Data protection privacy notice

We are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect about you.

What is personal information?

Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and email address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a website cookie.

Who we are

This privacy notice is provided by Glennmont Partners (“Glennmont”; the “firm”; “we”; “our”) which covers the FCA-authorised entities – Clean Energy Partners LLP, Glennmont Partners I Limited and Glennmont Asset Management Limited and our subsidiaries.

We are the Controller of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact our Compliance Officer using the details set out below:

Name of relevant contact: Toby Bishop

Email address: [email protected]

Postal address:  201 Bishopsgate, 9th Floor, London, EC2M 3BN

Contact telephone number: +44 (0)208 092 4219

You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

What types of information do we use?

We collect information in the course of providing our services to you. The information which we collect, use, store and transfer about you may include, but is not limited to:

• contact information such as name, email address, mailing address, phone number;
• information to verify the accuracy of your identity;
• information about your business role, such as job title and company name; and
• information about your interests in our services.

If you apply for or enquire about a job with us we may also ask you to provide details of your previous job title, your employment history, a copy of your CV and references – and we may also seek references and carry out checks with third parties if appropriate for the role you have applied for. If you are successful in your application this information may change.

We do not collect any special categories of personal data which would include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data. We ask that you do not send us any personal data that would fit these categories unless specifically requested to do so.

How do we collect information about you?

Typically, we will collect information from you when you contact us directly or provide information in order for us to provide our products and services. We collect information from and about you in the following ways:

Through direct interactions when you give us your personal information by filling in forms or during correspondence with us. This includes when you:

• invest in one of our funds;
• send us your CV;
• meet with us in person or talk to us face to face.

Through third parties such as credit reference agencies and fraud prevention agencies.

We may also receive personal information from other companies and organisations such as placement agents or other introducers.

How we will use your personal information

We only obtain, use and keep personal information where we need it for a specific purpose. We set out below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected.  Most commonly we will use your information in the following ways:

• We have a contract with you. For example, we have agreed to provide financial advice or to manage investments for you and have a contractual agreement to do this.
• We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example, this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
• We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to prevent fraud.

We set out in the table below all the ways we plan to use your personal information and the legal bases we rely on to do so. We also explain what our legitimate interests are where appropriate:

We will only use your personal information for the reason for which we collected it.  We will only use it for another reason if we believe that new reason is compatible with the original purpose. If we do need to use your personal information for a non-related purpose we will tell you about it and explain the legal basis which allows us to do so.

Marketing

We can use your personal information to send you communications if we believe we have a ‘legitimate interest’. We are required to make an assessment with regards to the benefits for us weighed against how appropriate it is to contact you in this way and whether it would be unfair to you. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products or services and we will only do so if we decide it would be of interest or beneficial for you.

You may opt-out of receiving any marketing information from us in any form by contacting the Compliance Officer.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

Cookies

Cookies are small text files placed on your computer (or other device where you access the internet) used to collect information on your activities online. They can also be used as part of website functionality. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website by tailoring it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

If you have concerns about cookies, this website explains how you can delete and control the cookies that are stored on your computer: https://www.aboutcookies.org/

Who we share your information with

We will only share your Personal Data with third parties in the ways set out in this privacy statement. We do not give, sell or rent your Personal Data to third parties for them to market their services to you. Nor do we accept advertising from third parties on our website.

We may provide your Personal Data to our service providers to help us with our business activities, such as inputting your contact information into our CRM or email marketing system. In all cases we will have a processor agreement with these companies safeguarding your Personal Data, including that it may only be processed for the purposes of that agreement and on our instructions. We may also disclose your Personal Data as follows:

• For the operation of our business, to other entities and service providers within Glennmont Partners.
• For provision of the Services, and for our own disaster recovery and business continuity purposes, we may store or transmit Personal Data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyse our business.
• We may be obliged to disclose your Personal Data to comply with a law, order or request of a court, government authority, other competent legal or regulatory authority or any applicable code of practice or guideline.
• We may also be obliged to disclose Personal Data when we believe in good faith that disclosure is necessary for our legitimate interest such as investigating fraud, to make or defend a legal claim, to protect your safety or the safety of others, or to maintain our compliance or that of our personnel with applicable laws, regulations and/or professional obligations, all in accordance with applicable law.
• If Glennmont Partners is involved in a merger, acquisition, or sale of all or a portion of its assets, we may disclose such Personal Data as is necessary for our legitimate interests in completing that transaction and always provided that appropriate safeguards are in place including limitations and restrictions on use, access and retention.
• In other situations, only with your prior consent.

Sending your information outside of the EEA

The regulations which have been put in place to protect your privacy apply throughout the EEA. The EEA is the European Economic Area which includes all the countries in the European Union plus Iceland, Liechtenstein and Norway. This means that any country within the EEA must meet the same privacy standards as the United Kingdom. All the personal information that we hold about you will be processed in the EEA.

Storing your information

As a financial services provider we will typically have a contract with you and will need to keep your personal information (updated to ensure accuracy) to fulfil our contract. We also need to comply with the legal requirements of multiple jurisdictions, including the EU and UK, which often requires us to keep certain records – which will include certain personal information – for several years.

Our policy is to keep records on prospective investors, management teams and other business contacts indefinitely; we may wish to contact long-standing contacts about a particularly relevant opportunity in the future, and in the context of our business there is no way to predict when such an opportunity might arise. We will ensure all records are safely destroyed if we no longer need to retain them. We review our retention periods for personal information on a regular basis.

Your rights

You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you to:

• access your information;
• request we correct your information;
• request that we erase your information;
• object to the processing of your information;
• request a restriction in the processing of your information;
• request a transfer of your information; and
• withdraw your consent.

If you wish to exercise any of these rights please contact the Compliance Officer. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.

Security

We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.