Privacy
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.
We are committed to safeguarding any personal information shared with us and take our privacy obligations seriously.
This Privacy Notice 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.
When you browse our website we use cookies to make our site secure and to ensure it works properly. We also use cookies to store information about how you use our website to improve the quality of services provided. We may also use cookies for targeting purposes. Cookies can be removed at any time by following the appropriate instructions on your Internet browser. If you use your browser settings to block all cookies (including essential cookies) or reject particular cookies you may not be able to access all or parts of our website. We do not require your consent to set ‘Strictly necessary’ cookies on your device; however, you can choose whether to accept or reject other types of cookies we use in our cookie preference centre. Cookies and similar tracking technologies will also be used in some of our emails; you can choose to block these via your device settings, but they are useful to help us understand if you have opened an email and how you responded to it. To understand more about the type of cookies we use and how to set these preferences, visit our cookie preference centre.
We keep our Privacy Notice under regular review. This version was last updated on 29 April 2024. We may need to make changes to this Privacy Notice 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. We may also notify you in other ways from time to time about the processing of your personal information.
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
Information about you that we collect and use depends on the context of your relationship or interaction with us but may include:
• Where you are investing on your own behalf, information about who you are in order to verify your identity and comply with Anti-Money Laundering Regulations e.g. your name, date of birth, national identifier/tax numbers, passport details, contact details, occupation, and source of wealth
• Where you are investing on behalf of a company, or representing a company, information about you, the company, and your relationship
• Information connected to the product or service you have with us e.g. bank account details, email address
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected via cookies when you visit one of our websites or access an online tool we may provide, e.g. username, your activity on our website.
Where we collect your information
We will collect your personal information directly from you, and from a variety of sources, including:
• An application form for a product or service with us
• Phone conversations with us
• Emails or letters you send to us
• Meetings with us
• Registering for one of our events
• Participating in research surveys to help us understand you better and improve our products and services
• Via our website
• Entering competitions e.g. to win tickets to a sporting event which we sponsor
• External third parties who support us in verifying your identity and relationships with our corporate clients
We may also collect personal information about you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to obtain updated contact information if we are unable to contact you directly.
Why we collect and use your information
We will collect and use your information in accordance with the lawful processing conditions set out in applicable data protection laws, as follows:
• It’s necessary to provide the product or service you have with us e.g. when you, or the company you represent, invest in one of our funds or products, we will require some personal information from you which may include your name, address, date of birth, and bank account details
• It’s necessary for us to meet our legal or regulatory obligations e.g. to send you important information including any changes to a product’s legal Terms and Conditions, to do appropriate money laundering checks, or for the detection and prevention of fraud
• You have given us your permission [consent] to use your information e.g., if we are collecting and using your sensitive personal information, or for certain types of direct marketing
• It’s in our legitimate interests to process your information to better understand you and your needs so we can:
o Send you postal communications from time to time to make you aware of other relevant products and services available from us
o Deliver appropriate information and guidance so you are aware of the options that may help you get the best outcome from your product or investment
o Conduct research and collate management information to understand how clients have interacted with us, which products and services they have already purchased or invested in, and to help us send more relevant communications based on our analysis of clients’ preferences and needs. This may also include analysing complaints for the purposes of improving services and processes
o Compensate you as appropriate due to service, process or regulatory failures
Where the processing is in our legitimate interests, we will always conduct an assessment to ensure that this use of your personal information is not excessive or unnecessary or otherwise more intrusive than it needs to be. If you wish to object to this processing, please contact us (see Contact Us section).
In addition to the uses above, please note that we may also process your information where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process. 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 other entities in our group for the reasons outlined in ‘Why we collect and use your information’.
We will also share your information with:
• Other entities in our group who support us in the provision of the products or services agreed with you, or the company you represent
• Various technology companies, software suppliers, or companies who can help us in our contact with you, for examples an internet service provider
• Credit and identity check agencies for ID verification and credit reference checks
• Third parties we have chosen to support us in the delivery of the products and services we offer to you and other clients. For example, research, consultancy, administrators, custodians, or technology companies who help us improve our services to you
• Our regulators; including Financial Service and Data Protection Supervisory Authorities
• Law enforcement and other appointed agencies who support us (or where they request the information) in the prevention and detection of crime; and
• Local tax authorities for the purposes of tax relief (where relevant), tax reporting, or the prevention and detection of tax fraud
• Third parties in the negotiations of a sale, restructure or re-organisation of all or part of our business e.g. professional advisers or prospective purchasers
• Third parties, where relevant, for the purposes of responding to complaints, including the payment of any compensation.
Please note that where we share your personal data with our selected third parties, they may be required to retain some data in line with their own regulatory obligations e.g. 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 are:
Right to be informed
You have a right to receive clear and easy to understand information on what personal information we hold, why, and who we share it with – we do this in our Privacy Notice on our websites and within, for example, product application forms and terms and conditions.
Right of access
You have a right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (‘DSAR’) by contacting us [see Contact Us section]
Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure of your personal information
You can ask for your information to be deleted or removed if there is not a compelling reason for us to continue to have it.
Right to restrict processing of your personal information
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving your investments/assets to another company.
Right to object to processing of your personal information
You can object to us processing your personal information where: it is based on our legitimate interests; for direct marketing (including profiling); and if we were using it for research and statistics.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
If you would like to exercise any of these rights please contact us [see the How to Contact us section].
How to make a complaint
We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please let us know immediately and we will do our utmost to make things right.
While we hope that we can resolve any complaints for you, you do have the option to complain to your local data protection authority. This is available to you whether or not you have exhausted our complaints procedure.
The UK data protection authority’s details are:
The Information Commissioner’s Office
Phone helpline (UK): 0303 123 1113
Phone helpline (outside UK): +44 1625 545 700
Email: casework@ico.org.uk
Website: https://ico.org.uk/concerns
For EU markets, you can find details of your Supervisory Authority on the
European Data Protection Board website.
For any other regional details, please contact us.