personal data for a specific purpose, you have the right to withdraw that consent at any time. If you wish to exercise any of these rights, please contact us as described in the “How to Contact Us” section.

How to make a complaint

We will always seek to collect, use, and protect your personal information in accordance with applicable data protection laws. If you believe that we have not handled your information in line with this Privacy Policy, please inform us as soon as possible, as described in the “How to Contact Us” section, and we will make every effort to resolve the matter. While we hope to address and settle any concerns directly with you, you also have the right to submit a complaint to your local data protection authority, such as the Information Commissioner’s Office (ICO) in the United Kingdom. This option is available to you whether or not you have exhausted our internal complaints procedure. The UK data protection authority, the Information Commissioner’s Office, can be contacted via its UK helpline on 0303 123 1113, from outside the UK on +44 1625 545 700, by email at casework@ico.org.uk, or through its website at https://ico.org.uk/concerns.

More information can be found on your rights here https://ico.org.uk/for-the-public If you would like to exercise any of these rights please contact your Client Relationship Manager or the Data Protection Officer (see the How to Contact us section).