Privacy Policy

OUR COMMITMENT TO PRIVACY

Your privacy is important to Sun Capital Partners, Inc., Sun Capital Advisors, Inc., Sun European Partners, LLP and our affiliates (together “Sun European”, ‘our’, ‘us’, ‘we’ or ‘company’). To better protect your privacy, we are providing information explaining our online information practices.

 

This Privacy Policy describes how we gather and use information for visitors of this site. Please read this Privacy Policy carefully.

 

For the purposes of applicable EU laws, Sun Capital Partners, Inc. and Sun European Partners LLP will each be a data controller of any personal data collected by us. If you have any questions regarding Sun European’s use of your personal data, or this Privacy Policy, please contact Antony Levinson at alevinson@suncappart.com.

 

We rely on various legal bases under applicable data protection legislation in order to process your personal information (e.g., name, address, email, IP address etc.), including our legitimate interests, contractual necessity and as required by law. Sun European uses the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations.

 

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations). Failure to provide this information means that we cannot provide our services or products to you).

 

Further information about the legal bases under which we process your personal information is included in the section headed “Why we use your personal information”

 

You do not need to take any action as a result of this Privacy Policy, but you do have certain rights as described below in the section headed “Your rights”.

 

HOW WE OBTAIN YOUR PERSONAL INFORMATION
Information you provide to us

 

We collect your personal information 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 information via email, post and telephone. This includes name, address, job title, position and email address. We may also collect information about you through technology.

 

Information provided by third parties

 

We also process information in relation to companies that Sun European is evaluating in connection with its potential investment in or purchase of such companies. This personal information is obtained via third parties (i.e., the company in question).

 

WHY WE USE YOUR PERSONAL INFORMATION

To the extent that you provide us with any personal information (i.e., name, address, email, job title, address etc.), through or in connection with this site (i.e., via telephone, email or post), we may use such information for the following purposes:

 

PurposeLegal Basis
To provide you with the services or financial products you have requested.Contractual necessity
To keep a record of your relationship with us.Legitimate interest
To verify your identity.Legal requirement and legitimate interest
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which Sun European is party to.Legitimate interest
Fraud and abuse prevention.Legal requirement and legitimate interest
Litigation management and conducting internal audits and investigations.Legal requirement and legitimate interest

We will send you direct marketing communications where we have obtained your prior consent to keep you informed of our products and services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by emailing Antony Levinson at alevinson@suncappart.com. You can also click on the “opt-out” link provided in all our marketing emails.

 

No automated decision making, including profiling, is used when processing your personal information.

 

DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our site; any transmission of information or data by you to or through this site is at your sole risk.

 

Sun Capital Partners, Inc. (our affiliate) is located in the US. To the extent any personal information is transferred from Sun European or an affiliate within the EEA to a Sun European affiliate outside the EEA, this transfer is legitimised and your personal information is adequately protected under the terms of the EU controller-to-controller model contract clauses.

 

Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including professional advisors, recruitment firms, consultants and data hosting providers. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. 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. For further information about the safeguards used, please contact Antony Levinson at alevinson@suncappart.com.

 

We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving Sun European (e.g., to the FCA, SEC and HMRC). Should Sun European, or any affiliated entity of Sun European, be the subject of a takeover, divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors.

 

SECURITY AND RETENTION OF PERSONAL INFORMATION

 We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law (e.g., 6 years from the date of collection, as required under FCA, SEC and IRS regulations). We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact Antony Levinson at alevinson@suncappart.com.

 

AUTHORITY AND CAPACITY

You represent to Sun European that you have the authority to visit this site according to the Terms and Conditions. This site is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.

 

COOKIES

Information regarding how you access this site (e.g., browser type, access times, and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for Sun European’s business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this site, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this site. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.

 

YOUR RIGHTS

You have the right to access the personal information 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 Antony Levinson at alevinson@suncappart.com.

  • Access: You have the right to ask for a copy of the personal information that Sun European holds 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 such 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.

NOTIFICATION OF CHANGES
We reserve the right to amend this Privacy Policy from time to time by updating this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the Privacy Policy under which the information was collected.

 

MISCELLANEOUS

The Miscellaneous provisions in our Terms and Conditions are hereby incorporated by reference.

 

CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact Antony Levinson (Senior Vice President and Corporate Counsel) at Antony Levinson at alevinson@suncappart.com.

 

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal information has been processed by Sun European, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.